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DETAILED RESEARCH · EVIDENCE & LIMITS INCLUDED

A003: Federal additional-signer, spousal-signature, and cosigner-notice rules—and their limits as proof of who owes

R003 · pass-01Captured 2026-10-2713 tables · 66 claim records · 28 source recordsScoped coordinator review completed

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

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SettleADebt R003 PASS-01

A003: Federal additional-signer, spousal-signature, and cosigner-notice rules—and their limits as proof of who owes

Actual check date: October 27, 2026, America/Los_Angeles. The final clock check during research was 14:11:30 PDT / 21:11:30 UTC.

This investigation used fresh public primary-source retrieval in this regular Chat. No prior research report was supplied or reused. No institution, borrower, account, property, licensing record, or case docket was investigated. Published judicial opinions were consulted only for the narrow guarantor/applicant issue. No forms were completed, no identifiers were entered into record-search systems, and no files or external publications were created. No independently verified UI model selection or separate GPT-6 Pro run is claimed.

1. The controlling distinction

Three questions must remain separate:

  1. May a covered creditor require this particular additional signature?
  2. Must a covered creditor deliver a cosigner notice before the proposed signer becomes obligated?
  3. What personal obligation, guaranty, or property exposure was actually created under the applicable agreement and law?

Regulation B primarily answers the first question. The FTC Credit Practices Rule answers the second for its covered actors and transactions. Neither supplies a complete answer to the third. In particular, Regulation B distinguishes documents needed to make collateral available from instruments imposing personal liability, and the FTC notice expressly says it is not the liability-creating contract. Consumer Financial Protection Bureau+2

The principal results are:

  • A creditor generally cannot require an individually qualified applicant to add a spouse or another personal obligor. But the property, income-reliance, additional-party, business-guaranty, and special-purpose-program branches have distinct conditions.
  • A genuine joint application requires evidence of contemporaneous joint intent. Marriage, joint assets, a joint financial statement, and signatures on a later promissory note cannot simply be substituted for that evidence.
  • A covered FTC cosigner must receive the prescribed disclosure before becoming obligated. The rule includes certain additions of a cosigner in exchange for forbearance on an already-defaulted obligation.
  • The FTC rule does not apply identically to banks, savings institutions, federal credit unions, and other creditors. Repealed institutional rules, continuing statutory authority, and supervisory guidance must be distinguished.
  • A prohibited signature demand or defective notice does not, without further authority and facts, establish automatic cancellation, release, unenforceability, a private cause of action, or an award.

The detailed propositions, conditions, and limits follow in the claim tables.

2. Currentness and authority controls

For all source tables below:

  • D means the actual access/check date, 2026-10-27, America/Los_Angeles.
  • Fresh means read during this investigation, not imported from another chat or report.
  • A House U.S. Code compilation date is the publisher’s stated legislative cutoff. It is not a completed session-law lag audit.
  • A CFPB page marked current is the agency’s currently published regulation. An eCFR currency label is not a claim that a complete annual official CFR edition was checked.
  • PDF page indexes are zero-based. Printed page numbers are separately identified.
  • Repeated clauses, mirrors, or publisher copies of the same underlying document are not treated as independent corroboration.

A material currentness finding is the April 22, 2026 Regulation B final rule, effective July 21, 2026. Its changes to special-purpose-credit-program provisions matter to this pass. Its effective-date discussion distinguishes credit extended before and on or after that effective date. I used the currently published §1002.8 rather than assuming older commentary remained unchanged. The relevant final-rule passages and amendment instructions were read; the entire 51-page preamble was not. No comprehensive judicial stay/vacatur or later-treatment audit was performed. govinfo.gov+3

Source table

Source ID Title / issuer and complete literal HTTPS URL(s) Exact pinpoint and read extent Version, status, jurisdiction, and check limits
R003-P1-S001 15 U.S.C. §1691, Scope of prohibition — House OLRC. https://uscode.house.gov/us/usc/119-121/t15/s1691/ Necessary operative text: §1691(a), (b), and (c), including marital inquiry and special-program provisions; relevant amendment/effective-date notes. Other displayed provisions were not used for a general adverse-action survey. Fresh; D. Compilation through Public Law 119-121, October 9, 2026. Federal statute; no complete post-compilation session-law audit.
R003-P1-S002 15 U.S.C. §1691a, Definitions; rules of construction — House OLRC. https://uscode.house.gov/us/usc/119-121/t15/s1691a/ Complete operative subsections (a)–(g), including statutory applicant, credit, creditor, person, and regulatory-reference provisions; displayed amendment notes. Fresh; D. Compilation through October 9, 2026. Statutory definition must be distinguished from the regulation’s special guarantor inclusion.
R003-P1-S003 15 U.S.C. §1691d, Applicability of other laws — House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1691d/ Complete operative (a)–(g); particular reliance on lien/property signatures, state property law, narrowly framed separate-credit preemption, and state-law preservation/exemption provisions. Fresh; D. Compilation through Public Law 119-124, October 15, 2026. No all-state property or remedies analysis.
R003-P1-S004 15 U.S.C. §1691e, Civil liability — House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1691e/ Operative body retrieved; used principally (a), (c), and (e): aggrieved-applicant liability, court-granted equitable/declaratory relief, and good-faith conformity protection. No deadline or award calculation. Fresh; D. Compilation through October 15, 2026. Does not resolve a particular guarantor’s statutory entitlement, jurisdiction, defenses, or remedy.
R003-P1-S005 12 C.F.R. §1002.1, Authority, scope and purpose — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/1/ Complete operative section and official comments 1(a)-1 through -3. Fresh; D. Agency labels current. U.S. lending, including Puerto Rico and territories; generally excludes lending outside the U.S. Part-specific motor-vehicle-dealer exclusion is expressly distinguished from ECOA itself.
R003-P1-S006 12 C.F.R. §1002.2, Definitions — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/2/ Complete necessary clauses: (e)–(j), (l)–(n), (q), (u), (w), (x), (z), (aa); relevant official comments to (e), (f), (g), (j), (l), (w), and (z). Fresh; D. Agency labels current. No general scoring, adverse-action, TILA, or debt-classification survey inferred from incidental displayed text.
R003-P1-S007 12 C.F.R. §1002.3, Limited exceptions — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/3/ Complete (a)–(d) and associated comments; especially (b)(2)(vi), (c)(2)(v), and (d)(2). Fresh; D. Agency labels current. Essential limits on applying §1002.7(d) to securities, incidental, and government credit.
R003-P1-S008 12 C.F.R. §1002.7, Rules concerning extensions of credit — CFPB; eCFR cross-check. https://www.consumerfinance.gov/rules-policy/regulations/1002/7/ ; https://www.ecfr.gov/current/title-12/chapter-X/part-1002/section-1002.7 Complete §7(d)(1)–(6) and every accompanying official comment; also complete relevant §7(a), §7(c), and comments. The CFPB body is the substantive reading source. Fresh; D. CFPB labels current. Initial eCFR page showed Title 12 currency through October 23, 2026; later canonical retrieval encountered an access challenge. No workaround; see failure log.
R003-P1-S009 12 C.F.R. §1002.6, Evaluation of applications — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/6/ §6(b)(8), relevant marital-status commentary, and §6(c), concerning equal standards and state property law. Fresh; D. Agency labels current. Only provisions necessary to signature/property distinctions used.
R003-P1-S010 12 C.F.R. §1002.11, Relation to state law — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/11/ Complete operative section and displayed comments; relied on (a), (b), (d), and (e). Fresh; D. Agency labels current. State property law remains a separate inquiry; no state-by-state preemption determination made.
R003-P1-S011 12 C.F.R. §1002.8, Special purpose credit programs — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/8/ Complete current operative (a)–(d) and all displayed official comments. Signature sentence in (d); program prerequisites in (a)–(b); information provision in (c). Fresh; D. Agency labels current. Current 2026 program conditions used; no actual program eligibility or compliance finding.
R003-P1-S012 Equal Credit Opportunity Act (Regulation B), final rule — CFPB, 91 FR 21620. https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07804.pdf Printed p.21620 / index 0, summary and effective date; pp.21658–21659 / indexes 38–39, relevant §8 discussion and effective-date section; pp.21668–21670 / indexes 48–50, relevant amendment instructions and revised §8 commentary. Fresh; D. Final, published April 22, 2026; stated effective July 21, 2026. Not a full 51-page read or judicial-status certification.
R003-P1-S013 Appendix B, Model Application Forms — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/b/ ; linked Form 1 images: https://files.consumerfinance.gov/f/images/cfpb_regulations_ER21DE11-046.original.png and https://files.consumerfinance.gov/f/images/cfpb_regulations_ER21DE11-047.original.png Complete introductory instructions 1–3 read. Image routes returned image markers, but their pixels were not available for verified visual inspection; no image-field transcription relied upon. Fresh; D. Optional official models; limited inquiry-compliance effect under §1002.5(b)–(d). Worksheet below relies on operative clauses and official commentary, not unseen form pixels.
R003-P1-S014 12 U.S.C. §5519, motor-vehicle-dealer exclusion — House OLRC. https://uscode.house.gov/us/usc/119-124/t12/s5519/ Relevant (a)–(d), including activity-based exclusion, statutory carvebacks, preserved other-agency authority, and FTC rulemaking provision. Fresh; D. Compilation through October 15, 2026. Exact classification of any dealer and complete counterpart-Regulation-B treatment remain untested.
R003-P1-S015 16 C.F.R. part 444, Credit Practices — FTC / eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-444 Entire operative §§444.1–444.5 read, including complete definitions, §444.3(a)–(c), complete prescribed notice, and §444.5 exemption conditions. Fresh; D. eCFR Title 16 currency through October 23, 2026; source note 49 FR 7789, March 1, 1984. FTC-jurisdiction consumer transactions; no complete annual-CFR/session-history audit.
R003-P1-S016 Complying with the Credit Practices Rule — FTC staff business guidance. https://www.ftc.gov/business-guidance/resources/complying-credit-practices-rule Complete page read; relied on “Introduction,” “What Transactions Are Covered,” “How Exemptions Are Granted,” and “Notice to Cosigners.” Fresh; D. December 2006 booklet, edited January 2025 for penalty information. Still published; staff guidance, not amended regulatory text. Historical bank-counterpart statements are not used as current coverage proof.
R003-P1-S017 Cosigning a Loan FAQs — FTC Consumer Advice. https://consumer.ftc.gov/articles/cosigning-loan-faqs Complete page read; particularly obligations, state collection sequence, real-estate-purchase notice qualification, language, copies, and release advice. Fresh; D. Dated April 2024; generic advice. Broad introductory statements must be read subject to controlling actor/transaction coverage.
R003-P1-S018 FTC Act jurisdiction, definitions, and rulemaking provisions — House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s44/ ; https://uscode.house.gov/us/usc/119-121/t15/s45/ ; https://uscode.house.gov/us/usc/119-124/t15/s57a/ Necessary §44 definitions; §45(a)(1)–(2); §57a(f)(1)–(4), (g)(1)–(3), and 2010 amendment/effective-date notes. Fresh; D. §45 compilation through October 9; other two through October 15, 2026. Grouped statutory usage, not three independent confirmations. No actual entity classification.
R003-P1-S019 12 U.S.C. §§5531 and 5536 — House OLRC. https://uscode.house.gov/us/usc/119-121/t12/s5531/ ; https://uscode.house.gov/us/usc/119-121/t12/s5536/ Operative §5531(a)–(f) and §5536(a)–(b), including covered-person/service-provider framework, unfairness conditions, and statutory prohibitions. Fresh; D. Compilation through October 9, 2026. Separate statutory UDAP/UDAAP analysis; no institution-specific enforcement finding.
R003-P1-S020 Unfair or Deceptive Acts or Practices (Regulation AA), final repeal — Federal Reserve, 81 FR 8133–8134. https://www.govinfo.gov/content/pkg/FR-2016-02-18/pdf/2016-03228.pdf Complete relevant Federal Reserve final-rule body, printed pp.8133–8134 / indexes 0–1; neighboring agency material excluded. Fresh; D. Published February 18, 2016; effective March 21, 2016. Removes former 12 C.F.R. part 227; explains statutory-authority repeal and non-transfer of that rulemaking authority.
R003-P1-S021 Unfair or Deceptive Acts or Practices; Technical Amendments — NCUA, final rule. https://www.govinfo.gov/content/pkg/FR-2014-10-03/pdf/2014-22715.pdf Complete part-706 discussion at p.59627 / index 0; relevant procedural discussion p.59628 / index 1; operative removal instruction 3 at p.59629 / index 2. Unrelated organizational amendments not treated as fully researched. Fresh; D. Effective October 3, 2014. Part 706 removed and reserved; continuing statutory authority expressly discussed.
R003-P1-S022 Thrift-rule history — OCC and Treasury. OCC integration rule: https://www.govinfo.gov/link/fr/76/49047 . Treasury, Removal of Office of Thrift Supervision Regulations: https://www.govinfo.gov/content/pkg/FR-2017-10-11/pdf/2017-21904.pdf OCC: summary/effective-date material at printed p.48950 / index 0 of a 250-page PDF; not the complete republication. Treasury: complete relevant item at pp.47083–47084 / indexes 0–1, including chapter-V removal instruction. Fresh; D. OCC document effective July 21, 2011. Treasury final published October 11, 2017; its printed DATES says October 11, 2018. No correction was verified. Treasury describes non-substantive removal of obsolete/superseded provisions.
R003-P1-S023 Interagency Guidance Regarding Unfair or Deceptive Credit Practices — Federal Reserve, CFPB, FDIC, NCUA, OCC. https://www.federalreserve.gov/frrs/guidance/interagency-guidance-regarding-unfair-or-deceptive-credit-practices.htm Complete guidance body and footnotes 1–12; especially footnote 9 on former OTS part 535 and footnote 11 on continued notice use. Fresh; D. Issued August 22, 2014. Guidance status checked separately in S024–S025. Its historical future-tense repeal statements are not current-rule statements.
R003-P1-S024 Publisher status pages for the same joint guidance. Federal Reserve: https://www.federalreserve.gov/supervisionreg/caletters/caltr1405.htm ; OCC: https://www.occ.gov/news-issuances/bulletins/2014/bulletin-2014-42.html ; NCUA: https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/unfair-or-deceptive-credit-practices Relevant publisher-page bodies read. NCUA letter 14-FCU-03 explicitly displays Active; Fed/OCC pages remained published without an observed rescission banner. Fresh; D. These are status checks of one underlying guidance document, not independent legal authorities. FDIC publisher retrieval failed; see log.
R003-P1-S025 Guidance and Withdrawn Guidance registers — CFPB. https://www.consumerfinance.gov/compliance/guidance/ ; https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/ Current index’s 2014 credit-practices entry; withdrawal-register body checked, including relevant ECOA entries and absence of the joint credit-practices item. Fresh; D. Index last modified June 15, 2026; withdrawal register July 22, 2026. Existing-credit advisory withdrawn May 12, 2025; special-purpose-program advisory withdrawn June 17, 2026. Those withdrawn advisories are not operative support here.
R003-P1-S026 Proposed Regulation AA status — CFPB. Withdrawal: https://www.govinfo.gov/content/pkg/FR-2025-05-15/pdf/2025-08645.pdf ; older proposal page: https://www.consumerfinance.gov/rules-policy/rules-under-development/prohibited-terms-and-conditions-in-agreements-for-consumer-financial-products-or-services-regulation-aa/ ; 2026 agenda: https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16603.pdf Complete withdrawal item, printed p.20569 / index 0; complete older landing-page body; relevant CFPB priorities statement at printed p.52943 / index 151 of 2026 agenda. Not the entire agenda or proposal. Fresh; D. Proposal withdrawn May 15, 2025; August 2026 agency statement again identifies that withdrawal. Old proposal landing page is not proof of a final/current obligation.
R003-P1-S027 Hawkins v. Community Bank of Raymore, 761 F.3d 937 — Eighth Circuit published opinion. https://www.govinfo.gov/content/pkg/USCOURTS-ca8-13-03065/pdf/USCOURTS-ca8-13-03065-0.pdf Complete majority body, slip pp.1–8 / indexes 0–7; especially pp.3–6 and 8. Separate concurrence not relied upon as the holding. Fresh; D. Filed August 5, 2014; Eighth Circuit. Published summary-judgment appellate decision. Later history checked only to S028; no comprehensive later-treatment or current circuit survey.
R003-P1-S028 Hawkins v. Community Bank of Raymore, 577 U.S. 495 — Supreme Court. https://www.govinfo.gov/content/pkg/USREPORTS-577/pdf/USREPORTS-577-495.pdf Complete published disposition, printed p.495 / index 0. Fresh; D. March 22, 2016; judgment affirmed by an equally divided Court. No reasoned Supreme Court majority resolving the statutory issue.

3. Atomic claim table: ECOA coverage and the statutory/regulatory boundary

All claim IDs below have the prefix R003-P1-. All claims are in area A003.

Type: Text = statute/regulation; Comment = codified official interpretation; Guidance = published agency explanation; Opinion = published judicial holding/disposition; Synthesis = expressly labeled analytical conclusion; Unknown = an unresolved application or authority question.

Claim ID Area / type Precise assertion and operative conditions Limits and exceptions Source / exact pinpoint
R003-P1-C001 A003 / Text ECOA prohibits a creditor from discriminating against an applicant concerning any aspect of a credit transaction on the enumerated bases, including sex and marital status. This is a credit-discrimination prohibition, not a federal determination that every spouse owes, or that every debt arrangement is covered credit. S001, §1691(a). uscode.house.gov
R003-P1-C002 A003 / Text + Comment ECOA credit concerns a right to defer payment, incur debt and defer payment, or acquire property/services and defer payment. Regulation B generally reaches personal and commercial credit; its basic credit definition does not require a finance charge or a particular installment count. The specific §1002.3 exceptions still matter. This does not rerun TILA or FDCPA coverage. S002, §1691a(d), (f); S005, comment 1(a)-1; S006, §2(g), (h), (j), comment 2(j)-1. uscode.house.gov+1
R003-P1-C003 A003 / Text + Comment Statutory creditor includes regular extenders, renewers, continuers, arrangers, and participating assignees. Regulation B’s operative definition includes regular participation in credit decisions, including setting terms, and participating assignees/transferees/subrogees. The additional referral-only definition expressly applies to §4(a)–(b); it cannot automatically be carried into §7(d). The definition also limits responsibility for another creditor’s violation where there was no prior knowledge or reasonable notice, and excludes merely honoring a credit card. S002, §1691a(e); S006, §2(l), comments 2(l)-1–2. Consumer Financial Protection Bureau
R003-P1-C004 A003 / Text + Comment A Regulation B application can be oral or written under the creditor’s actual procedures. Actual practice matters, not only the creditor’s written application policy. Ordinary use within an existing credit limit is excluded from this application definition. This claim does not decide every inquiry/prequalification or adverse-action issue. S006, §2(f), comments 2(f)-1–2. Consumer Financial Protection Bureau
R003-P1-C005 A003 / Text Statutory applicant under §1691a(b) and regulatory applicant under §1002.2(e) are not identically worded. The regulation expressly includes guarantors, sureties, endorsers, and similar parties for §1002.7(d). That express regulatory inclusion does not itself settle statutory claimant status, standing, available defenses, or a private remedy in every court. S002, §1691a(b); S006, §2(e); S027–S028. uscode.house.gov+2
R003-P1-C006 A003 / Text + Synthesis Regulation B defines contractual liability by an express agreement to repay all debts arising on an account. The definition does not authenticate a signature, establish authority, resolve formation, or transform an account label, access permission, or credit-report entry into that agreement. S006, §2(i); S008, comment 7(a)-1. Consumer Financial Protection Bureau+1
R003-P1-C007 A003 / Text Extensions of credit include refinancing, renewals, consolidation, additional credit, and certain continuations at or after maturity. Credit transaction includes dealings concerning existing credit as well as applications. This broad lifecycle coverage does not make every modification a new guaranty or automatically trigger release; the particular renewal comment has its own conditions. Regulation B’s open-end definition also excludes negotiated advances under an open-end real-estate mortgage or letter of credit. S006, §2(m), (q), (w), comment 2(w)-1. Consumer Financial Protection Bureau
R003-P1-C008 A003 / Text + Comment Part 1002 generally applies to U.S. lending, including Puerto Rico and U.S. territories, and excludes persons covered by the specified §1029 motor-vehicle-dealer exclusion. That is an exclusion from this part, not from ECOA itself. Section 5519 contains activity-based carvebacks. Exact counterpart-Regulation-B treatment for such an actor is not completed here. S005, §1(a), comments 1(a)-1–2; S014, §5519(a)–(d). Consumer Financial Protection Bureau
R003-P1-C009 A003 / Text Section 7(d) does not apply to securities credit as defined in §3(b)(1): credit regulated under Securities Exchange Act §7, or credit by a broker/dealer regulated as such under that Act. This is the specified signature-rule exception, not permission for every discriminatory practice and not a ruling on an actual securities obligation. S007, §3(b)(1), (b)(2)(vi). Consumer Financial Protection Bureau
R003-P1-C010 A003 / Text + Comment Section 7(d) does not apply to defined incidental consumer credit: other than utility/securities credit, not under a credit-card account, not subject to a finance charge as defined in §1026.4, and not payable by agreement in more than four installments. All stated definitional conditions matter. “Four” is an installment-count condition in §3(c)(1)(iii), not an invented qualification or payment schedule. A deferral can still be ECOA credit even though this exception applies. S007, §3(c)(1), (c)(2)(v), comment 3(c)-1. Consumer Financial Protection Bureau
R003-P1-C011 A003 / Text + Comment Credit to governments, subdivisions, agencies, or instrumentalities is exempt from the part’s requirements except §4(a)’s general nondiscrimination rule. Credit by a government agency to consumers is not within that exception merely because the creditor is governmental. S007, §3(d), comment 3(d)-1. Consumer Financial Protection Bureau
R003-P1-C012 A003 / Text + Comment The defined public-utility-credit exception does not remove §7(d). Its listed exceptions concern specified marital-information and retention provisions. The definition requires the specified service/facility and government-filed or regulated charges. Financing unrelated goods or improvements is not utility-service credit merely because a utility provides it. S007, §3(a), comments 3(a)-1–3. Consumer Financial Protection Bureau
R003-P1-C013 A003 / Text ECOA permits consideration/application of state property laws and recognizes signatures serving lien, title, inchoate-right, or earnings purposes, subject to the statutory prohibition on discriminatory creditworthiness evaluation. Regulation B preserves state property and estate laws and preempts inconsistent credit-discrimination law only to the stated extent. This is not a uniform federal marital-property or recourse code. Married and unmarried applicants remain subject to equal evaluation standards except as law permits. S003, §1691d(a), (b), (f); S009, §6(b)(8), (c); S010, §11(a), (d). uscode.house.gov+1
R003-P1-C014 A003 / Text Section 1691d(c) addresses a particular case: state law prohibits separate consumer credit, each spouse voluntarily applies separately to the same creditor, and that state prohibition is preempted; its sole-responsibility proviso applies in that specified setting. It must not be converted into a blanket statement that every separately named marital debt is solely one spouse’s debt under all state law. S003, §1691d(c). uscode.house.gov
R003-P1-C015 A003 / Opinion + Unknown The Hawkins Eighth Circuit majority held that executing a guaranty alone did not make the claimants statutory applicants; it rejected their reliance on the predecessor regulatory definition. It affirmed summary judgment on the ECOA claim/defense; state-law counterclaims had been dismissed without prejudice. The Supreme Court affirmed by equal division. The Supreme Court supplied no reasoned nationwide merits resolution. The appellate opinion used the then-operative Chevron framework; no claim is made that this is today’s general review framework. Current forum-specific treatment, statutory entitlement, Article III issues, and remedy remain unverified. S027, slip pp.3–8 / indexes 2–7; S028, p.495 / index 0. govinfo.gov+2

The precise guarantor question left open

The unresolved question is not whether the current regulation contains the word guarantor: it does. The unresolved application is whether a person who is only a guarantor can invoke ECOA as a statutory applicant in the relevant court and procedural posture, and what claim, defense, or remedy that court recognizes. The single appellate majority and Supreme Court disposition read here do not support a uniform national answer. No unseen decision from another circuit is treated as read.

4. Atomic claim table: every significant signature branch

These rows assume the relevant actor and transaction are subject to §1002.7(d), unless a row identifies an exception.

Claim ID Area / type Precise assertion and operative conditions Limits / what remains unproved Source / exact pinpoint
R003-P1-C016 A003 / Text + Comment For individual credit, a creditor generally must first determine that the applicant does not independently qualify before requiring another signer. If the applicant qualifies for the requested amount and terms, the creditor cannot require a spouse’s or another non-joint applicant’s signature on a credit instrument, subject to the paragraph’s exceptions. A neutral policy requiring everyone to obtain a cosigner does not defeat this protection. The business-role guaranty exception below is material. No actual qualification is assessed here. S008, §7(d)(1), comments 7(d)-1–2 and 7(d)(1)-1. Consumer Financial Protection Bureau
R003-P1-C017 A003 / Comment A joint applicant applies contemporaneously for shared or joint credit. Someone added because the creditor demands another signature as a condition of approval is not thereby a joint applicant. The joint-applicant exception permits obtaining the genuine applicant’s signature; it does not itself establish the scope or enforceability of a later contractual promise. S008, comment 7(d)(1)-2. Consumer Financial Protection Bureau
R003-P1-C018 A003 / Text + Comment Joint intent must be evidenced at application. Application signatures or initials affirming joint-credit intent may establish it, separately from accuracy certification. A promissory-note signature may not serve as the required proof of application-stage joint intent. A joint financial statement, joint-asset evidence, marriage, or shared household must not silently become a joint application. A financial-statement signature certifying accuracy is insufficient. S008, §7(d)(1), comment 7(d)(1)-3. Consumer Financial Protection Bureau
R003-P1-C019 A003 / Comment For unsecured credit supported by jointly owned property, the creditor must value the applicant’s own interest. It may not condition the extension on the nonapplicant owner’s signature if that interest supports the requested amount and terms. Joint title alone does not demonstrate a need for another signature. Actual ownership form, valuation, legal access, and the requested terms remain necessary facts. S008, comment 7(d)(2)-1. Consumer Financial Protection Bureau
R003-P1-C020 A003 / Comment Valuation may consider the existing ownership form, attachability, execution, severance or partition, resulting value, and associated costs. The creditor cannot premise the demand on speculative later changes such as divorce or a future transfer into a different tenancy. S008, comment 7(d)(2)-1(i). Consumer Financial Protection Bureau
R003-P1-C021 A003 / Text + Comment If the applicant relies on joint property for unsecured credit and the interest is insufficient, the creditor may pursue the stated alternatives: an appropriate additional party, secured credit, or instruments necessary/reasonably believed necessary under the property-situs state’s law to reach the relied-on property upon death or default. Property-access instruments should not impose personal liability unless state law makes that necessary. The commentary rejects routine demands for an instrument, such as a quitclaim deed, that forfeits the other owner’s interest. S008, §7(d)(2), comment 7(d)(2)-1(ii). Consumer Financial Protection Bureau
R003-P1-C022 A003 / Comment The official commentary says a creditor’s reasonable belief about necessary instruments should be supported by a thorough review of pertinent statutory and decisional law or a state attorney-general opinion. This is not permission based solely on a creditor’s preference. It does not prescribe a particular retained memorandum or decide whether an actual legal analysis was reasonable. S008, comments 7(d)(2)-2 and 7(d)(4)-2. Consumer Financial Protection Bureau+1
R003-P1-C023 A003 / Text + Comment The unsecured community-property branch requires a married applicant who resides in a community-property state or relies on property there; a necessary/reasonably necessary state-law instrument; both inadequate management/control of sufficient community property under state law and insufficient separate property to qualify without community property. Marriage or a community-property-state connection alone is insufficient. The residency comment allows a residence assumption unless the applicant indicates otherwise; it does not supply missing property-control law. S008, §7(d)(3)(i)–(ii), comment 7(d)(3)-1. Consumer Financial Protection Bureau
R003-P1-C024 A003 / Text For secured credit, a creditor may require spouse/other signatures on instruments necessary or reasonably believed necessary under applicable state law to make the offered security available on default—for example, to create a lien, pass title, waive inchoate rights, or assign earnings. Permission is tied to the legal collateral purpose. It is not a general permission to make every owner a personal guarantor. S008, §7(d)(4); S003, §1691d(a). Consumer Financial Protection Bureau+1
R003-P1-C025 A003 / Comment If a mortgage or security agreement alone makes the property available, the creditor may not require the spouse to sign the note. If state law actually requires both spouses’ note signatures for an enforceable lien, the commentary permits them. The relevant state rule must be identified; an assumption that every mortgage requires personal repayment liability is inadequate. S008, comments 7(d)(4)-1–2. Consumer Financial Protection Bureau
R003-P1-C026 A003 / Comment A combined note/security instrument cannot be required where only a security-interest signature is needed unless the instrument clearly limits the spouse’s signature to granting security and excludes personal liability; a nearby legend is an example. The commentary does not mandate one magic phrase. Actual instrument language, capacity, and applicable law still control what was signed. S008, comment 7(d)(4)-3. Consumer Financial Protection Bureau
R003-P1-C027 A003 / Text When an additional party’s personal liability is necessary under the creditor’s standards to support the requested credit, the creditor may request a cosigner, guarantor, endorser, or similar party. The spouse may serve, but the creditor cannot insist that the spouse be the additional party merely because a supporting obligor is needed. S008, §7(d)(5). Consumer Financial Protection Bureau
R003-P1-C028 A003 / Comment A creditor may impose eligibility conditions on additional parties, such as residence in its market area. Such conditions cannot discriminate on sex, marital status, or another prohibited basis. They cannot be used to disguise an otherwise prohibited spouse-only requirement. S008, comment 7(d)(5)-1. Consumer Financial Protection Bureau
R003-P1-C029 A003 / Comment An individual applicant actually relying on another person’s income may be required to obtain that person’s signature to make the income available. This includes a spouse’s income outside community-property treatment and a spouse’s separate income in a community-property state. The commentary separately permits, but does not require, a spouse’s signature where future earnings are not community property until earned—even if the creditor normally requires a nonspouse income-provider’s signature. Actual income reliance and state characterization are essential. S008, comment 7(d)(5)-2; S009, §6(c). Consumer Financial Protection Bureau
R003-P1-C030 A003 / Comment A creditor may require personal guarantees from business partners, directors, officers, and shareholders of closely held corporations even if the business itself is creditworthy, when based on that business relationship. The requirement cannot depend on a prohibited basis—for example, only married officers or only businesses associated with a protected group. This is not a universal exemption for all business-related additional signers. S008, comment 7(d)(6)-1. Consumer Financial Protection Bureau
R003-P1-C031 A003 / Text + Comment Additional parties receive the relevant signature protections. A creditor cannot automatically demand a guarantor’s spouse’s signature. The commentary allows a further signature in appropriate financial circumstances under §7(d)(2); that incorporates the property-access conditions, not unlimited permission for a spouse’s personal guaranty. S008, §7(d)(6), comment 7(d)(6)-2. Consumer Financial Protection Bureau
R003-P1-C032 A003 / Comment If creditworthiness is reevaluated when an obligation is renewed, the creditor must determine whether an additional party remains warranted and release that party if not warranted. This is a conditional federal release duty. It is not automatic expiration at every renewal, nor does business creditworthiness alone eliminate a permissible business-role guaranty. Effect on prior obligations and release mechanics remains a contract/state-law issue. S008, comment 7(d)(5)-3, read with comment 7(d)(6)-1. Consumer Financial Protection Bureau
R003-P1-C033 A003 / Text + Comment For an existing open-end account, specified adverse changes cannot be triggered merely by age, retirement, name, or marital-status change absent evidence of inability/unwillingness to repay. Reapplication based on marital change requires the stated spouse-income reliance and income-insufficiency information; the comment also addresses loss of another supporting person. During permitted reapplication, existing contractual access continues. Joint-account closure requests or repudiation of responsibility for future charges are separately addressed. No inference of release from existing debt follows merely from closing an account. S008, §7(c)(1)–(2), comments 7(c)(1)-1–2 and 7(c)(2)-1. Consumer Financial Protection Bureau
R003-P1-C034 A003 / Comment + Synthesis A creditor may condition authorized-user designation on that user becoming contractually liable, without prohibited discrimination. For an overdraft line attached to a transaction account, it may require all persons authorized to draw to assume overdraft liability. Permission to require an agreement is different from proof that an agreement exists. Mere account access or authorized-user status does not prove the express undertaking. S008, comments 7(a)-1–3; S006, §2(i). Consumer Financial Protection Bureau+1
R003-P1-C035 A003 / Text Section 8(d) permits specified marital/support-income/spouse-resource inquiries where financial need is a special-purpose-program criterion. Its separate signature sentence permits obtaining a spouse’s or another person’s signature on a program application or credit instrument if Federal or state law requires it. A program label or creditor preference does not satisfy the signature condition. Section 8(c)’s information permission is not a free-standing authorization to demand any spouse’s guaranty. S011, §8(c)–(d). Consumer Financial Protection Bureau
R003-P1-C036 A003 / Text + Comment The special-program branch requires a qualifying §8(a) program: legally authorized assistance for an economically disadvantaged class; qualifying nonprofit assistance; or a qualifying for-profit program meeting the written-plan and need conditions. Current for-profit rules require the plan’s specified class, procedures, evidence, and explanation of otherwise-unavailable credit; additional conditions govern otherwise-prohibited common characteristics. Current §8(b)(3) bars race, color, national origin, and sex as for-profit-program eligibility characteristics; §8(b)(4) requires participant-specific evidence for other otherwise-prohibited characteristics. Anti-evasion and other Regulation B provisions remain applicable. No actual program is evaluated. S011, §8(a)(1)–(3), (b)(1)–(4), comments 8(a)-1–6 and 8(b)-1–2. Consumer Financial Protection Bureau
R003-P1-C037 A003 / Text + Currentness The 2026 final rule states that special-program credit extended on or after July 21, 2026 must comply with its new requirements; prior extensions must comply with the applicable earlier program rules described in its effective-date discussion. A preexisting program is not thereby authorized to make all future extensions indefinitely under old rules. This pass does not certify absence of later judicial orders. S012, printed pp.21620, 21658–21659 / indexes 0, 38–39. govinfo.gov+1
R003-P1-C038 A003 / Text + Synthesis Appendix B models are optional. Appropriate use/modification yields the specified compliance treatment for §1002.5(b)–(d) inquiries. That limited effect is not a general contract-formation, guaranty-enforceability, joint-intent, or liability safe harbor. S013, introductory paragraphs 1–3; S008, comment 7(d)(1)-3. Consumer Financial Protection Bureau

5. Atomic claim table: FTC coverage, notice, and evidentiary limits

Rows C048–C051 contain every substantive element of the prescribed notice in original paraphrase. They are a research explanation, not replacement compliance wording. The controlling published wording is at S015, §444.3(c).

Claim ID Area / type Precise assertion and operative conditions Limits / exceptions Source / exact pinpoint
R003-P1-C039 A003 / Text Part 444’s creditor is a covered lender or retail installment seller: lending money to consumers, or selling goods/services on deferred-payment or lease-purchase terms, within FTC jurisdiction. Consumer means a natural person seeking/acquiring goods, services, or money for personal, family, or household use. Section 444.3 concerns consumer credit in or affecting commerce. Its broad definition of debt—money due or alleged due—does not erase these actor, purpose, obligation, and commerce conditions. Business credit is not brought within this consumer rule merely by adding a natural-person guarantor. S015, §444.1(a)–(g), §444.3(a). ecfr.gov
R003-P1-C040 A003 / Text FTC Act §45(a)(2) excludes banks, savings-and-loan institutions, and federal credit unions as statutorily defined, along with other enumerated categories, from the FTC’s stated enforcement jurisdiction. “Credit union” is not synonymous with “federal credit union.” Nor does “nonbank” alone establish coverage. Section 44’s organizational definition and §57a(f)’s institution definitions matter; no actual status was investigated. S018, §§44, 45(a)(2), 57a(f)(2)–(4); S015, §444.1(a)–(b). uscode.house.gov+2
R003-P1-C041 A003 / Guidance Published FTC materials describe the rule as excluding real-estate purchases, while covering qualifying consumer loans secured by already-owned real estate. This is the FTC’s published scope explanation, not an express real-estate-purchase phrase in §444.1. Do not convert it into an exclusion of every real-estate-secured loan or every mortgage-related transaction. S016, “What Transactions Are Covered”; S017, “What Are My Obligations…”. Federal Trade Commission+1
R003-P1-C042 A003 / Text A cosigner under §444.1(k) is a natural person who becomes liable for another’s obligation without compensation. The definition expressly includes a signature demanded to extend credit to another or to forbear collection of another’s defaulted obligation. The rule is not confined to new-money originations. The underlying consumer-credit and actor requirements still apply. S015, §444.1(k). ecfr.gov
R003-P1-C043 A003 / Text + Guidance Someone receiving no goods, services, or money in return for the credit obligation receives no compensation for this definition; labels do not control. FTC guidance distinguishes a genuine co-buyer sharing purchased goods or co-borrower sharing proceeds from a supporting cosigner. A “co-borrower” caption cannot dispose of contrary facts. Conversely, a primary purchaser is not made a covered cosigner merely because another person also signs. Shared household membership alone does not establish the actual benefit or contractual role. S015, §444.1(k); S016, “Notice to Cosigners,” final paragraphs. ecfr.gov+1
R003-P1-C044 A003 / Text + Guidance The rule expressly excludes a spouse whose signature is required to perfect a state-law security interest. FTC guidance also says no notice is needed for a security-agreement signer who has no personal liability. A document that also imposes a personal undertaking requires analysis of its actual terms; “property owner” is not a universal cosigner exemption. S015, §444.1(k); S016, “Notice to Cosigners.” ecfr.gov+1
R003-P1-C045 A003 / Text Section 444.3(a)(1) prohibits direct or indirect misrepresentation of the nature or extent of cosigner liability to any person. Section 444.3(b) states that compliance with paragraph (c)’s preventive requirements does not violate paragraph (a). Paragraph (b)’s statement concerns the specified paragraph (a); it is not a universal contractual-enforceability or all-laws immunity provision. S015, §444.3(a)(1), (b). ecfr.gov
R003-P1-C046 A003 / Text The creditor must inform the cosigner before obligation and give the prescribed disclosure before that event. For open-end credit, the specified event is execution of the agreement creating liability for future charges. Delivery after obligation does not satisfy the express prior-delivery condition. No fixed number of advance days is stated here. S015, §444.3(a)(2), (c). ecfr.gov
R003-P1-C047 A003 / Text The regulatory disclosure is a separate document containing the prescribed statement, without other statements under the literal rule. Section 444.3 does not specify a numerical font size. Staff explanations concerning permitted administrative additions and packet placement are separately classified below. S015, §444.3(c). ecfr.gov
R003-P1-C048 A003 / Text — notice element 1 Under the heading Notice to Cosigner, the opening paragraph says the recipient is being asked to guarantee the debt, should consider that choice carefully, will have to pay if the borrower does not, and should assess both ability and willingness to accept that responsibility. This is the complete opening warning in paraphrase, not a finding that an enforceable guaranty has already been formed. S015, §444.3(c), heading and first notice paragraph. ecfr.gov
R003-P1-C049 A003 / Text — notice element 2 The second paragraph warns of possible responsibility for up to the entire debt if the borrower fails to pay, and possible late fees or collection costs increasing the amount. It supplies no calculation of an actual balance, permissible charge, or award. S015, §444.3(c), second notice paragraph. ecfr.gov
R003-P1-C050 A003 / Text — notice element 3 The third paragraph warns that the creditor can seek payment from the cosigner without first trying the borrower; can use the same collection methods, including suit or wage garnishment; and that default may enter the cosigner’s credit record. This warning is not an independent grant of collection powers or an override of state collection-sequence protections, contract terms, exemptions, or required judicial procedures. S015, §444.3(c), third notice paragraph; S017, state-law qualification immediately following the notice. ecfr.gov+1
R003-P1-C051 A003 / Text — notice element 4 The final paragraph states: “This notice is not the contract that makes you liable for the debt.” Notice receipt, including an acknowledgment, must not be substituted for the actual liability-creating instrument. S015, §444.3(c), final notice paragraph. ecfr.gov
R003-P1-C052 A003 / Guidance FTC staff permits letterhead, identifying details, an optional receipt-signature line, consistent state notices, and omission of a statement inaccurate under state law. It forbids distracting additions and permits attachment only when the notice comes first in the packet. Its guidance says revolving-account notice is given once at opening; FTC advice says it should match the agreement’s language. These are published implementation explanations; they do not amend the literal regulation or establish a general notice-expiration/cancellation rule. No identifying details were entered here. S016, “Notice to Cosigners”; S017, language paragraph. Federal Trade Commission+1
R003-P1-C053 A003 / Text + Synthesis Part 444 does not itself prescribe a signed acknowledgment, fixed notice-retention period, or periodic notice-expiration interval. An acknowledgment may evidence receipt, but its presence does not establish every delivery condition. Absence of a document from a reviewed set is not automatically proof of nondelivery. Other retention, disclosure-copy, electronic-delivery, or evidentiary laws are not negated by this limited reading. S015, complete §§444.1–.5; S016, optional acknowledgment/file-copy explanation. ecfr.gov+1
R003-P1-C054 A003 / Guidance FTC consumer advice recommends obtaining relevant papers and arranging statements/default alerts. That advice is not a universal affirmative duty under part 444 to deliver every loan paper or later account statement. Product-specific and state-law rights remain outside this finding. S017, “If I Cosign a Loan, What Can I Do To Protect Myself?” Consumer Advice
R003-P1-C055 A003 / Text Under §444.5, an appropriate state agency must apply, and the FTC must determine that an effective state requirement affords substantially equivalent or greater protection. The federal provision then ceases to operate only to the extent specified and while effective state administration/enforcement continues. Stronger state law alone is not an automatic exemption. Specific currently operative exemption determinations were not verified in this pass. S015, §444.5(a)(1)–(2) and concluding condition. ecfr.gov
R003-P1-C056 A003 / Text FTC Act §57a(g) separately permits petitions for person/class exemptions and specifies the Commission’s finding and procedural requirements. Petition or review pendency does not itself stay the rule. No exemption is inferred merely from a request or from a failed source retrieval. S018, §57a(g)(1)–(3). uscode.house.gov
R003-P1-C057 A003 / Text + Synthesis A missing or late required notice raises a compliance issue under §444.3. The read provisions do not establish automatic debt cancellation, release, a notice-based rescission period, uniform unenforceability, or a private cause of action. An actual remedy requires the applicable enforcement/remedies authority, forum, contract, state law, and facts. The FTC booklet dates the rule’s operation to March 1, 1985; that historical trigger is distinct from this report’s access date. S015, §444.3; S016, introduction and effective-date discussion. ecfr.gov+1

What the notice proves—and what it does not

A sufficiently authenticated notice and delivery record can help establish what warning was supplied, to whom in a stated role, and when. It cannot by itself establish the promise, the signer’s authority, the agreement’s enforceability, the amount due, a valid lien, a collection priority, or a lawful remedy.

Likewise, an empty notice field or absent copy is an evidence gap until the delivery history is established. When the assumed fact is actual late delivery after obligation, the timing condition is not met; that still does not select the remedy. These are separate findings under C046, C051, C053, and C057.

6. Atomic claim table: institutional changes, guidance status, and remedies

Claim ID Area / type Precise assertion and operative conditions Status / jurisdiction / limits Source / exact pinpoint
R003-P1-C058 A003 / Text + Final-rule history Dodd-Frank repealed the former institution-specific FTC Act rulemaking authority. The Federal Reserve’s final rule formally removed former Regulation AA, 12 C.F.R. part 227, effective March 21, 2016. It explains that the statutory repeal nullified the relevant provisions and that Regulation AA did not transfer to CFPB under the FTC Act. The 2010 enactment date, designated-transfer-date provision, and 2016 formal removal are distinct. The FTC’s own part 444 remained a separate rule. S018, §57a(f)(1), 2010 effective-date note; S020, pp.8133–8134 / indexes 0–1. uscode.house.gov+1
R003-P1-C059 A003 / Final rule NCUA removed and reserved part 706 effective October 3, 2014. Its final rule expressly retained the distinction between repealed regulations and continuing statutory supervisory/enforcement authority. A federal-credit-union notice obligation cannot simply be asserted today by citing former §706 as a current rule. S021, p.59627 / index 0; removal instruction 3, p.59629 / index 2. govinfo.gov+1
R003-P1-C060 A003 / Guidance + Final-rule history The joint agencies explained that former OTS part 535 was omitted from OCC republication because the relevant authority was unavailable and was effectively repealed July 21, 2011. Treasury later directed removal of obsolete OTS chapter V as non-substantive cleanup. The complete 2011 republication was not independently reconstructed. The 2017 Treasury document’s printed effective date is October 11, 2018; no correction was verified. Neither document is treated as creating a new cosigner-notice duty. S023, footnote 9; S022, OCC p.48950 / index 0; Treasury pp.47083–47084 / indexes 0–1. federalreserve.gov+2
R003-P1-C061 A003 / Text Separate federal statutory prohibitions remain relevant. Section 5531 addresses UDAAP involving covered persons/service providers and consumer financial products/services; §5536 contains operative prohibitions. Section 45 supplies the FTC Act prohibition, with enforcement and actor qualifications. Statutory unfairness has specified injury, avoidability, and countervailing-benefit conditions; a regulatory repeal does not establish that every former practice is permissible. These statutes do not themselves reproduce §444.3(c)’s exact notice as a universal institutional obligation. S018, §45(a); S019, §§5531(a)–(d), 5536(a); S020–S021. uscode.house.gov+3
R003-P1-C062 A003 / Verified publisher status As checked on D, CFPB’s guidance index still listed the 2014 credit-practices guidance, its withdrawal register did not list that item, and NCUA expressly marked its accompanying letter Active. Fed and OCC publisher pages remained posted without an observed rescission banner. FDIC publisher status remains unresolved: both attempted official pages returned 403. The verified statuses are stated agency by agency; publication of an old document alone was not treated as a complete currentness check. S024–S025; failure F04 below. Consumer Financial Protection Bureau+4
R003-P1-C063 A003 / Guidance + Synthesis The 2014 guidance says repeal is not a determination that former practices are permissible; statutory violations depend on facts and circumstances. Footnote 11 expresses the agencies’ view that continuing to provide a notice before obligation properly discloses cosigner liability. This is a supervisory interpretation, not a newly enacted regulation applying the FTC’s exact affirmative notice duty to every exempt institution, and not an independently created private right. Operative assertions must rest on current statutes/rules. S023, guidance body and footnote 11; S019–S021. federalreserve.gov
R003-P1-C064 A003 / Withdrawal / history The CFPB’s proposed Regulation AA was withdrawn May 15, 2025. Its August 2026 regulatory-priorities statement again identifies the withdrawal. The remaining proposal landing page does not make the proposal final or revive former Federal Reserve Regulation AA. No new universal cosigner-notice obligation is established by these materials. S026, withdrawal p.20569 / index 0; agenda p.52943 / index 151. govinfo.gov+2
R003-P1-C065 A003 / Text + Synthesis ECOA’s civil-liability provisions address an aggrieved applicant and authorize specified court relief; they also include a good-faith-conformity protection. A signature-rule violation is therefore not itself a complete adjudication of contract invalidity or of a particular claimant’s remedy. Statutory applicant status, court/claim posture, state defenses, relief, and later authority remain separate. No damages, limitation-period, or litigation-strategy analysis is supplied. S004, §1691e(a), (c), (e); S027–S028. uscode.house.gov+2
R003-P1-C066 A003 / Synthesis The audit must distinguish application intent, capacity, express promise, security consent, notice delivery, and governing property law. Evidence of one cannot automatically stand in for all the others. Neither household relationship, marriage, credit reporting, account access, nor an official model notice alone proves actual personal liability. This is an evidentiary limit of the researched federal sources, not a ruling that other law can never impose an obligation. S006, §2(i); S008, comments 7(d)(1)-3 and 7(d)(4)-3; S010, §11(d); S015, §444.3(c). Consumer Financial Protection Bureau+4

Institution coverage must be stated conditionally

Generic institutional class What this pass establishes What it does not establish
FTC-covered nonbank lender or retail installment seller Part 444 can impose the notice duty when its consumer-credit, cosigner, timing, and exemption conditions are met. That every nonbank or every transaction is covered.
Statutorily defined bank Do not apply part 444 solely because the activity resembles consumer lending. Former part 227 is repealed; separate statutory and guidance analysis remains. A universal current bank notice obligation, or freedom to misrepresent liability.
Statutorily defined savings institution Former OTS rule history must be separated from current statutory powers and any other applicable law. That an obsolete part-535 citation proves a present affirmative duty.
Federal credit union FTC jurisdictional exclusion and NCUA’s part-706 repeal are material. NCUA’s guidance-status page is Active. That repeal permits every formerly prohibited practice.
State-chartered credit union or uncertain institutional class The federal-credit-union exclusion cannot be assumed to cover it; FTC jurisdiction and other applicable law need their own analysis. Actual charter, organizational, insurance, regulatory, or transaction status. No roster was used.

This table is a synthesis of C039–C040 and C058–C064, not an institution classification.

7. Complete blank generic-document liability/signature audit worksheet

Purpose: identify what a generic document review would need to establish. Every finding field remains blank. The worksheet neither requests actual borrower records nor authorizes searches, contacts, filing, or verification of real identities.

The legal anchors are the official clauses and interpretations identified above, including §1002.7(d), §1002.2(i), Appendix B’s limited instructions, and §444.3(c). No invented borrower entries or fabricated executed instruments are supplied.

Worksheet item Question to resolve Evidence or published authority needed Blank finding Claim links
W01 — Engagement and transaction What credit, purchase, or service arrangement is described, and what question about the signature is being asked? Complete generic engagement/application and transaction terms; primary purpose; deferral structure. C002, C004, C039
W02 — Creditor role Which legal actor category and credit-decision role is relevant? Stated legal capacity and applicable statutory definitions; decision participation versus referral-only role. No entity lookup. C003, C008, C040
W03 — Transaction exceptions Does a securities, incidental, government, utility, special-program, or FTC exemption branch apply? Complete defining conditions and any applicable published exemption determination. C009–C012, C035–C037, C055–C056
W04 — Application request Was individual or joint credit actually requested under the applicable procedures? Complete application, instructions, and generic description of oral/written procedures. C004, C016–C018
W05 — Joint intent Is joint-credit intent evidenced at application independently of accuracy certification? Separate intent affirmation and its timing; distinguish later note execution and joint financial statements. C017–C018
W06 — Additional-signature condition Was the signer voluntarily applying, or added because the creditor demanded support? Application conditions, approval conditions, and the stated reason for requesting the signature. C016–C018, C027
W07 — Individual qualification premise What standards and requested amount/terms make the qualified/unqualified branch relevant? Applicable standards and the stated evaluation basis; no invented score or numerical qualification. C016, C019, C027
W08 — Named capacity and signature block Does the document identify a borrower, guarantor, owner, authorized agent, witness, or consent-only signer? Complete signature block, incorporated definitions, capacity clauses, and cross-references. C005–C006, C024–C026
W09 — Express promise What exact language creates an alleged repayment obligation, and for which debts? Entire promise-to-pay/account agreement, incorporated terms, conditions, and exclusions. C006, C051, C066
W10 — Guaranty scope Is the undertaking limited, continuing, conditional, secured, or associated with renewals/future advances? Complete generic guaranty, termination/release provisions, modification terms, and governing law. C007, C027, C032, C065
W11 — Formation and authority What remains necessary to establish execution, assent, authority, authenticity, or capacity? Applicable published formation/agency law and relevant execution evidence; these are parent holds. C006, C065–C066
W12 — Collateral-only consent Is the signature solely to make identified security available? Complete security instrument; any limitation legend; separation from note/guaranty. C024–C026, C044
W13 — State-law necessity Which state law requires or supports belief that this instrument/signature is needed? Pertinent statutes, published decisions, or attorney-general opinion; property situs and governing-law questions kept separate. C021–C025
W14 — Joint-property interest Has the applicant’s existing interest been valued independently? Ownership-form assumptions; attachment/execution/partition rules, resulting value and costs. C019–C021
W15 — Community-property conditions Are residence/property location, management/control, community assets, and separate-property sufficiency established? Applicable published state law and the specific qualifying facts; no marital presumption substituted for them. C023
W16 — Reliance on another’s income Is the other person’s income actually relied upon, and how must it be made available? Income-reliance terms; state characterization of separate income and future earnings. C029
W17 — Business relationship Is a guarantee requested because of a qualifying business role, or merely marriage/protected status? Generic organizational role and guarantee policy; distinguish spouse from partner/officer/shareholder role. C030–C031
W18 — Special-purpose program Is the program within current §8, and what law specifically requires the signature? Published enabling law, program rules, required plan elements, relevant version, and signature mandate. C035–C037
W19 — FTC cosigner role Is the proposed signer a natural person supporting another’s obligation without compensation, or a genuine primary beneficiary? Proceeds/goods/services allocation and complete obligations; labels alone insufficient. C039, C042–C044
W20 — Notice content/version Does the notice contain the complete applicable prescribed warning? Blank official notice and complete generic notice specimen; any state-law modification authority. C047–C052
W21 — Obligation and delivery sequence When does liability arise, and was the notice given before that event? Agreement-execution sequence and delivery evidence; for open-end credit, agreement covering future charges. C046
W22 — Format and placement Is the notice separate, and how is it placed in the packet? Complete generic packet, notice placement, additions, language, and applicable official explanations. C047, C052
W23 — Receipt evidence Is there proof of delivery, merely a file copy, an acknowledgment, or no available evidence? Delivery/receipt evidence and its limits; distinguish missing document from proven nondelivery. C051, C053, C057
W24 — Copies and records gap Which relevant instruments or delivery materials remain unavailable? Explicit inventory of missing categories; separate any independently applicable copy/retention law. C053–C054
W25 — Renewal/release Was creditworthiness reevaluated at renewal, and was the additional party still warranted? Renewal terms, stated reevaluation, applicable guarantee basis, and release instrument if relevant. C007, C030, C032
W26 — Open-end changes/access Is a marital/status change being used to demand reapplication, alter access, or add liability? Existing terms, supporting-income facts, permitted reapplication conditions, and express authorized-user undertaking. C033–C034
W27 — Remedy and forum What published authority supports the claimed consequence of a violation? Applicable statutory claimant rule, published forum authority, state defenses, remedy provisions, and later history. C015, C057, C065
W28 — Final inference check Is any conclusion resting only on marriage, household, title, credit reporting, access, or receipt of a notice? Identify the missing promise, capacity, application intent, property-law link, or remedy authority. C018, C024–C026, C051, C066

Audit output categories should remain separate: signature demand permitted/prohibited/unresolved; notice required/not established/exempt/unresolved; delivery established/not established/late on assumed facts; personal promise established/not established; collateral exposure established/not established; remedy unresolved. A conclusion in one category does not silently fill the others.

8. Clearly hypothetical qualitative failure branches

Every row is an analytical hypothesis using generic roles only. There are no invented identities, accounts, properties, qualifications, amounts, or awards.

Unless a row makes coverage the question, assume the specified federal rule applies and no unidentified exemption changes the result. “Adverse classification” below means a harmful analytical misclassification, not an ECOA adverse-action determination.

Example / assigned branch Expressly assumed facts Federal result at this pass’s scope Contract/state-law unknowns and evidence needed Adverse classification to avoid
H01 — Qualified sole applicant; Q6(a) An individual applies alone, independently meets the creditor’s standards for the requested terms, and is asked for a spouse’s personal guaranty. No property, income-reliance, business-role, or program exception is assumed. The demand conflicts with the general §7(d)(1) restriction. C016, C027. Need the application, condition imposed, actual guarantee, applicable claimant/remedy authority, and state contract law before deciding consequences. Treating the spouse as a voluntary joint applicant; or treating the prohibited demand as automatic proof the guaranty is void.
H02 — Genuine joint applicants; Q6(b) Both applicants contemporaneously request shared credit and separately affirm that intent at application. The joint-applicant exception permits obtaining both applicants’ signatures. C017–C018. The application is not the complete repayment contract. Need actual promise language, capacities, execution, and governing law; FTC primary-beneficiary status is a separate test. Assuming joint intent alone establishes every later personal obligation; or treating every joint applicant as a notice-entitled cosigner.
H03 — Sole applicant; other owner signs security; Q6(c) One applicant seeks secured credit. Applicable law is assumed to require another owner’s signature only on a security instrument; the instrument clearly excludes that owner’s personal promise. The collateral signature may be required. Requiring a note solely for convenience would not fit the assumed necessity. A signer with no personal liability is not converted into an FTC cosigner. C024–C026, C044. Need the complete instrument and actual published property law. Lien validity, priority, foreclosure, and recourse remain unproved. Calling the owner a personal debtor; or saying the owner faces no exposure because no personal promise exists.
H04 — Business guarantor and spouse; Q6(d) Credit is primarily business credit. An officer’s guaranty is requested because of the officer role, even though the business qualifies. The officer’s spouse is then automatically asked to guarantee. The role-based officer guaranty may be permitted; automatic spouse addition is not justified by that permission. The FTC consumer-notice rule is not established for the assumed business transaction. C030–C031, C039. Need full guarantees, the relationship-based policy, property/income facts if another exception is invoked, and state guaranty law. Treating all business guarantees as prohibited for a qualified business; or treating every officer’s spouse as responsible.
H05 — Community-property uncertainty; Q6(e) A married sole applicant has the specified community-property-state connection, but management/control law and separate-property sufficiency are unknown. The connection alone does not resolve §7(d)(3). Both substantive conditions and necessary-instrument analysis remain open. C023. Need published state management/control and debt-access rules, property characterization, and the relevant sufficiency facts. Inferring joint personal debt from marriage or geography; or rejecting every spouse signature without examining the statutory conditions.
H06 — FTC cosigner versus primary purchaser; Q6(f) In a covered consumer transaction, an unpaid natural person supports another’s debt and receives no goods, services, or money. Compare a genuine joint purchaser receiving the purchased goods. The first fits the defined cosigner branch; the genuine primary-beneficiary alternative may not. Labels cannot substitute for the facts. C042–C043. Need complete obligation language and allocation of benefits. Neither notice status decides enforceability. Reclassifying a supporting signer as a co-borrower merely by caption; or treating every jointly signed purchase as a cosigner transaction.
H07 — Missing or late notice; Q6(g) Alternative A: the required notice is proved to have been delivered only after obligation. Alternative B: no notice is present in the available document set, but delivery history is unknown. A fails the prior-delivery condition. B is an evidence gap, not yet proof of nondelivery. Neither yields automatic release. C046, C053, C057. Need the obligation-formation event, delivery sequence, applicable exemption status, and remedy authority. “No copy means no notice”; “late notice automatically cancels the debt”; or “signed guarantee proves notice compliance.”
H08 — Institution class uncertain; Q6(h) Only a generic description such as bank, credit union, or finance business is supplied; no statutory classification is established. FTC-rule coverage cannot be decided from the label. ECOA/Regulation B and other statutory duties require their own coverage analysis. C003, C039–C040, C058–C064. Need legal-category and transaction facts; no roster or real institution search is authorized or performed. Applying part 444 identically to every institution; or assuming absence of FTC jurisdiction removes all federal protections.
H09 — Renewal and release At renewal the creditor reevaluates creditworthiness and determines that no additional party remains warranted under the applicable rules; no independent business-role basis is assumed. The official comment requires release of the additional party. If reevaluation or the no-longer-warranted premise is missing, that specific result is not established. C032. Need renewal/reevaluation evidence and release terms; scope of historical liability and any separate continuing guaranty remains open. Treating guarantees as automatically perpetual; or treating every renewal as automatic discharge.
H10 — Unsecured joint assets A sole applicant relies on joint property; the applicant’s own existing interest is assumed sufficient for the requested terms. The nonapplicant owner’s signature cannot be demanded under the insufficiency branch. If the interest is insufficient, the limited alternatives must be examined. C019–C022. Need the existing ownership form, property-situs law, accessibility, value, costs, and instrument purpose. Ignoring the applicant’s own interest; relying on imagined future divorce; or routinely requiring forfeiture of the other owner’s title.
H11 — Reliance on spouse’s income An individual application actually relies on the spouse’s income; it is assumed not automatically available as community property. A signature making that relied-on income available may be permitted. The reason is the specific income reliance, not marriage alone. C029. Need income characterization, enforceable commitment terms, and relevant state law. “A spouse can never be required to sign”; or “every married applicant must obtain a spouse signature.”
H12 — Incidental-credit exception The extension is assumed to meet every element of §3(c)(1), including its non-card, no-finance-charge, and installment conditions. Section 7(d) is excepted. That does not erase the general discrimination rule or independently settle FTC coverage. C010, C039. Need terms establishing the exception and separate actor/consumer-purpose analysis; state liability remains open. Applying §7(d) merely because the arrangement is credit; or treating the exception as proof that nobody owes.
H13 — Special-purpose program A qualifying program is asserted, and a signature is said to be required by law; no actual enabling law or compliant program materials are supplied. The label alone is insufficient. Current §8 prerequisites, the applicable version, and the specific legal signature requirement must be established. C035–C037. Need published enabling law and generic program materials; no actual eligibility assessment is made. Treating any “special program” as permission to require a spouse’s personal guaranty.
H14 — Defaulted obligation and forbearance A covered creditor conditions forbearance on a defaulted consumer obligation on an unpaid natural person’s new supporting undertaking. The FTC cosigner definition expressly reaches this branch; the notice must precede the new obligation. C042, C046. Need forbearance/guaranty terms, formation and consideration law, delivery sequence, and coverage/exemption facts. Assuming notice applies only when fresh loan proceeds are advanced.
H15 — Account access without demonstrated promise A person has account access or an authorized-user designation, but no express undertaking has been established. Regulation B permits certain contractual-liability conditions for authorized users; that permission does not prove this user agreed. C006, C034. Need complete agreement and capacity/assent evidence; other possible legal bases remain parent holds. Treating access, household membership, or a credit-report entry as conclusive personal liability.

The federal conclusions in these hypotheses derive from the cited claims and their operative sources, particularly complete §1002.7(d) commentary and §444.1(k)/§444.3. They are not invented account records or actual eligibility decisions. Consumer Financial Protection Bureau+3

9. Granular coverage table

Answered means the bounded legal proposition is explained. It does not mean an actual transaction has been decided. Partial identifies an authority or currentness gap. Unresolved identifies facts or law not supplied/within scope. Excluded identifies a parent dimension deliberately not undertaken.

Every proposed next step below is limited to published law, opinions, official generic materials, or blank/sample documents. None authorizes a record search, contact, filing, or institution lookup.

Assigned subquestion / significant branch Status and reason Claim / example links Exact remaining gap and next bounded permissible investigation
Q1 — ECOA statutory actor, applicant, credit, person Answered at necessary statutory scope. C001–C006; S001–S002 Actual role/request/purpose facts absent. Next: compare a generic document’s stated roles with the cited definitions.
Q1 — Consumer versus business coverage Answered. Both may fall under Regulation B; FTC purpose rule is narrower. C002, C030, C039; H04 Mixed-purpose characterization may need generic terms and applicable published interpretation. No broad classification survey undertaken.
Q1 — Participating creditor, assignee, referral-only actor Answered as a rule; actual participation unresolved. C003 Need role and decision-participation facts; do not infer §7(d) coverage from referral language limited to §4(a)–(b).
Q1 — Guarantor regulatory inclusion Answered. Inclusion is express for §7(d). C005, C031 Does not supply statutory plaintiff/defense status.
Q1 — Statutory guarantor claim/defense and jurisdiction Partial. One complete appellate majority and its Supreme Court disposition read. C015, C065; S027–S028 Current governing forum’s published authority and precise posture remain missing. Next: bounded published-opinion review after a jurisdictional research scope is defined; no docket/status query.
Q1 — Securities exception Answered. Express §7(d) exclusion. C009 Actual statutory securities-credit classification absent; next published-law analysis only if needed for a generic scenario.
Q1 — Incidental-credit exception Answered. Complete conjunctive definition and signature exception identified. C010; H12 Need transaction terms for each element; no automatic exemption merely from “bill” or “service.”
Q1 — Government credit Answered. To-government versus by-government distinction made. C011 Actual recipient class absent.
Q1 — Utility credit Answered. Listed exception does not eliminate §7(d). C012 Need service and rate-regulation facts; no utility entity lookup.
Q1 — Territory and §1029 dealer boundary Partial. Part-1002 boundary and Act preservation established. C008; S005, S014 Complete counterpart part-202 treatment for an excluded dealer not completed. Next: published counterpart regulation and transfer-rule analysis only.
Q1 — Currentness/effective/later history Partial, expressly bounded. Current agency text and relevant final rules read. C037, C058–C064 No complete session-law lag audit, official annual-CFR audit, or universe of judicial orders. Next: targeted published amendments/opinions, without case-record searches.
Q2 — Individually qualified applicant; Q6(a) Answered with exceptions visible. C016; H01 Actual qualification not assessed; contract consequence/remedy remains separate.
Q2 — Genuine joint application; Q6(b) Answered. Contemporaneous intent and separate evidence requirements covered. C017–C018; H02 Need application-stage evidence, not just a later note or financial statement.
Q2 — Unsecured joint property: valuation Answered. Existing-interest valuation and speculative-change prohibition covered. C019–C020; H10 State attachment/partition rules and value/cost facts missing. Next: state published law for a specified generic ownership form.
Q2 — Unsecured joint property: instruments/options Answered. Necessity, death/default access, alternatives, and forfeiture limit covered. C021–C022; H10 Exact instrument and state-law necessity missing.
Q2 — Community property; Q6(e) Answered rule; application unresolved. Both required financial/property conditions stated. C023; H05 State management/control, separate/community characterization, and sufficiency facts missing.
Q2 — Secured collateral-only signature; Q6(c) Answered. Security access distinguished from personal promise. C024–C025; H03 State lien-creation requirements and full instrument missing; perfection/priority/remedies excluded.
Q2 — Integrated note/security document Answered. Clear limitation requirement and example of nearby legend covered. C026; H03 Need the whole document; no unseen signature block or legend treated as inspected.
Q2 — Additional personal party and spouse choice Answered. Necessity does not authorize a spouse-only condition. C027–C028; H01 Actual standards, reason, and eligibility restrictions missing.
Q2 — Other person’s/spouse’s income Answered. Separate-income and future-earnings conditions covered. C029; H11 Actual reliance and state income characterization missing.
Q2 — Business role and guarantor’s spouse; Q6(d) Answered. Qualified-business exception and spouse protection both covered. C030–C031; H04 Role, financial circumstances, guarantee terms, and state law missing.
Q2 — Renewals, extensions, release Answered at definition and conditional-comment scope. C007, C032; H09 Reevaluation, continuing justification, and effect on existing obligations missing. General release/novation law excluded.
Q2 — Existing open-end account changes Answered only as material to signature/reapplication issues. C033 Supporting-income facts and existing terms missing; no general adverse-action survey.
Q2/Q5 — Authorized-user and overdraft distinctions Answered. Permissible required undertaking separated from actual agreement. C006, C034; H15 Express contractual undertaking and other possible legal bases unproved.
Q2 — Special-purpose-program exception Answered rule; actual program unresolved. Current prerequisites and law-required signature condition covered. C035–C037; H13 Specific program law, date/version, and compliant generic materials missing; actual eligibility excluded.
Q3 — FTC creditor/debt/consumer/commerce coverage Answered at rule-definition level. C039–C040 Actual institutional and transaction facts absent; statutory cross-reference classification not performed for any entity.
Q3 — Real-estate-purchase scope Answered as published FTC interpretation, not invented rule wording. C041 Boundary cases such as mixed-purpose/refinancing structures not comprehensively researched. Next: targeted official published interpretation for a defined generic structure.
Q3 — Cosigner versus co-borrower; Q6(f) Answered. Natural-person, another’s obligation, compensation, benefit, and label conditions covered. C042–C044; H06 Actual benefit allocation and obligation terms missing.
Q3 — Defaulted obligation/forbearance Answered. Express definitional branch included. C042, C046; H14 New undertaking’s formation and prior delivery evidence missing.
Q3 — Complete required notice content Answered. All four paragraphs and heading accounted for. C048–C051; S015 Paraphrase is not a substitute compliance form; actual notice version not reviewed.
Q3 — Timing and open-end trigger Answered. Before obligation; future-charge agreement execution for open-end credit. C046; H07 Actual chronology unproved. No invented advance-day rule or expiry period.
Q3 — Format, packet placement, language Answered with authority levels separated. Rule versus staff implementation guidance distinguished. C047, C052 Complete generic packet, additions, and applicable state-language rules absent. Electronic-delivery law excluded.
Q3 — Collection sequence and rights Answered as warning and limitation. No universal collection-first priority inferred. C050, C052 State sequence, contract waivers, judicial procedures, exemptions, and actual remedies remain missing.
Q3 — Records, copies, acknowledgment Answered within part 444 and the official materials read. C051, C053–C054 Other retention/copy statutes and actual delivery evidence unreviewed; absence of a file copy is not decisive.
Q3 — Missing/late notice; Q6(g) Answered at compliance level; remedy unresolved. C057; H07 Need formation timing, delivery proof, governing remedies law, and forum. No automatic release or private cause inferred.
Q3 — FTC state/person exemptions Partial. Complete mechanisms read; specific current determinations not verified. C055–C056 A historical California exemption reference surfaced, but operative/current determination was not read. Next: the published FTC determination and any published amendment/revocation, without state-wide liability surveying.
Q4 — Bank/CU/nonbank distinction; Q6(h) Answered framework; actual coverage unresolved. C040, C058–C064; H08 Exact statutory actor class absent; no roster used.
Q4 — Federal Reserve and NCUA repeals Answered. Actual final-rule bodies/instructions and dates read. C058–C059 No actual pre-repeal transaction adjudicated; other laws remain separate.
Q4 — OTS/OCC history Partial historical reconstruction. Joint explanation and actual integration/removal documents consulted. C060 Full 2011 republication comparison and any correction to the later printed effective date not verified. Next: published correction/republication text only if that historical date matters.
Q4 — 2014 guidance current status Partial across publishers. CFPB/NCUA status verified; Fed/OCC pages checked; FDIC blocked. C062–C063 FDIC publisher status not established. Next: an accessible official publication or withdrawal notice; no access workaround.
Q4 — Statutory authority versus new notice duty Answered at bounded level. Repeal, statutes, and guidance separated. C061, C063 A particular conduct-based UDAAP determination requires its statutory elements and facts; none made.
Q4 — Proposed replacement Answered for the identified proposal. Actual withdrawal and later agency acknowledgment read. C064 No assertion that an old proposal page is current law; no exhaustive inventory of every possible product-specific duty.
Q5 — Blank liability/signature audit Answered. W01–W28 provided, with blank findings. C038, C066; worksheet Actual formation, authority, signatures, state-law effects, and remedies deliberately unresolved.
Q6 — All eight required branches and additional failures Answered. H01–H08 map directly to (a)–(h); H09–H15 cover additional material branches. H01–H15 Hypotheses are assumptions for analysis, not records, actual qualification findings, or real liability decisions.
General debt/TILA/FDCPA gateways; comprehensive state/remedy/litigation surveys Excluded by assignment. Parent holds below No prior report assumed to have completed these dimensions.

10. Read and failure log

The source table is the affirmative read log: it identifies the actual bodies read and the portions not read. This supplementary log records retrieval failures, limited visual access, and status conflicts. A failure is not evidence that a rule, exemption, or document does not exist.

Log item Exact route(s) / event Result and treatment
F01 — Legacy House routes https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1691a&num=0&edition=prelim ; https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1691a+edition%3Aprelim%29 ; https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1691+edition%3Aprelim%29 404/maintenance responses on these routes. Necessary statutory bodies were subsequently read through S001–S002’s canonical compilation URLs.
F02 — Earlier §1691d/e routes https://uscode.house.gov/us/usc/119-121/t15/s1691d/ ; https://uscode.house.gov/us/usc/119-121/t15/s1691e/ ; https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1691d&num=0&edition=prelim ; https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1691e&num=0&edition=prelim Timeout/server/404 failures. Resolved by S003–S004’s 119-124 compilation URLs.
F03 — Annual-code alternatives https://www.govinfo.gov/content/pkg/USCODE-2025-title15/html/USCODE-2025-title15-chap41-subchapIV-sec1691d.htm ; https://www.govinfo.gov/content/pkg/USCODE-2025-title15/html/USCODE-2025-title15-chap41-subchapIV-sec1691e.htm Tool-inaccessible. Not counted as statutory reads; canonical House bodies supplied the necessary text.
F04 — FDIC guidance status https://www.fdic.gov/news/financial-institution-letters/2014/fil14044.html ; https://www.fdic.gov/laws-and-regulations/fdic-and-interagency-statements Both returned 403. FDIC current publisher status remains unresolved. Search discovery was not substituted for a body read.
F05 — eCFR access challenge https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.7 ; resulting access page https://unblock.federalregister.gov/ A later retrieval encountered an access/CAPTCHA page. No workaround attempted. Complete necessary regulation/commentary read from CFPB’s public regulation page.
F06 — Wrong-date NCUA route https://www.govinfo.gov/content/pkg/FR-2014-09-29/pdf/2014-22715.pdf Inaccessible. Correct October 3 publication retrieved and read at S021.
F07 — OCC historical route https://www.govinfo.gov/link/fr/76/48950 Inaccessible. The alternate published-page link in S022 returned the 250-page integration document. Only the stated portions were read; no full-document omission comparison claimed.
F08 — Appendix B and visual limits https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1002-appB.pdf ; S013’s two image URLs. Guessed annual-appendix route inaccessible. Image retrieval returned markers rather than inspectable pixels. No form-layout or image-text findings are claimed. Official introductory text and model legal clauses support the worksheet.
F09 — Historical exemption discovery https://www.govinfo.gov/content/pkg/FR-1988-06-01/pdf/FR-1988-06-01.pdf Whole-issue retrieval failed for size. A discovery reference to a California exemption was not promoted into a read/current exemption conclusion. C055’s mechanism is established; particular determinations remain a gap.
F10 — Treasury HTML alternative https://www.govinfo.gov/content/pkg/FR-2017-10-11/html/2017-21904.htm Inaccessible; official PDF in S022 was read. Its printed 2018 effective date was retained as printed, not silently replaced with publication year. A screenshot response did not yield verified pixels; PDF text is not called visual inspection.
F11 — CFPB index follow-through Starting page: https://www.consumerfinance.gov/compliance/guidance/ One attempted link-follow operation could not resolve its target. The actual index body, withdrawal register, and full joint guidance at the Federal Reserve were read separately.
F12 — Irrelevant later-notice discovery https://downloads.regulations.gov/FTC-2026-0728-0001/content.pdf A generic current-rule search surfaced this June 2026 notice; download returned 403. Discovery identified a Privacy Act notice, not a credit-practices rule. It supplies no substantive support here; no underlying personal records were accessed.
F13 — Proposal page versus legal status All three complete URLs in S026. The old landing page still describes a proposal. The actual May 2025 withdrawal and August 2026 agency statement control the reported status; an old page heading was not treated as a new rule.
F14 — Retrieval truncation and repeat reads Some batched public-web outputs were truncated. Necessary bodies were reopened in bounded portions. Unseen truncated material was not counted as read. Reopening the same document is not independent corroboration.
F15 — Judicial read limits Complete published opinion/disposition URLs in S027–S028. Majority body and Supreme Court disposition read. No case-record/docket-status query, comprehensive citator, all-circuit survey, or unseen majority opinion claimed.
F16 — Side-source not used to establish a counterpart regime https://www.ecfr.gov/current/title-12/chapter-II/subchapter-A/part-202/section-202.1 Scope text was consulted, but a complete current part-202 signature/counterpart analysis was not performed. The §1029 boundary remains expressly partial rather than being filled from assumption.

Visual and transcription limit: no equation was involved. No unseen image pixels, full form layout, or PDF table layout is represented as visually inspected. The conclusions rely on the operative text actually retrieved and read.

11. Assigned-question → source/claim crosswalk

Assigned question Principal sources Claims / deliverables
1. Necessary ECOA/Regulation B coverage, applicant/guarantor definition, standing and currentness limits S001–S007, S012, S014, S027–S028 C001–C015, C037, C065; corresponding coverage rows and judicial read limits
2. Every additional-signature/spouse branch, joint intent, collateral, business, renewal/change S003, S006, S008–S013 C016–C038; H01–H05, H09–H13, H15; W04–W18, W25–W26
3. FTC exact coverage, cosigner definition, full notice, timing, format, copies/records, remedies limits S015–S018 C039–C057; complete notice-content rows C048–C051; H06–H07, H14; W19–W24
4. Bank/CU/thrift changes, repeals, current guidance status, statutory authority S018–S026 C040, C058–C064; institution table; H08; F04, F07, F10, F13
5. Blank generic document/signature/liability audit S006, S008, S010, S013, S015–S017, S027–S028 W01–W28; C006, C038, C051–C057, C065–C066
6. At least eight hypothetical qualitative failure branches Underlying claim sources above H01–H08 satisfy the specified branches; H09–H15 add renewal, valuation, income, incidental credit, program, forbearance, and account-access branches

12. Explicit self-check — not independent review

Check Result
Actual current-date public browsing Performed on October 27, 2026, America/Los_Angeles; source/version cutoffs separately recorded.
Complete relevant operative bodies Complete §1002.7(d) and its official comments; necessary adjacent clauses/comments; complete part 444 including notice and exemption conditions read.
Exceptions preserved Securities, incidental, government, utility, property, income, business-role, special-program, institutional, and exemption mechanisms identified.
Regulatory definition versus statutory remedy Kept separate; no uniform guarantor standing or private-remedy conclusion inferred.
Notice versus agreement Explicitly separated; no receipt-as-guaranty or missing-notice-as-release inference.
Current guidance status CFPB registers and publisher pages checked; FDIC retrieval gap remains visible. Withdrawn ECOA advisories not used as operative support.
Judicial evidence Complete relevant majority body and Supreme Court disposition read; posture, disposition, pinpoint, and later-history limits recorded.
Visible deliverables Source, claim, institution, worksheet, hypothetical, coverage, failure-log, crosswalk, and self-check tables appear in this answer.
Actual-data and owner limits No actual liability/eligibility decision, institution roster, borrower/property/account lookup, record request, filing, contact, form completion, publication, local coordinator file, or subagent work.
Independent review / acceptance None claimed. This is the same researcher’s self-check, not independent legal review, operational acceptance, or parent completion.

13. Remaining parent dimensions and specific holds

This pass leaves the following dimensions open:

Parent dimension Specific matters still held
Actual formation and attribution Contract formation; assent; authority and agency; signature authenticity; identity; fraud; ratification; assumption; release; novation. The narrow renewal-release comment does not complete general release law.
Guaranty and suretyship law Full guaranty construction; suretyship defenses; modification effects; waiver validity; contribution; reimbursement; subrogation.
Marital and other personal-status law Full marital/community-property regimes; family/necessaries obligations; succession and estates; minors and incapacity; state, local, tribal, and foreign law.
Security and remedies against property Attachment, perfection, priority, lien enforceability, foreclosure and other secured remedies, recourse/nonrecourse consequences, and property-specific exemptions.
Product-specific obligations Student, medical, housing, utility, tax, public, employment, business, and foreign obligations; product-specific notice, copy, cancellation, and release requirements.
Lifecycle, procedure, and remedies Insolvency/discharge; limitations; evidence and burdens; claimant status and standing in the relevant forum; court procedures; enforcement and remedies; the remaining debt lifecycle.
Programs, settlement, and operations Actual program eligibility; settlement suitability; tools and other A003 dimensions; operations and publication decisions.
Unfinished bounded authority checks Specific current FTC exemption determinations; FDIC publisher status; full excluded-dealer counterpart treatment; complete current forum-specific guarantor authority; and any transaction-date-specific legislative or judicial history needed for a later defined question.

This is the first focused R003/A003 component only. It does not constitute A003, component, state, parent, operations, or publication acceptance, and it does not establish full parent completion.

END R003 PASS-01

Every captured table

Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

Captured table 01

Source ID · Title / issuer and complete literal HTTPS URL(s) · Exact pinpoint and read extent · 28 data rows

Source IDTitle / issuer and complete literal HTTPS URL(s)Exact pinpoint and read extentVersion, status, jurisdiction, and check limits
R003-P1-S00115 U.S.C. §1691, Scope of prohibition — House OLRC. https://uscode.house.gov/us/usc/119-121/t15/s1691/Necessary operative text: §1691(a), (b), and (c), including marital inquiry and special-program provisions; relevant amendment/effective-date notes. Other displayed provisions were not used for a general adverse-action survey.Fresh; D. Compilation through Public Law 119-121, October 9, 2026. Federal statute; no complete post-compilation session-law audit.
R003-P1-S00215 U.S.C. §1691a, Definitions; rules of construction — House OLRC. https://uscode.house.gov/us/usc/119-121/t15/s1691a/Complete operative subsections (a)–(g), including statutory applicant, credit, creditor, person, and regulatory-reference provisions; displayed amendment notes.Fresh; D. Compilation through October 9, 2026. Statutory definition must be distinguished from the regulation’s special guarantor inclusion.
R003-P1-S00315 U.S.C. §1691d, Applicability of other laws — House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1691d/Complete operative (a)–(g); particular reliance on lien/property signatures, state property law, narrowly framed separate-credit preemption, and state-law preservation/exemption provisions.Fresh; D. Compilation through Public Law 119-124, October 15, 2026. No all-state property or remedies analysis.
R003-P1-S00415 U.S.C. §1691e, Civil liability — House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1691e/Operative body retrieved; used principally (a), (c), and (e): aggrieved-applicant liability, court-granted equitable/declaratory relief, and good-faith conformity protection. No deadline or award calculation.Fresh; D. Compilation through October 15, 2026. Does not resolve a particular guarantor’s statutory entitlement, jurisdiction, defenses, or remedy.
R003-P1-S00512 C.F.R. §1002.1, Authority, scope and purpose — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/1/Complete operative section and official comments 1(a)-1 through -3.Fresh; D. Agency labels current. U.S. lending, including Puerto Rico and territories; generally excludes lending outside the U.S. Part-specific motor-vehicle-dealer exclusion is expressly distinguished from ECOA itself.
R003-P1-S00612 C.F.R. §1002.2, Definitions — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/2/Complete necessary clauses: (e)–(j), (l)–(n), (q), (u), (w), (x), (z), (aa); relevant official comments to (e), (f), (g), (j), (l), (w), and (z).Fresh; D. Agency labels current. No general scoring, adverse-action, TILA, or debt-classification survey inferred from incidental displayed text.
R003-P1-S00712 C.F.R. §1002.3, Limited exceptions — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/3/Complete (a)–(d) and associated comments; especially (b)(2)(vi), (c)(2)(v), and (d)(2).Fresh; D. Agency labels current. Essential limits on applying §1002.7(d) to securities, incidental, and government credit.
R003-P1-S00812 C.F.R. §1002.7, Rules concerning extensions of credit — CFPB; eCFR cross-check. https://www.consumerfinance.gov/rules-policy/regulations/1002/7/ ; https://www.ecfr.gov/current/title-12/chapter-X/part-1002/section-1002.7Complete §7(d)(1)–(6) and every accompanying official comment; also complete relevant §7(a), §7(c), and comments. The CFPB body is the substantive reading source.Fresh; D. CFPB labels current. Initial eCFR page showed Title 12 currency through October 23, 2026; later canonical retrieval encountered an access challenge. No workaround; see failure log.
R003-P1-S00912 C.F.R. §1002.6, Evaluation of applications — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/6/§6(b)(8), relevant marital-status commentary, and §6(c), concerning equal standards and state property law.Fresh; D. Agency labels current. Only provisions necessary to signature/property distinctions used.
R003-P1-S01012 C.F.R. §1002.11, Relation to state law — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/11/Complete operative section and displayed comments; relied on (a), (b), (d), and (e).Fresh; D. Agency labels current. State property law remains a separate inquiry; no state-by-state preemption determination made.
R003-P1-S01112 C.F.R. §1002.8, Special purpose credit programs — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/8/Complete current operative (a)–(d) and all displayed official comments. Signature sentence in (d); program prerequisites in (a)–(b); information provision in (c).Fresh; D. Agency labels current. Current 2026 program conditions used; no actual program eligibility or compliance finding.
R003-P1-S012Equal Credit Opportunity Act (Regulation B), final rule — CFPB, 91 FR 21620. https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07804.pdfPrinted p.21620 / index 0, summary and effective date; pp.21658–21659 / indexes 38–39, relevant §8 discussion and effective-date section; pp.21668–21670 / indexes 48–50, relevant amendment instructions and revised §8 commentary.Fresh; D. Final, published April 22, 2026; stated effective July 21, 2026. Not a full 51-page read or judicial-status certification.
R003-P1-S013Appendix B, Model Application Forms — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/b/ ; linked Form 1 images: https://files.consumerfinance.gov/f/images/cfpb_regulations_ER21DE11-046.original.png and https://files.consumerfinance.gov/f/images/cfpb_regulations_ER21DE11-047.original.pngComplete introductory instructions 1–3 read. Image routes returned image markers, but their pixels were not available for verified visual inspection; no image-field transcription relied upon.Fresh; D. Optional official models; limited inquiry-compliance effect under §1002.5(b)–(d). Worksheet below relies on operative clauses and official commentary, not unseen form pixels.
R003-P1-S01412 U.S.C. §5519, motor-vehicle-dealer exclusion — House OLRC. https://uscode.house.gov/us/usc/119-124/t12/s5519/Relevant (a)–(d), including activity-based exclusion, statutory carvebacks, preserved other-agency authority, and FTC rulemaking provision.Fresh; D. Compilation through October 15, 2026. Exact classification of any dealer and complete counterpart-Regulation-B treatment remain untested.
R003-P1-S01516 C.F.R. part 444, Credit Practices — FTC / eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-444Entire operative §§444.1–444.5 read, including complete definitions, §444.3(a)–(c), complete prescribed notice, and §444.5 exemption conditions.Fresh; D. eCFR Title 16 currency through October 23, 2026; source note 49 FR 7789, March 1, 1984. FTC-jurisdiction consumer transactions; no complete annual-CFR/session-history audit.
R003-P1-S016Complying with the Credit Practices Rule — FTC staff business guidance. https://www.ftc.gov/business-guidance/resources/complying-credit-practices-ruleComplete page read; relied on “Introduction,” “What Transactions Are Covered,” “How Exemptions Are Granted,” and “Notice to Cosigners.”Fresh; D. December 2006 booklet, edited January 2025 for penalty information. Still published; staff guidance, not amended regulatory text. Historical bank-counterpart statements are not used as current coverage proof.
R003-P1-S017Cosigning a Loan FAQs — FTC Consumer Advice. https://consumer.ftc.gov/articles/cosigning-loan-faqsComplete page read; particularly obligations, state collection sequence, real-estate-purchase notice qualification, language, copies, and release advice.Fresh; D. Dated April 2024; generic advice. Broad introductory statements must be read subject to controlling actor/transaction coverage.
R003-P1-S018FTC Act jurisdiction, definitions, and rulemaking provisions — House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s44/ ; https://uscode.house.gov/us/usc/119-121/t15/s45/ ; https://uscode.house.gov/us/usc/119-124/t15/s57a/Necessary §44 definitions; §45(a)(1)–(2); §57a(f)(1)–(4), (g)(1)–(3), and 2010 amendment/effective-date notes.Fresh; D. §45 compilation through October 9; other two through October 15, 2026. Grouped statutory usage, not three independent confirmations. No actual entity classification.
R003-P1-S01912 U.S.C. §§5531 and 5536 — House OLRC. https://uscode.house.gov/us/usc/119-121/t12/s5531/ ; https://uscode.house.gov/us/usc/119-121/t12/s5536/Operative §5531(a)–(f) and §5536(a)–(b), including covered-person/service-provider framework, unfairness conditions, and statutory prohibitions.Fresh; D. Compilation through October 9, 2026. Separate statutory UDAP/UDAAP analysis; no institution-specific enforcement finding.
R003-P1-S020Unfair or Deceptive Acts or Practices (Regulation AA), final repeal — Federal Reserve, 81 FR 8133–8134. https://www.govinfo.gov/content/pkg/FR-2016-02-18/pdf/2016-03228.pdfComplete relevant Federal Reserve final-rule body, printed pp.8133–8134 / indexes 0–1; neighboring agency material excluded.Fresh; D. Published February 18, 2016; effective March 21, 2016. Removes former 12 C.F.R. part 227; explains statutory-authority repeal and non-transfer of that rulemaking authority.
R003-P1-S021Unfair or Deceptive Acts or Practices; Technical Amendments — NCUA, final rule. https://www.govinfo.gov/content/pkg/FR-2014-10-03/pdf/2014-22715.pdfComplete part-706 discussion at p.59627 / index 0; relevant procedural discussion p.59628 / index 1; operative removal instruction 3 at p.59629 / index 2. Unrelated organizational amendments not treated as fully researched.Fresh; D. Effective October 3, 2014. Part 706 removed and reserved; continuing statutory authority expressly discussed.
R003-P1-S022Thrift-rule history — OCC and Treasury. OCC integration rule: https://www.govinfo.gov/link/fr/76/49047 . Treasury, Removal of Office of Thrift Supervision Regulations: https://www.govinfo.gov/content/pkg/FR-2017-10-11/pdf/2017-21904.pdfOCC: summary/effective-date material at printed p.48950 / index 0 of a 250-page PDF; not the complete republication. Treasury: complete relevant item at pp.47083–47084 / indexes 0–1, including chapter-V removal instruction.Fresh; D. OCC document effective July 21, 2011. Treasury final published October 11, 2017; its printed DATES says October 11, 2018. No correction was verified. Treasury describes non-substantive removal of obsolete/superseded provisions.
R003-P1-S023Interagency Guidance Regarding Unfair or Deceptive Credit Practices — Federal Reserve, CFPB, FDIC, NCUA, OCC. https://www.federalreserve.gov/frrs/guidance/interagency-guidance-regarding-unfair-or-deceptive-credit-practices.htmComplete guidance body and footnotes 1–12; especially footnote 9 on former OTS part 535 and footnote 11 on continued notice use.Fresh; D. Issued August 22, 2014. Guidance status checked separately in S024–S025. Its historical future-tense repeal statements are not current-rule statements.
R003-P1-S024Publisher status pages for the same joint guidance. Federal Reserve: https://www.federalreserve.gov/supervisionreg/caletters/caltr1405.htm ; OCC: https://www.occ.gov/news-issuances/bulletins/2014/bulletin-2014-42.html ; NCUA: https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/unfair-or-deceptive-credit-practicesRelevant publisher-page bodies read. NCUA letter 14-FCU-03 explicitly displays Active; Fed/OCC pages remained published without an observed rescission banner.Fresh; D. These are status checks of one underlying guidance document, not independent legal authorities. FDIC publisher retrieval failed; see log.
R003-P1-S025Guidance and Withdrawn Guidance registers — CFPB. https://www.consumerfinance.gov/compliance/guidance/ ; https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/Current index’s 2014 credit-practices entry; withdrawal-register body checked, including relevant ECOA entries and absence of the joint credit-practices item.Fresh; D. Index last modified June 15, 2026; withdrawal register July 22, 2026. Existing-credit advisory withdrawn May 12, 2025; special-purpose-program advisory withdrawn June 17, 2026. Those withdrawn advisories are not operative support here.
R003-P1-S026Proposed Regulation AA status — CFPB. Withdrawal: https://www.govinfo.gov/content/pkg/FR-2025-05-15/pdf/2025-08645.pdf ; older proposal page: https://www.consumerfinance.gov/rules-policy/rules-under-development/prohibited-terms-and-conditions-in-agreements-for-consumer-financial-products-or-services-regulation-aa/ ; 2026 agenda: https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16603.pdfComplete withdrawal item, printed p.20569 / index 0; complete older landing-page body; relevant CFPB priorities statement at printed p.52943 / index 151 of 2026 agenda. Not the entire agenda or proposal.Fresh; D. Proposal withdrawn May 15, 2025; August 2026 agency statement again identifies that withdrawal. Old proposal landing page is not proof of a final/current obligation.
R003-P1-S027Hawkins v. Community Bank of Raymore, 761 F.3d 937 — Eighth Circuit published opinion. https://www.govinfo.gov/content/pkg/USCOURTS-ca8-13-03065/pdf/USCOURTS-ca8-13-03065-0.pdfComplete majority body, slip pp.1–8 / indexes 0–7; especially pp.3–6 and 8. Separate concurrence not relied upon as the holding.Fresh; D. Filed August 5, 2014; Eighth Circuit. Published summary-judgment appellate decision. Later history checked only to S028; no comprehensive later-treatment or current circuit survey.
R003-P1-S028Hawkins v. Community Bank of Raymore, 577 U.S. 495 — Supreme Court. https://www.govinfo.gov/content/pkg/USREPORTS-577/pdf/USREPORTS-577-495.pdfComplete published disposition, printed p.495 / index 0.Fresh; D. March 22, 2016; judgment affirmed by an equally divided Court. No reasoned Supreme Court majority resolving the statutory issue.
Source links captured in this table

Captured table 02

Claim ID · Area / type · Precise assertion and operative conditions · 15 data rows

Claim IDArea / typePrecise assertion and operative conditionsLimits and exceptionsSource / exact pinpoint
R003-P1-C001A003 / TextECOA prohibits a creditor from discriminating against an applicant concerning any aspect of a credit transaction on the enumerated bases, including sex and marital status.This is a credit-discrimination prohibition, not a federal determination that every spouse owes, or that every debt arrangement is covered credit.S001, §1691(a). uscode.house.gov
R003-P1-C002A003 / Text + CommentECOA credit concerns a right to defer payment, incur debt and defer payment, or acquire property/services and defer payment. Regulation B generally reaches personal and commercial credit; its basic credit definition does not require a finance charge or a particular installment count.The specific §1002.3 exceptions still matter. This does not rerun TILA or FDCPA coverage.S002, §1691a(d), (f); S005, comment 1(a)-1; S006, §2(g), (h), (j), comment 2(j)-1. uscode.house.gov +1
R003-P1-C003A003 / Text + CommentStatutory creditor includes regular extenders, renewers, continuers, arrangers, and participating assignees. Regulation B’s operative definition includes regular participation in credit decisions, including setting terms, and participating assignees/transferees/subrogees.The additional referral-only definition expressly applies to §4(a)–(b); it cannot automatically be carried into §7(d). The definition also limits responsibility for another creditor’s violation where there was no prior knowledge or reasonable notice, and excludes merely honoring a credit card.S002, §1691a(e); S006, §2(l), comments 2(l)-1–2. Consumer Financial Protection Bureau
R003-P1-C004A003 / Text + CommentA Regulation B application can be oral or written under the creditor’s actual procedures. Actual practice matters, not only the creditor’s written application policy.Ordinary use within an existing credit limit is excluded from this application definition. This claim does not decide every inquiry/prequalification or adverse-action issue.S006, §2(f), comments 2(f)-1–2. Consumer Financial Protection Bureau
R003-P1-C005A003 / TextStatutory applicant under §1691a(b) and regulatory applicant under §1002.2(e) are not identically worded. The regulation expressly includes guarantors, sureties, endorsers, and similar parties for §1002.7(d).That express regulatory inclusion does not itself settle statutory claimant status, standing, available defenses, or a private remedy in every court.S002, §1691a(b); S006, §2(e); S027–S028. uscode.house.gov +2
R003-P1-C006A003 / Text + SynthesisRegulation B defines contractual liability by an express agreement to repay all debts arising on an account.The definition does not authenticate a signature, establish authority, resolve formation, or transform an account label, access permission, or credit-report entry into that agreement.S006, §2(i); S008, comment 7(a)-1. Consumer Financial Protection Bureau +1
R003-P1-C007A003 / TextExtensions of credit include refinancing, renewals, consolidation, additional credit, and certain continuations at or after maturity. Credit transaction includes dealings concerning existing credit as well as applications.This broad lifecycle coverage does not make every modification a new guaranty or automatically trigger release; the particular renewal comment has its own conditions. Regulation B’s open-end definition also excludes negotiated advances under an open-end real-estate mortgage or letter of credit.S006, §2(m), (q), (w), comment 2(w)-1. Consumer Financial Protection Bureau
R003-P1-C008A003 / Text + CommentPart 1002 generally applies to U.S. lending, including Puerto Rico and U.S. territories, and excludes persons covered by the specified §1029 motor-vehicle-dealer exclusion.That is an exclusion from this part, not from ECOA itself. Section 5519 contains activity-based carvebacks. Exact counterpart-Regulation-B treatment for such an actor is not completed here.S005, §1(a), comments 1(a)-1–2; S014, §5519(a)–(d). Consumer Financial Protection Bureau
R003-P1-C009A003 / TextSection 7(d) does not apply to securities credit as defined in §3(b)(1): credit regulated under Securities Exchange Act §7, or credit by a broker/dealer regulated as such under that Act.This is the specified signature-rule exception, not permission for every discriminatory practice and not a ruling on an actual securities obligation.S007, §3(b)(1), (b)(2)(vi). Consumer Financial Protection Bureau
R003-P1-C010A003 / Text + CommentSection 7(d) does not apply to defined incidental consumer credit: other than utility/securities credit, not under a credit-card account, not subject to a finance charge as defined in §1026.4, and not payable by agreement in more than four installments.All stated definitional conditions matter. “Four” is an installment-count condition in §3(c)(1)(iii), not an invented qualification or payment schedule. A deferral can still be ECOA credit even though this exception applies.S007, §3(c)(1), (c)(2)(v), comment 3(c)-1. Consumer Financial Protection Bureau
R003-P1-C011A003 / Text + CommentCredit to governments, subdivisions, agencies, or instrumentalities is exempt from the part’s requirements except §4(a)’s general nondiscrimination rule.Credit by a government agency to consumers is not within that exception merely because the creditor is governmental.S007, §3(d), comment 3(d)-1. Consumer Financial Protection Bureau
R003-P1-C012A003 / Text + CommentThe defined public-utility-credit exception does not remove §7(d). Its listed exceptions concern specified marital-information and retention provisions.The definition requires the specified service/facility and government-filed or regulated charges. Financing unrelated goods or improvements is not utility-service credit merely because a utility provides it.S007, §3(a), comments 3(a)-1–3. Consumer Financial Protection Bureau
R003-P1-C013A003 / TextECOA permits consideration/application of state property laws and recognizes signatures serving lien, title, inchoate-right, or earnings purposes, subject to the statutory prohibition on discriminatory creditworthiness evaluation. Regulation B preserves state property and estate laws and preempts inconsistent credit-discrimination law only to the stated extent.This is not a uniform federal marital-property or recourse code. Married and unmarried applicants remain subject to equal evaluation standards except as law permits.S003, §1691d(a), (b), (f); S009, §6(b)(8), (c); S010, §11(a), (d). uscode.house.gov +1
R003-P1-C014A003 / TextSection 1691d(c) addresses a particular case: state law prohibits separate consumer credit, each spouse voluntarily applies separately to the same creditor, and that state prohibition is preempted; its sole-responsibility proviso applies in that specified setting.It must not be converted into a blanket statement that every separately named marital debt is solely one spouse’s debt under all state law.S003, §1691d(c). uscode.house.gov
R003-P1-C015A003 / Opinion + UnknownThe Hawkins Eighth Circuit majority held that executing a guaranty alone did not make the claimants statutory applicants; it rejected their reliance on the predecessor regulatory definition. It affirmed summary judgment on the ECOA claim/defense; state-law counterclaims had been dismissed without prejudice. The Supreme Court affirmed by equal division.The Supreme Court supplied no reasoned nationwide merits resolution. The appellate opinion used the then-operative Chevron framework; no claim is made that this is today’s general review framework. Current forum-specific treatment, statutory entitlement, Article III issues, and remedy remain unverified.S027, slip pp.3–8 / indexes 2–7; S028, p.495 / index 0. govinfo.gov +2
Source links captured in this table

Captured table 03

Claim ID · Area / type · Precise assertion and operative conditions · 23 data rows

Claim IDArea / typePrecise assertion and operative conditionsLimits / what remains unprovedSource / exact pinpoint
R003-P1-C016A003 / Text + CommentFor individual credit, a creditor generally must first determine that the applicant does not independently qualify before requiring another signer. If the applicant qualifies for the requested amount and terms, the creditor cannot require a spouse’s or another non-joint applicant’s signature on a credit instrument, subject to the paragraph’s exceptions.A neutral policy requiring everyone to obtain a cosigner does not defeat this protection. The business-role guaranty exception below is material. No actual qualification is assessed here.S008, §7(d)(1), comments 7(d)-1–2 and 7(d)(1)-1. Consumer Financial Protection Bureau
R003-P1-C017A003 / CommentA joint applicant applies contemporaneously for shared or joint credit. Someone added because the creditor demands another signature as a condition of approval is not thereby a joint applicant.The joint-applicant exception permits obtaining the genuine applicant’s signature; it does not itself establish the scope or enforceability of a later contractual promise.S008, comment 7(d)(1)-2. Consumer Financial Protection Bureau
R003-P1-C018A003 / Text + CommentJoint intent must be evidenced at application. Application signatures or initials affirming joint-credit intent may establish it, separately from accuracy certification. A promissory-note signature may not serve as the required proof of application-stage joint intent.A joint financial statement, joint-asset evidence, marriage, or shared household must not silently become a joint application. A financial-statement signature certifying accuracy is insufficient.S008, §7(d)(1), comment 7(d)(1)-3. Consumer Financial Protection Bureau
R003-P1-C019A003 / CommentFor unsecured credit supported by jointly owned property, the creditor must value the applicant’s own interest. It may not condition the extension on the nonapplicant owner’s signature if that interest supports the requested amount and terms.Joint title alone does not demonstrate a need for another signature. Actual ownership form, valuation, legal access, and the requested terms remain necessary facts.S008, comment 7(d)(2)-1. Consumer Financial Protection Bureau
R003-P1-C020A003 / CommentValuation may consider the existing ownership form, attachability, execution, severance or partition, resulting value, and associated costs.The creditor cannot premise the demand on speculative later changes such as divorce or a future transfer into a different tenancy.S008, comment 7(d)(2)-1(i). Consumer Financial Protection Bureau
R003-P1-C021A003 / Text + CommentIf the applicant relies on joint property for unsecured credit and the interest is insufficient, the creditor may pursue the stated alternatives: an appropriate additional party, secured credit, or instruments necessary/reasonably believed necessary under the property-situs state’s law to reach the relied-on property upon death or default.Property-access instruments should not impose personal liability unless state law makes that necessary. The commentary rejects routine demands for an instrument, such as a quitclaim deed, that forfeits the other owner’s interest.S008, §7(d)(2), comment 7(d)(2)-1(ii). Consumer Financial Protection Bureau
R003-P1-C022A003 / CommentThe official commentary says a creditor’s reasonable belief about necessary instruments should be supported by a thorough review of pertinent statutory and decisional law or a state attorney-general opinion.This is not permission based solely on a creditor’s preference. It does not prescribe a particular retained memorandum or decide whether an actual legal analysis was reasonable.S008, comments 7(d)(2)-2 and 7(d)(4)-2. Consumer Financial Protection Bureau +1
R003-P1-C023A003 / Text + CommentThe unsecured community-property branch requires a married applicant who resides in a community-property state or relies on property there; a necessary/reasonably necessary state-law instrument; both inadequate management/control of sufficient community property under state law and insufficient separate property to qualify without community property.Marriage or a community-property-state connection alone is insufficient. The residency comment allows a residence assumption unless the applicant indicates otherwise; it does not supply missing property-control law.S008, §7(d)(3)(i)–(ii), comment 7(d)(3)-1. Consumer Financial Protection Bureau
R003-P1-C024A003 / TextFor secured credit, a creditor may require spouse/other signatures on instruments necessary or reasonably believed necessary under applicable state law to make the offered security available on default—for example, to create a lien, pass title, waive inchoate rights, or assign earnings.Permission is tied to the legal collateral purpose. It is not a general permission to make every owner a personal guarantor.S008, §7(d)(4); S003, §1691d(a). Consumer Financial Protection Bureau +1
R003-P1-C025A003 / CommentIf a mortgage or security agreement alone makes the property available, the creditor may not require the spouse to sign the note. If state law actually requires both spouses’ note signatures for an enforceable lien, the commentary permits them.The relevant state rule must be identified; an assumption that every mortgage requires personal repayment liability is inadequate.S008, comments 7(d)(4)-1–2. Consumer Financial Protection Bureau
R003-P1-C026A003 / CommentA combined note/security instrument cannot be required where only a security-interest signature is needed unless the instrument clearly limits the spouse’s signature to granting security and excludes personal liability; a nearby legend is an example.The commentary does not mandate one magic phrase. Actual instrument language, capacity, and applicable law still control what was signed.S008, comment 7(d)(4)-3. Consumer Financial Protection Bureau
R003-P1-C027A003 / TextWhen an additional party’s personal liability is necessary under the creditor’s standards to support the requested credit, the creditor may request a cosigner, guarantor, endorser, or similar party.The spouse may serve, but the creditor cannot insist that the spouse be the additional party merely because a supporting obligor is needed.S008, §7(d)(5). Consumer Financial Protection Bureau
R003-P1-C028A003 / CommentA creditor may impose eligibility conditions on additional parties, such as residence in its market area.Such conditions cannot discriminate on sex, marital status, or another prohibited basis. They cannot be used to disguise an otherwise prohibited spouse-only requirement.S008, comment 7(d)(5)-1. Consumer Financial Protection Bureau
R003-P1-C029A003 / CommentAn individual applicant actually relying on another person’s income may be required to obtain that person’s signature to make the income available. This includes a spouse’s income outside community-property treatment and a spouse’s separate income in a community-property state.The commentary separately permits, but does not require, a spouse’s signature where future earnings are not community property until earned—even if the creditor normally requires a nonspouse income-provider’s signature. Actual income reliance and state characterization are essential.S008, comment 7(d)(5)-2; S009, §6(c). Consumer Financial Protection Bureau
R003-P1-C030A003 / CommentA creditor may require personal guarantees from business partners, directors, officers, and shareholders of closely held corporations even if the business itself is creditworthy, when based on that business relationship.The requirement cannot depend on a prohibited basis—for example, only married officers or only businesses associated with a protected group. This is not a universal exemption for all business-related additional signers.S008, comment 7(d)(6)-1. Consumer Financial Protection Bureau
R003-P1-C031A003 / Text + CommentAdditional parties receive the relevant signature protections. A creditor cannot automatically demand a guarantor’s spouse’s signature.The commentary allows a further signature in appropriate financial circumstances under §7(d)(2); that incorporates the property-access conditions, not unlimited permission for a spouse’s personal guaranty.S008, §7(d)(6), comment 7(d)(6)-2. Consumer Financial Protection Bureau
R003-P1-C032A003 / CommentIf creditworthiness is reevaluated when an obligation is renewed, the creditor must determine whether an additional party remains warranted and release that party if not warranted.This is a conditional federal release duty. It is not automatic expiration at every renewal, nor does business creditworthiness alone eliminate a permissible business-role guaranty. Effect on prior obligations and release mechanics remains a contract/state-law issue.S008, comment 7(d)(5)-3, read with comment 7(d)(6)-1. Consumer Financial Protection Bureau
R003-P1-C033A003 / Text + CommentFor an existing open-end account, specified adverse changes cannot be triggered merely by age, retirement, name, or marital-status change absent evidence of inability/unwillingness to repay. Reapplication based on marital change requires the stated spouse-income reliance and income-insufficiency information; the comment also addresses loss of another supporting person.During permitted reapplication, existing contractual access continues. Joint-account closure requests or repudiation of responsibility for future charges are separately addressed. No inference of release from existing debt follows merely from closing an account.S008, §7(c)(1)–(2), comments 7(c)(1)-1–2 and 7(c)(2)-1. Consumer Financial Protection Bureau
R003-P1-C034A003 / Comment + SynthesisA creditor may condition authorized-user designation on that user becoming contractually liable, without prohibited discrimination. For an overdraft line attached to a transaction account, it may require all persons authorized to draw to assume overdraft liability.Permission to require an agreement is different from proof that an agreement exists. Mere account access or authorized-user status does not prove the express undertaking.S008, comments 7(a)-1–3; S006, §2(i). Consumer Financial Protection Bureau +1
R003-P1-C035A003 / TextSection 8(d) permits specified marital/support-income/spouse-resource inquiries where financial need is a special-purpose-program criterion. Its separate signature sentence permits obtaining a spouse’s or another person’s signature on a program application or credit instrument if Federal or state law requires it.A program label or creditor preference does not satisfy the signature condition. Section 8(c)’s information permission is not a free-standing authorization to demand any spouse’s guaranty.S011, §8(c)–(d). Consumer Financial Protection Bureau
R003-P1-C036A003 / Text + CommentThe special-program branch requires a qualifying §8(a) program: legally authorized assistance for an economically disadvantaged class; qualifying nonprofit assistance; or a qualifying for-profit program meeting the written-plan and need conditions. Current for-profit rules require the plan’s specified class, procedures, evidence, and explanation of otherwise-unavailable credit; additional conditions govern otherwise-prohibited common characteristics.Current §8(b)(3) bars race, color, national origin, and sex as for-profit-program eligibility characteristics; §8(b)(4) requires participant-specific evidence for other otherwise-prohibited characteristics. Anti-evasion and other Regulation B provisions remain applicable. No actual program is evaluated.S011, §8(a)(1)–(3), (b)(1)–(4), comments 8(a)-1–6 and 8(b)-1–2. Consumer Financial Protection Bureau
R003-P1-C037A003 / Text + CurrentnessThe 2026 final rule states that special-program credit extended on or after July 21, 2026 must comply with its new requirements; prior extensions must comply with the applicable earlier program rules described in its effective-date discussion.A preexisting program is not thereby authorized to make all future extensions indefinitely under old rules. This pass does not certify absence of later judicial orders.S012, printed pp.21620, 21658–21659 / indexes 0, 38–39. govinfo.gov +1
R003-P1-C038A003 / Text + SynthesisAppendix B models are optional. Appropriate use/modification yields the specified compliance treatment for §1002.5(b)–(d) inquiries.That limited effect is not a general contract-formation, guaranty-enforceability, joint-intent, or liability safe harbor.S013, introductory paragraphs 1–3; S008, comment 7(d)(1)-3. Consumer Financial Protection Bureau
Source links captured in this table

Captured table 04

Claim ID · Area / type · Precise assertion and operative conditions · 19 data rows

Claim IDArea / typePrecise assertion and operative conditionsLimits / exceptionsSource / exact pinpoint
R003-P1-C039A003 / TextPart 444’s creditor is a covered lender or retail installment seller: lending money to consumers, or selling goods/services on deferred-payment or lease-purchase terms, within FTC jurisdiction. Consumer means a natural person seeking/acquiring goods, services, or money for personal, family, or household use. Section 444.3 concerns consumer credit in or affecting commerce.Its broad definition of debt—money due or alleged due—does not erase these actor, purpose, obligation, and commerce conditions. Business credit is not brought within this consumer rule merely by adding a natural-person guarantor.S015, §444.1(a)–(g), §444.3(a). ecfr.gov
R003-P1-C040A003 / TextFTC Act §45(a)(2) excludes banks, savings-and-loan institutions, and federal credit unions as statutorily defined, along with other enumerated categories, from the FTC’s stated enforcement jurisdiction.“Credit union” is not synonymous with “federal credit union.” Nor does “nonbank” alone establish coverage. Section 44’s organizational definition and §57a(f)’s institution definitions matter; no actual status was investigated.S018, §§44, 45(a)(2), 57a(f)(2)–(4); S015, §444.1(a)–(b). uscode.house.gov +2
R003-P1-C041A003 / GuidancePublished FTC materials describe the rule as excluding real-estate purchases, while covering qualifying consumer loans secured by already-owned real estate.This is the FTC’s published scope explanation, not an express real-estate-purchase phrase in §444.1. Do not convert it into an exclusion of every real-estate-secured loan or every mortgage-related transaction.S016, “What Transactions Are Covered”; S017, “What Are My Obligations…”. Federal Trade Commission +1
R003-P1-C042A003 / TextA cosigner under §444.1(k) is a natural person who becomes liable for another’s obligation without compensation. The definition expressly includes a signature demanded to extend credit to another or to forbear collection of another’s defaulted obligation.The rule is not confined to new-money originations. The underlying consumer-credit and actor requirements still apply.S015, §444.1(k). ecfr.gov
R003-P1-C043A003 / Text + GuidanceSomeone receiving no goods, services, or money in return for the credit obligation receives no compensation for this definition; labels do not control. FTC guidance distinguishes a genuine co-buyer sharing purchased goods or co-borrower sharing proceeds from a supporting cosigner.A “co-borrower” caption cannot dispose of contrary facts. Conversely, a primary purchaser is not made a covered cosigner merely because another person also signs. Shared household membership alone does not establish the actual benefit or contractual role.S015, §444.1(k); S016, “Notice to Cosigners,” final paragraphs. ecfr.gov +1
R003-P1-C044A003 / Text + GuidanceThe rule expressly excludes a spouse whose signature is required to perfect a state-law security interest. FTC guidance also says no notice is needed for a security-agreement signer who has no personal liability.A document that also imposes a personal undertaking requires analysis of its actual terms; “property owner” is not a universal cosigner exemption.S015, §444.1(k); S016, “Notice to Cosigners.” ecfr.gov +1
R003-P1-C045A003 / TextSection 444.3(a)(1) prohibits direct or indirect misrepresentation of the nature or extent of cosigner liability to any person. Section 444.3(b) states that compliance with paragraph (c)’s preventive requirements does not violate paragraph (a).Paragraph (b)’s statement concerns the specified paragraph (a); it is not a universal contractual-enforceability or all-laws immunity provision.S015, §444.3(a)(1), (b). ecfr.gov
R003-P1-C046A003 / TextThe creditor must inform the cosigner before obligation and give the prescribed disclosure before that event. For open-end credit, the specified event is execution of the agreement creating liability for future charges.Delivery after obligation does not satisfy the express prior-delivery condition. No fixed number of advance days is stated here.S015, §444.3(a)(2), (c). ecfr.gov
R003-P1-C047A003 / TextThe regulatory disclosure is a separate document containing the prescribed statement, without other statements under the literal rule.Section 444.3 does not specify a numerical font size. Staff explanations concerning permitted administrative additions and packet placement are separately classified below.S015, §444.3(c). ecfr.gov
R003-P1-C048A003 / Text — notice element 1Under the heading Notice to Cosigner, the opening paragraph says the recipient is being asked to guarantee the debt, should consider that choice carefully, will have to pay if the borrower does not, and should assess both ability and willingness to accept that responsibility.This is the complete opening warning in paraphrase, not a finding that an enforceable guaranty has already been formed.S015, §444.3(c), heading and first notice paragraph. ecfr.gov
R003-P1-C049A003 / Text — notice element 2The second paragraph warns of possible responsibility for up to the entire debt if the borrower fails to pay, and possible late fees or collection costs increasing the amount.It supplies no calculation of an actual balance, permissible charge, or award.S015, §444.3(c), second notice paragraph. ecfr.gov
R003-P1-C050A003 / Text — notice element 3The third paragraph warns that the creditor can seek payment from the cosigner without first trying the borrower; can use the same collection methods, including suit or wage garnishment; and that default may enter the cosigner’s credit record.This warning is not an independent grant of collection powers or an override of state collection-sequence protections, contract terms, exemptions, or required judicial procedures.S015, §444.3(c), third notice paragraph; S017, state-law qualification immediately following the notice. ecfr.gov +1
R003-P1-C051A003 / Text — notice element 4The final paragraph states: “This notice is not the contract that makes you liable for the debt.”Notice receipt, including an acknowledgment, must not be substituted for the actual liability-creating instrument.S015, §444.3(c), final notice paragraph. ecfr.gov
R003-P1-C052A003 / GuidanceFTC staff permits letterhead, identifying details, an optional receipt-signature line, consistent state notices, and omission of a statement inaccurate under state law. It forbids distracting additions and permits attachment only when the notice comes first in the packet. Its guidance says revolving-account notice is given once at opening; FTC advice says it should match the agreement’s language.These are published implementation explanations; they do not amend the literal regulation or establish a general notice-expiration/cancellation rule. No identifying details were entered here.S016, “Notice to Cosigners”; S017, language paragraph. Federal Trade Commission +1
R003-P1-C053A003 / Text + SynthesisPart 444 does not itself prescribe a signed acknowledgment, fixed notice-retention period, or periodic notice-expiration interval. An acknowledgment may evidence receipt, but its presence does not establish every delivery condition.Absence of a document from a reviewed set is not automatically proof of nondelivery. Other retention, disclosure-copy, electronic-delivery, or evidentiary laws are not negated by this limited reading.S015, complete §§444.1–.5; S016, optional acknowledgment/file-copy explanation. ecfr.gov +1
R003-P1-C054A003 / GuidanceFTC consumer advice recommends obtaining relevant papers and arranging statements/default alerts.That advice is not a universal affirmative duty under part 444 to deliver every loan paper or later account statement. Product-specific and state-law rights remain outside this finding.S017, “If I Cosign a Loan, What Can I Do To Protect Myself?” Consumer Advice
R003-P1-C055A003 / TextUnder §444.5, an appropriate state agency must apply, and the FTC must determine that an effective state requirement affords substantially equivalent or greater protection. The federal provision then ceases to operate only to the extent specified and while effective state administration/enforcement continues.Stronger state law alone is not an automatic exemption. Specific currently operative exemption determinations were not verified in this pass.S015, §444.5(a)(1)–(2) and concluding condition. ecfr.gov
R003-P1-C056A003 / TextFTC Act §57a(g) separately permits petitions for person/class exemptions and specifies the Commission’s finding and procedural requirements.Petition or review pendency does not itself stay the rule. No exemption is inferred merely from a request or from a failed source retrieval.S018, §57a(g)(1)–(3). uscode.house.gov
R003-P1-C057A003 / Text + SynthesisA missing or late required notice raises a compliance issue under §444.3. The read provisions do not establish automatic debt cancellation, release, a notice-based rescission period, uniform unenforceability, or a private cause of action.An actual remedy requires the applicable enforcement/remedies authority, forum, contract, state law, and facts. The FTC booklet dates the rule’s operation to March 1, 1985; that historical trigger is distinct from this report’s access date.S015, §444.3; S016, introduction and effective-date discussion. ecfr.gov +1
Source links captured in this table

Captured table 05

Claim ID · Area / type · Precise assertion and operative conditions · 9 data rows

Claim IDArea / typePrecise assertion and operative conditionsStatus / jurisdiction / limitsSource / exact pinpoint
R003-P1-C058A003 / Text + Final-rule historyDodd-Frank repealed the former institution-specific FTC Act rulemaking authority. The Federal Reserve’s final rule formally removed former Regulation AA, 12 C.F.R. part 227, effective March 21, 2016. It explains that the statutory repeal nullified the relevant provisions and that Regulation AA did not transfer to CFPB under the FTC Act.The 2010 enactment date, designated-transfer-date provision, and 2016 formal removal are distinct. The FTC’s own part 444 remained a separate rule.S018, §57a(f)(1), 2010 effective-date note; S020, pp.8133–8134 / indexes 0–1. uscode.house.gov +1
R003-P1-C059A003 / Final ruleNCUA removed and reserved part 706 effective October 3, 2014. Its final rule expressly retained the distinction between repealed regulations and continuing statutory supervisory/enforcement authority.A federal-credit-union notice obligation cannot simply be asserted today by citing former §706 as a current rule.S021, p.59627 / index 0; removal instruction 3, p.59629 / index 2. govinfo.gov +1
R003-P1-C060A003 / Guidance + Final-rule historyThe joint agencies explained that former OTS part 535 was omitted from OCC republication because the relevant authority was unavailable and was effectively repealed July 21, 2011. Treasury later directed removal of obsolete OTS chapter V as non-substantive cleanup.The complete 2011 republication was not independently reconstructed. The 2017 Treasury document’s printed effective date is October 11, 2018; no correction was verified. Neither document is treated as creating a new cosigner-notice duty.S023, footnote 9; S022, OCC p.48950 / index 0; Treasury pp.47083–47084 / indexes 0–1. federalreserve.gov +2
R003-P1-C061A003 / TextSeparate federal statutory prohibitions remain relevant. Section 5531 addresses UDAAP involving covered persons/service providers and consumer financial products/services; §5536 contains operative prohibitions. Section 45 supplies the FTC Act prohibition, with enforcement and actor qualifications.Statutory unfairness has specified injury, avoidability, and countervailing-benefit conditions; a regulatory repeal does not establish that every former practice is permissible. These statutes do not themselves reproduce §444.3(c)’s exact notice as a universal institutional obligation.S018, §45(a); S019, §§5531(a)–(d), 5536(a); S020–S021. uscode.house.gov +3
R003-P1-C062A003 / Verified publisher statusAs checked on D, CFPB’s guidance index still listed the 2014 credit-practices guidance, its withdrawal register did not list that item, and NCUA expressly marked its accompanying letter Active. Fed and OCC publisher pages remained posted without an observed rescission banner.FDIC publisher status remains unresolved: both attempted official pages returned 403. The verified statuses are stated agency by agency; publication of an old document alone was not treated as a complete currentness check.S024–S025; failure F04 below. Consumer Financial Protection Bureau +4
R003-P1-C063A003 / Guidance + SynthesisThe 2014 guidance says repeal is not a determination that former practices are permissible; statutory violations depend on facts and circumstances. Footnote 11 expresses the agencies’ view that continuing to provide a notice before obligation properly discloses cosigner liability.This is a supervisory interpretation, not a newly enacted regulation applying the FTC’s exact affirmative notice duty to every exempt institution, and not an independently created private right. Operative assertions must rest on current statutes/rules.S023, guidance body and footnote 11; S019–S021. federalreserve.gov
R003-P1-C064A003 / Withdrawal / historyThe CFPB’s proposed Regulation AA was withdrawn May 15, 2025. Its August 2026 regulatory-priorities statement again identifies the withdrawal.The remaining proposal landing page does not make the proposal final or revive former Federal Reserve Regulation AA. No new universal cosigner-notice obligation is established by these materials.S026, withdrawal p.20569 / index 0; agenda p.52943 / index 151. govinfo.gov +2
R003-P1-C065A003 / Text + SynthesisECOA’s civil-liability provisions address an aggrieved applicant and authorize specified court relief; they also include a good-faith-conformity protection. A signature-rule violation is therefore not itself a complete adjudication of contract invalidity or of a particular claimant’s remedy.Statutory applicant status, court/claim posture, state defenses, relief, and later authority remain separate. No damages, limitation-period, or litigation-strategy analysis is supplied.S004, §1691e(a), (c), (e); S027–S028. uscode.house.gov +2
R003-P1-C066A003 / SynthesisThe audit must distinguish application intent, capacity, express promise, security consent, notice delivery, and governing property law. Evidence of one cannot automatically stand in for all the others.Neither household relationship, marriage, credit reporting, account access, nor an official model notice alone proves actual personal liability. This is an evidentiary limit of the researched federal sources, not a ruling that other law can never impose an obligation.S006, §2(i); S008, comments 7(d)(1)-3 and 7(d)(4)-3; S010, §11(d); S015, §444.3(c). Consumer Financial Protection Bureau +4
Source links captured in this table

Captured table 06

Generic institutional class · What this pass establishes · What it does not establish · 5 data rows

Generic institutional classWhat this pass establishesWhat it does not establish
FTC-covered nonbank lender or retail installment sellerPart 444 can impose the notice duty when its consumer-credit, cosigner, timing, and exemption conditions are met.That every nonbank or every transaction is covered.
Statutorily defined bankDo not apply part 444 solely because the activity resembles consumer lending. Former part 227 is repealed; separate statutory and guidance analysis remains.A universal current bank notice obligation, or freedom to misrepresent liability.
Statutorily defined savings institutionFormer OTS rule history must be separated from current statutory powers and any other applicable law.That an obsolete part-535 citation proves a present affirmative duty.
Federal credit unionFTC jurisdictional exclusion and NCUA’s part-706 repeal are material. NCUA’s guidance-status page is Active.That repeal permits every formerly prohibited practice.
State-chartered credit union or uncertain institutional classThe federal-credit-union exclusion cannot be assumed to cover it; FTC jurisdiction and other applicable law need their own analysis.Actual charter, organizational, insurance, regulatory, or transaction status. No roster was used.

Captured table 07

Worksheet item · Question to resolve · Evidence or published authority needed · 28 data rows

Worksheet itemQuestion to resolveEvidence or published authority neededBlank findingClaim links
W01 — Engagement and transactionWhat credit, purchase, or service arrangement is described, and what question about the signature is being asked?Complete generic engagement/application and transaction terms; primary purpose; deferral structure.C002, C004, C039
W02 — Creditor roleWhich legal actor category and credit-decision role is relevant?Stated legal capacity and applicable statutory definitions; decision participation versus referral-only role. No entity lookup.C003, C008, C040
W03 — Transaction exceptionsDoes a securities, incidental, government, utility, special-program, or FTC exemption branch apply?Complete defining conditions and any applicable published exemption determination.C009–C012, C035–C037, C055–C056
W04 — Application requestWas individual or joint credit actually requested under the applicable procedures?Complete application, instructions, and generic description of oral/written procedures.C004, C016–C018
W05 — Joint intentIs joint-credit intent evidenced at application independently of accuracy certification?Separate intent affirmation and its timing; distinguish later note execution and joint financial statements.C017–C018
W06 — Additional-signature conditionWas the signer voluntarily applying, or added because the creditor demanded support?Application conditions, approval conditions, and the stated reason for requesting the signature.C016–C018, C027
W07 — Individual qualification premiseWhat standards and requested amount/terms make the qualified/unqualified branch relevant?Applicable standards and the stated evaluation basis; no invented score or numerical qualification.C016, C019, C027
W08 — Named capacity and signature blockDoes the document identify a borrower, guarantor, owner, authorized agent, witness, or consent-only signer?Complete signature block, incorporated definitions, capacity clauses, and cross-references.C005–C006, C024–C026
W09 — Express promiseWhat exact language creates an alleged repayment obligation, and for which debts?Entire promise-to-pay/account agreement, incorporated terms, conditions, and exclusions.C006, C051, C066
W10 — Guaranty scopeIs the undertaking limited, continuing, conditional, secured, or associated with renewals/future advances?Complete generic guaranty, termination/release provisions, modification terms, and governing law.C007, C027, C032, C065
W11 — Formation and authorityWhat remains necessary to establish execution, assent, authority, authenticity, or capacity?Applicable published formation/agency law and relevant execution evidence; these are parent holds.C006, C065–C066
W12 — Collateral-only consentIs the signature solely to make identified security available?Complete security instrument; any limitation legend; separation from note/guaranty.C024–C026, C044
W13 — State-law necessityWhich state law requires or supports belief that this instrument/signature is needed?Pertinent statutes, published decisions, or attorney-general opinion; property situs and governing-law questions kept separate.C021–C025
W14 — Joint-property interestHas the applicant’s existing interest been valued independently?Ownership-form assumptions; attachment/execution/partition rules, resulting value and costs.C019–C021
W15 — Community-property conditionsAre residence/property location, management/control, community assets, and separate-property sufficiency established?Applicable published state law and the specific qualifying facts; no marital presumption substituted for them.C023
W16 — Reliance on another’s incomeIs the other person’s income actually relied upon, and how must it be made available?Income-reliance terms; state characterization of separate income and future earnings.C029
W17 — Business relationshipIs a guarantee requested because of a qualifying business role, or merely marriage/protected status?Generic organizational role and guarantee policy; distinguish spouse from partner/officer/shareholder role.C030–C031
W18 — Special-purpose programIs the program within current §8, and what law specifically requires the signature?Published enabling law, program rules, required plan elements, relevant version, and signature mandate.C035–C037
W19 — FTC cosigner roleIs the proposed signer a natural person supporting another’s obligation without compensation, or a genuine primary beneficiary?Proceeds/goods/services allocation and complete obligations; labels alone insufficient.C039, C042–C044
W20 — Notice content/versionDoes the notice contain the complete applicable prescribed warning?Blank official notice and complete generic notice specimen; any state-law modification authority.C047–C052
W21 — Obligation and delivery sequenceWhen does liability arise, and was the notice given before that event?Agreement-execution sequence and delivery evidence; for open-end credit, agreement covering future charges.C046
W22 — Format and placementIs the notice separate, and how is it placed in the packet?Complete generic packet, notice placement, additions, language, and applicable official explanations.C047, C052
W23 — Receipt evidenceIs there proof of delivery, merely a file copy, an acknowledgment, or no available evidence?Delivery/receipt evidence and its limits; distinguish missing document from proven nondelivery.C051, C053, C057
W24 — Copies and records gapWhich relevant instruments or delivery materials remain unavailable?Explicit inventory of missing categories; separate any independently applicable copy/retention law.C053–C054
W25 — Renewal/releaseWas creditworthiness reevaluated at renewal, and was the additional party still warranted?Renewal terms, stated reevaluation, applicable guarantee basis, and release instrument if relevant.C007, C030, C032
W26 — Open-end changes/accessIs a marital/status change being used to demand reapplication, alter access, or add liability?Existing terms, supporting-income facts, permitted reapplication conditions, and express authorized-user undertaking.C033–C034
W27 — Remedy and forumWhat published authority supports the claimed consequence of a violation?Applicable statutory claimant rule, published forum authority, state defenses, remedy provisions, and later history.C015, C057, C065
W28 — Final inference checkIs any conclusion resting only on marriage, household, title, credit reporting, access, or receipt of a notice?Identify the missing promise, capacity, application intent, property-law link, or remedy authority.C018, C024–C026, C051, C066

Captured table 08

Example / assigned branch · Expressly assumed facts · Federal result at this pass’s scope · 15 data rows

Example / assigned branchExpressly assumed factsFederal result at this pass’s scopeContract/state-law unknowns and evidence neededAdverse classification to avoid
H01 — Qualified sole applicant; Q6(a)An individual applies alone, independently meets the creditor’s standards for the requested terms, and is asked for a spouse’s personal guaranty. No property, income-reliance, business-role, or program exception is assumed.The demand conflicts with the general §7(d)(1) restriction. C016, C027.Need the application, condition imposed, actual guarantee, applicable claimant/remedy authority, and state contract law before deciding consequences.Treating the spouse as a voluntary joint applicant; or treating the prohibited demand as automatic proof the guaranty is void.
H02 — Genuine joint applicants; Q6(b)Both applicants contemporaneously request shared credit and separately affirm that intent at application.The joint-applicant exception permits obtaining both applicants’ signatures. C017–C018.The application is not the complete repayment contract. Need actual promise language, capacities, execution, and governing law; FTC primary-beneficiary status is a separate test.Assuming joint intent alone establishes every later personal obligation; or treating every joint applicant as a notice-entitled cosigner.
H03 — Sole applicant; other owner signs security; Q6(c)One applicant seeks secured credit. Applicable law is assumed to require another owner’s signature only on a security instrument; the instrument clearly excludes that owner’s personal promise.The collateral signature may be required. Requiring a note solely for convenience would not fit the assumed necessity. A signer with no personal liability is not converted into an FTC cosigner. C024–C026, C044.Need the complete instrument and actual published property law. Lien validity, priority, foreclosure, and recourse remain unproved.Calling the owner a personal debtor; or saying the owner faces no exposure because no personal promise exists.
H04 — Business guarantor and spouse; Q6(d)Credit is primarily business credit. An officer’s guaranty is requested because of the officer role, even though the business qualifies. The officer’s spouse is then automatically asked to guarantee.The role-based officer guaranty may be permitted; automatic spouse addition is not justified by that permission. The FTC consumer-notice rule is not established for the assumed business transaction. C030–C031, C039.Need full guarantees, the relationship-based policy, property/income facts if another exception is invoked, and state guaranty law.Treating all business guarantees as prohibited for a qualified business; or treating every officer’s spouse as responsible.
H05 — Community-property uncertainty; Q6(e)A married sole applicant has the specified community-property-state connection, but management/control law and separate-property sufficiency are unknown.The connection alone does not resolve §7(d)(3). Both substantive conditions and necessary-instrument analysis remain open. C023.Need published state management/control and debt-access rules, property characterization, and the relevant sufficiency facts.Inferring joint personal debt from marriage or geography; or rejecting every spouse signature without examining the statutory conditions.
H06 — FTC cosigner versus primary purchaser; Q6(f)In a covered consumer transaction, an unpaid natural person supports another’s debt and receives no goods, services, or money. Compare a genuine joint purchaser receiving the purchased goods.The first fits the defined cosigner branch; the genuine primary-beneficiary alternative may not. Labels cannot substitute for the facts. C042–C043.Need complete obligation language and allocation of benefits. Neither notice status decides enforceability.Reclassifying a supporting signer as a co-borrower merely by caption; or treating every jointly signed purchase as a cosigner transaction.
H07 — Missing or late notice; Q6(g)Alternative A: the required notice is proved to have been delivered only after obligation. Alternative B: no notice is present in the available document set, but delivery history is unknown.A fails the prior-delivery condition. B is an evidence gap, not yet proof of nondelivery. Neither yields automatic release. C046, C053, C057.Need the obligation-formation event, delivery sequence, applicable exemption status, and remedy authority.“No copy means no notice”; “late notice automatically cancels the debt”; or “signed guarantee proves notice compliance.”
H08 — Institution class uncertain; Q6(h)Only a generic description such as bank, credit union, or finance business is supplied; no statutory classification is established.FTC-rule coverage cannot be decided from the label. ECOA/Regulation B and other statutory duties require their own coverage analysis. C003, C039–C040, C058–C064.Need legal-category and transaction facts; no roster or real institution search is authorized or performed.Applying part 444 identically to every institution; or assuming absence of FTC jurisdiction removes all federal protections.
H09 — Renewal and releaseAt renewal the creditor reevaluates creditworthiness and determines that no additional party remains warranted under the applicable rules; no independent business-role basis is assumed.The official comment requires release of the additional party. If reevaluation or the no-longer-warranted premise is missing, that specific result is not established. C032.Need renewal/reevaluation evidence and release terms; scope of historical liability and any separate continuing guaranty remains open.Treating guarantees as automatically perpetual; or treating every renewal as automatic discharge.
H10 — Unsecured joint assetsA sole applicant relies on joint property; the applicant’s own existing interest is assumed sufficient for the requested terms.The nonapplicant owner’s signature cannot be demanded under the insufficiency branch. If the interest is insufficient, the limited alternatives must be examined. C019–C022.Need the existing ownership form, property-situs law, accessibility, value, costs, and instrument purpose.Ignoring the applicant’s own interest; relying on imagined future divorce; or routinely requiring forfeiture of the other owner’s title.
H11 — Reliance on spouse’s incomeAn individual application actually relies on the spouse’s income; it is assumed not automatically available as community property.A signature making that relied-on income available may be permitted. The reason is the specific income reliance, not marriage alone. C029.Need income characterization, enforceable commitment terms, and relevant state law.“A spouse can never be required to sign”; or “every married applicant must obtain a spouse signature.”
H12 — Incidental-credit exceptionThe extension is assumed to meet every element of §3(c)(1), including its non-card, no-finance-charge, and installment conditions.Section 7(d) is excepted. That does not erase the general discrimination rule or independently settle FTC coverage. C010, C039.Need terms establishing the exception and separate actor/consumer-purpose analysis; state liability remains open.Applying §7(d) merely because the arrangement is credit; or treating the exception as proof that nobody owes.
H13 — Special-purpose programA qualifying program is asserted, and a signature is said to be required by law; no actual enabling law or compliant program materials are supplied.The label alone is insufficient. Current §8 prerequisites, the applicable version, and the specific legal signature requirement must be established. C035–C037.Need published enabling law and generic program materials; no actual eligibility assessment is made.Treating any “special program” as permission to require a spouse’s personal guaranty.
H14 — Defaulted obligation and forbearanceA covered creditor conditions forbearance on a defaulted consumer obligation on an unpaid natural person’s new supporting undertaking.The FTC cosigner definition expressly reaches this branch; the notice must precede the new obligation. C042, C046.Need forbearance/guaranty terms, formation and consideration law, delivery sequence, and coverage/exemption facts.Assuming notice applies only when fresh loan proceeds are advanced.
H15 — Account access without demonstrated promiseA person has account access or an authorized-user designation, but no express undertaking has been established.Regulation B permits certain contractual-liability conditions for authorized users; that permission does not prove this user agreed. C006, C034.Need complete agreement and capacity/assent evidence; other possible legal bases remain parent holds.Treating access, household membership, or a credit-report entry as conclusive personal liability.

Captured table 09

Assigned subquestion / significant branch · Status and reason · Claim / example links · 45 data rows

Assigned subquestion / significant branchStatus and reasonClaim / example linksExact remaining gap and next bounded permissible investigation
Q1 — ECOA statutory actor, applicant, credit, personAnswered at necessary statutory scope.C001–C006; S001–S002Actual role/request/purpose facts absent. Next: compare a generic document’s stated roles with the cited definitions.
Q1 — Consumer versus business coverageAnswered. Both may fall under Regulation B; FTC purpose rule is narrower.C002, C030, C039; H04Mixed-purpose characterization may need generic terms and applicable published interpretation. No broad classification survey undertaken.
Q1 — Participating creditor, assignee, referral-only actorAnswered as a rule; actual participation unresolved.C003Need role and decision-participation facts; do not infer §7(d) coverage from referral language limited to §4(a)–(b).
Q1 — Guarantor regulatory inclusionAnswered. Inclusion is express for §7(d).C005, C031Does not supply statutory plaintiff/defense status.
Q1 — Statutory guarantor claim/defense and jurisdictionPartial. One complete appellate majority and its Supreme Court disposition read.C015, C065; S027–S028Current governing forum’s published authority and precise posture remain missing. Next: bounded published-opinion review after a jurisdictional research scope is defined; no docket/status query.
Q1 — Securities exceptionAnswered. Express §7(d) exclusion.C009Actual statutory securities-credit classification absent; next published-law analysis only if needed for a generic scenario.
Q1 — Incidental-credit exceptionAnswered. Complete conjunctive definition and signature exception identified.C010; H12Need transaction terms for each element; no automatic exemption merely from “bill” or “service.”
Q1 — Government creditAnswered. To-government versus by-government distinction made.C011Actual recipient class absent.
Q1 — Utility creditAnswered. Listed exception does not eliminate §7(d).C012Need service and rate-regulation facts; no utility entity lookup.
Q1 — Territory and §1029 dealer boundaryPartial. Part-1002 boundary and Act preservation established.C008; S005, S014Complete counterpart part-202 treatment for an excluded dealer not completed. Next: published counterpart regulation and transfer-rule analysis only.
Q1 — Currentness/effective/later historyPartial, expressly bounded. Current agency text and relevant final rules read.C037, C058–C064No complete session-law lag audit, official annual-CFR audit, or universe of judicial orders. Next: targeted published amendments/opinions, without case-record searches.
Q2 — Individually qualified applicant; Q6(a)Answered with exceptions visible.C016; H01Actual qualification not assessed; contract consequence/remedy remains separate.
Q2 — Genuine joint application; Q6(b)Answered. Contemporaneous intent and separate evidence requirements covered.C017–C018; H02Need application-stage evidence, not just a later note or financial statement.
Q2 — Unsecured joint property: valuationAnswered. Existing-interest valuation and speculative-change prohibition covered.C019–C020; H10State attachment/partition rules and value/cost facts missing. Next: state published law for a specified generic ownership form.
Q2 — Unsecured joint property: instruments/optionsAnswered. Necessity, death/default access, alternatives, and forfeiture limit covered.C021–C022; H10Exact instrument and state-law necessity missing.
Q2 — Community property; Q6(e)Answered rule; application unresolved. Both required financial/property conditions stated.C023; H05State management/control, separate/community characterization, and sufficiency facts missing.
Q2 — Secured collateral-only signature; Q6(c)Answered. Security access distinguished from personal promise.C024–C025; H03State lien-creation requirements and full instrument missing; perfection/priority/remedies excluded.
Q2 — Integrated note/security documentAnswered. Clear limitation requirement and example of nearby legend covered.C026; H03Need the whole document; no unseen signature block or legend treated as inspected.
Q2 — Additional personal party and spouse choiceAnswered. Necessity does not authorize a spouse-only condition.C027–C028; H01Actual standards, reason, and eligibility restrictions missing.
Q2 — Other person’s/spouse’s incomeAnswered. Separate-income and future-earnings conditions covered.C029; H11Actual reliance and state income characterization missing.
Q2 — Business role and guarantor’s spouse; Q6(d)Answered. Qualified-business exception and spouse protection both covered.C030–C031; H04Role, financial circumstances, guarantee terms, and state law missing.
Q2 — Renewals, extensions, releaseAnswered at definition and conditional-comment scope.C007, C032; H09Reevaluation, continuing justification, and effect on existing obligations missing. General release/novation law excluded.
Q2 — Existing open-end account changesAnswered only as material to signature/reapplication issues.C033Supporting-income facts and existing terms missing; no general adverse-action survey.
Q2/Q5 — Authorized-user and overdraft distinctionsAnswered. Permissible required undertaking separated from actual agreement.C006, C034; H15Express contractual undertaking and other possible legal bases unproved.
Q2 — Special-purpose-program exceptionAnswered rule; actual program unresolved. Current prerequisites and law-required signature condition covered.C035–C037; H13Specific program law, date/version, and compliant generic materials missing; actual eligibility excluded.
Q3 — FTC creditor/debt/consumer/commerce coverageAnswered at rule-definition level.C039–C040Actual institutional and transaction facts absent; statutory cross-reference classification not performed for any entity.
Q3 — Real-estate-purchase scopeAnswered as published FTC interpretation, not invented rule wording.C041Boundary cases such as mixed-purpose/refinancing structures not comprehensively researched. Next: targeted official published interpretation for a defined generic structure.
Q3 — Cosigner versus co-borrower; Q6(f)Answered. Natural-person, another’s obligation, compensation, benefit, and label conditions covered.C042–C044; H06Actual benefit allocation and obligation terms missing.
Q3 — Defaulted obligation/forbearanceAnswered. Express definitional branch included.C042, C046; H14New undertaking’s formation and prior delivery evidence missing.
Q3 — Complete required notice contentAnswered. All four paragraphs and heading accounted for.C048–C051; S015Paraphrase is not a substitute compliance form; actual notice version not reviewed.
Q3 — Timing and open-end triggerAnswered. Before obligation; future-charge agreement execution for open-end credit.C046; H07Actual chronology unproved. No invented advance-day rule or expiry period.
Q3 — Format, packet placement, languageAnswered with authority levels separated. Rule versus staff implementation guidance distinguished.C047, C052Complete generic packet, additions, and applicable state-language rules absent. Electronic-delivery law excluded.
Q3 — Collection sequence and rightsAnswered as warning and limitation. No universal collection-first priority inferred.C050, C052State sequence, contract waivers, judicial procedures, exemptions, and actual remedies remain missing.
Q3 — Records, copies, acknowledgmentAnswered within part 444 and the official materials read.C051, C053–C054Other retention/copy statutes and actual delivery evidence unreviewed; absence of a file copy is not decisive.
Q3 — Missing/late notice; Q6(g)Answered at compliance level; remedy unresolved.C057; H07Need formation timing, delivery proof, governing remedies law, and forum. No automatic release or private cause inferred.
Q3 — FTC state/person exemptionsPartial. Complete mechanisms read; specific current determinations not verified.C055–C056A historical California exemption reference surfaced, but operative/current determination was not read. Next: the published FTC determination and any published amendment/revocation, without state-wide liability surveying.
Q4 — Bank/CU/nonbank distinction; Q6(h)Answered framework; actual coverage unresolved.C040, C058–C064; H08Exact statutory actor class absent; no roster used.
Q4 — Federal Reserve and NCUA repealsAnswered. Actual final-rule bodies/instructions and dates read.C058–C059No actual pre-repeal transaction adjudicated; other laws remain separate.
Q4 — OTS/OCC historyPartial historical reconstruction. Joint explanation and actual integration/removal documents consulted.C060Full 2011 republication comparison and any correction to the later printed effective date not verified. Next: published correction/republication text only if that historical date matters.
Q4 — 2014 guidance current statusPartial across publishers. CFPB/NCUA status verified; Fed/OCC pages checked; FDIC blocked.C062–C063FDIC publisher status not established. Next: an accessible official publication or withdrawal notice; no access workaround.
Q4 — Statutory authority versus new notice dutyAnswered at bounded level. Repeal, statutes, and guidance separated.C061, C063A particular conduct-based UDAAP determination requires its statutory elements and facts; none made.
Q4 — Proposed replacementAnswered for the identified proposal. Actual withdrawal and later agency acknowledgment read.C064No assertion that an old proposal page is current law; no exhaustive inventory of every possible product-specific duty.
Q5 — Blank liability/signature auditAnswered. W01–W28 provided, with blank findings.C038, C066; worksheetActual formation, authority, signatures, state-law effects, and remedies deliberately unresolved.
Q6 — All eight required branches and additional failuresAnswered. H01–H08 map directly to (a)–(h); H09–H15 cover additional material branches.H01–H15Hypotheses are assumptions for analysis, not records, actual qualification findings, or real liability decisions.
General debt/TILA/FDCPA gateways; comprehensive state/remedy/litigation surveysExcluded by assignment.Parent holds belowNo prior report assumed to have completed these dimensions.

Captured table 10

Log item · Exact route(s) / event · Result and treatment · 16 data rows

Log itemExact route(s) / eventResult and treatment
F01 — Legacy House routeshttps://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1691a&num=0&edition=prelim ; https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1691a+edition%3Aprelim%29 ; https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1691+edition%3Aprelim%29404/maintenance responses on these routes. Necessary statutory bodies were subsequently read through S001–S002’s canonical compilation URLs.
F02 — Earlier §1691d/e routeshttps://uscode.house.gov/us/usc/119-121/t15/s1691d/ ; https://uscode.house.gov/us/usc/119-121/t15/s1691e/ ; https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1691d&num=0&edition=prelim ; https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1691e&num=0&edition=prelimTimeout/server/404 failures. Resolved by S003–S004’s 119-124 compilation URLs.
F03 — Annual-code alternativeshttps://www.govinfo.gov/content/pkg/USCODE-2025-title15/html/USCODE-2025-title15-chap41-subchapIV-sec1691d.htm ; https://www.govinfo.gov/content/pkg/USCODE-2025-title15/html/USCODE-2025-title15-chap41-subchapIV-sec1691e.htmTool-inaccessible. Not counted as statutory reads; canonical House bodies supplied the necessary text.
F04 — FDIC guidance statushttps://www.fdic.gov/news/financial-institution-letters/2014/fil14044.html ; https://www.fdic.gov/laws-and-regulations/fdic-and-interagency-statementsBoth returned 403. FDIC current publisher status remains unresolved. Search discovery was not substituted for a body read.
F05 — eCFR access challengehttps://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.7 ; resulting access page https://unblock.federalregister.gov/A later retrieval encountered an access/CAPTCHA page. No workaround attempted. Complete necessary regulation/commentary read from CFPB’s public regulation page.
F06 — Wrong-date NCUA routehttps://www.govinfo.gov/content/pkg/FR-2014-09-29/pdf/2014-22715.pdfInaccessible. Correct October 3 publication retrieved and read at S021.
F07 — OCC historical routehttps://www.govinfo.gov/link/fr/76/48950Inaccessible. The alternate published-page link in S022 returned the 250-page integration document. Only the stated portions were read; no full-document omission comparison claimed.
F08 — Appendix B and visual limitshttps://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1002-appB.pdf ; S013’s two image URLs.Guessed annual-appendix route inaccessible. Image retrieval returned markers rather than inspectable pixels. No form-layout or image-text findings are claimed. Official introductory text and model legal clauses support the worksheet.
F09 — Historical exemption discoveryhttps://www.govinfo.gov/content/pkg/FR-1988-06-01/pdf/FR-1988-06-01.pdfWhole-issue retrieval failed for size. A discovery reference to a California exemption was not promoted into a read/current exemption conclusion. C055’s mechanism is established; particular determinations remain a gap.
F10 — Treasury HTML alternativehttps://www.govinfo.gov/content/pkg/FR-2017-10-11/html/2017-21904.htmInaccessible; official PDF in S022 was read. Its printed 2018 effective date was retained as printed, not silently replaced with publication year. A screenshot response did not yield verified pixels; PDF text is not called visual inspection.
F11 — CFPB index follow-throughStarting page: https://www.consumerfinance.gov/compliance/guidance/One attempted link-follow operation could not resolve its target. The actual index body, withdrawal register, and full joint guidance at the Federal Reserve were read separately.
F12 — Irrelevant later-notice discoveryhttps://downloads.regulations.gov/FTC-2026-0728-0001/content.pdfA generic current-rule search surfaced this June 2026 notice; download returned 403. Discovery identified a Privacy Act notice, not a credit-practices rule. It supplies no substantive support here; no underlying personal records were accessed.
F13 — Proposal page versus legal statusAll three complete URLs in S026.The old landing page still describes a proposal. The actual May 2025 withdrawal and August 2026 agency statement control the reported status; an old page heading was not treated as a new rule.
F14 — Retrieval truncation and repeat readsSome batched public-web outputs were truncated.Necessary bodies were reopened in bounded portions. Unseen truncated material was not counted as read. Reopening the same document is not independent corroboration.
F15 — Judicial read limitsComplete published opinion/disposition URLs in S027–S028.Majority body and Supreme Court disposition read. No case-record/docket-status query, comprehensive citator, all-circuit survey, or unseen majority opinion claimed.
F16 — Side-source not used to establish a counterpart regimehttps://www.ecfr.gov/current/title-12/chapter-II/subchapter-A/part-202/section-202.1Scope text was consulted, but a complete current part-202 signature/counterpart analysis was not performed. The §1029 boundary remains expressly partial rather than being filled from assumption.
Source links captured in this table

Captured table 11

Assigned question · Principal sources · Claims / deliverables · 6 data rows

Assigned questionPrincipal sourcesClaims / deliverables
1. Necessary ECOA/Regulation B coverage, applicant/guarantor definition, standing and currentness limitsS001–S007, S012, S014, S027–S028C001–C015, C037, C065; corresponding coverage rows and judicial read limits
2. Every additional-signature/spouse branch, joint intent, collateral, business, renewal/changeS003, S006, S008–S013C016–C038; H01–H05, H09–H13, H15; W04–W18, W25–W26
3. FTC exact coverage, cosigner definition, full notice, timing, format, copies/records, remedies limitsS015–S018C039–C057; complete notice-content rows C048–C051; H06–H07, H14; W19–W24
4. Bank/CU/thrift changes, repeals, current guidance status, statutory authorityS018–S026C040, C058–C064; institution table; H08; F04, F07, F10, F13
5. Blank generic document/signature/liability auditS006, S008, S010, S013, S015–S017, S027–S028W01–W28; C006, C038, C051–C057, C065–C066
6. At least eight hypothetical qualitative failure branchesUnderlying claim sources aboveH01–H08 satisfy the specified branches; H09–H15 add renewal, valuation, income, incidental credit, program, forbearance, and account-access branches

Captured table 12

Check · Result · 10 data rows

CheckResult
Actual current-date public browsingPerformed on October 27, 2026, America/Los_Angeles; source/version cutoffs separately recorded.
Complete relevant operative bodiesComplete §1002.7(d) and its official comments; necessary adjacent clauses/comments; complete part 444 including notice and exemption conditions read.
Exceptions preservedSecurities, incidental, government, utility, property, income, business-role, special-program, institutional, and exemption mechanisms identified.
Regulatory definition versus statutory remedyKept separate; no uniform guarantor standing or private-remedy conclusion inferred.
Notice versus agreementExplicitly separated; no receipt-as-guaranty or missing-notice-as-release inference.
Current guidance statusCFPB registers and publisher pages checked; FDIC retrieval gap remains visible. Withdrawn ECOA advisories not used as operative support.
Judicial evidenceComplete relevant majority body and Supreme Court disposition read; posture, disposition, pinpoint, and later-history limits recorded.
Visible deliverablesSource, claim, institution, worksheet, hypothetical, coverage, failure-log, crosswalk, and self-check tables appear in this answer.
Actual-data and owner limitsNo actual liability/eligibility decision, institution roster, borrower/property/account lookup, record request, filing, contact, form completion, publication, local coordinator file, or subagent work.
Independent review / acceptanceNone claimed. This is the same researcher’s self-check, not independent legal review, operational acceptance, or parent completion.

Captured table 13

Parent dimension · Specific matters still held · 8 data rows

Parent dimensionSpecific matters still held
Actual formation and attributionContract formation; assent; authority and agency; signature authenticity; identity; fraud; ratification; assumption; release; novation. The narrow renewal-release comment does not complete general release law.
Guaranty and suretyship lawFull guaranty construction; suretyship defenses; modification effects; waiver validity; contribution; reimbursement; subrogation.
Marital and other personal-status lawFull marital/community-property regimes; family/necessaries obligations; succession and estates; minors and incapacity; state, local, tribal, and foreign law.
Security and remedies against propertyAttachment, perfection, priority, lien enforceability, foreclosure and other secured remedies, recourse/nonrecourse consequences, and property-specific exemptions.
Product-specific obligationsStudent, medical, housing, utility, tax, public, employment, business, and foreign obligations; product-specific notice, copy, cancellation, and release requirements.
Lifecycle, procedure, and remediesInsolvency/discharge; limitations; evidence and burdens; claimant status and standing in the relevant forum; court procedures; enforcement and remedies; the remaining debt lifecycle.
Programs, settlement, and operationsActual program eligibility; settlement suitability; tools and other A003 dimensions; operations and publication decisions.
Unfinished bounded authority checksSpecific current FTC exemption determinations; FDIC publisher status; full excluded-dealer counterpart treatment; complete current forum-specific guarantor authority; and any transaction-date-specific legislative or judicial history needed for a later defined question.

Find the assertion and its boundaries

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

R003-P1-C001 Saved research record

ECOA prohibits a creditor from discriminating against an applicant concerning any aspect of a credit transaction on the enumerated bases, including sex and marital status.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Text
Limits and exceptions
This is a credit-discrimination prohibition, not a federal determination that every spouse owes, or that every debt arrangement is covered credit.
Source / exact pinpoint
S001, §1691(a). uscode.house.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C002 Saved research record

ECOA credit concerns a right to defer payment, incur debt and defer payment, or acquire property/services and defer payment. Regulation B generally reaches personal and commercial credit; its basic credit definition does not require a finance charge or a particular installment count.

Recorded check status: selected definition clauses checked other premises held

Area / type
A003 / Text + Comment
Limits and exceptions
The specific §1002.3 exceptions still matter. This does not rerun TILA or FDCPA coverage.
Source / exact pinpoint
S002, §1691a(d), (f); S005, comment 1(a)-1; S006, §2(g), (h), (j), comment 2(j)-1. uscode.house.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "selected_definition_clauses_checked_other_premises_held", "scope": "Selectedstatutory/regulatorydefinitionssupporttheboundedwording; elsewherecitedscope/motor-dealer/judicial/actualexpresspromiseconditionsremainunaccepted.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C003 Saved research record

Statutory creditor includes regular extenders, renewers, continuers, arrangers, and participating assignees. Regulation B’s operative definition includes regular participation in credit decisions, including setting terms, and participating assignees/transferees/subrogees.

Recorded check status: selected definition clauses checked other premises held

Area / type
A003 / Text + Comment
Limits and exceptions
The additional referral-only definition expressly applies to §4(a)–(b); it cannot automatically be carried into §7(d). The definition also limits responsibility for another creditor’s violation where there was no prior knowledge or reasonable notice, and excludes merely honoring a credit card.
Source / exact pinpoint
S002, §1691a(e); S006, §2(l), comments 2(l)-1–2. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "selected_definition_clauses_checked_other_premises_held", "scope": "Selectedstatutory/regulatorydefinitionssupporttheboundedwording; elsewherecitedscope/motor-dealer/judicial/actualexpresspromiseconditionsremainunaccepted.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C004 Saved research record

A Regulation B application can be oral or written under the creditor’s actual procedures. Actual practice matters, not only the creditor’s written application policy.

Recorded check status: selected definition clauses checked other premises held

Area / type
A003 / Text + Comment
Limits and exceptions
Ordinary use within an existing credit limit is excluded from this application definition. This claim does not decide every inquiry/prequalification or adverse-action issue.
Source / exact pinpoint
S006, §2(f), comments 2(f)-1–2. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "selected_definition_clauses_checked_other_premises_held", "scope": "Selectedstatutory/regulatorydefinitionssupporttheboundedwording; elsewherecitedscope/motor-dealer/judicial/actualexpresspromiseconditionsremainunaccepted.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C005 Saved research record

Statutory applicant under §1691a(b) and regulatory applicant under §1002.2(e) are not identically worded. The regulation expressly includes guarantors, sureties, endorsers, and similar parties for §1002.7(d).

Recorded check status: selected definition clauses checked other premises held

Area / type
A003 / Text
Limits and exceptions
That express regulatory inclusion does not itself settle statutory claimant status, standing, available defenses, or a private remedy in every court.
Source / exact pinpoint
S002, §1691a(b); S006, §2(e); S027–S028. uscode.house.gov +2

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "selected_definition_clauses_checked_other_premises_held", "scope": "Selectedstatutory/regulatorydefinitionssupporttheboundedwording; elsewherecitedscope/motor-dealer/judicial/actualexpresspromiseconditionsremainunaccepted.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C006 Saved research record

Regulation B defines contractual liability by an express agreement to repay all debts arising on an account.

Recorded check status: selected definition clauses checked other premises held

Area / type
A003 / Text + Synthesis
Limits and exceptions
The definition does not authenticate a signature, establish authority, resolve formation, or transform an account label, access permission, or credit-report entry into that agreement.
Source / exact pinpoint
S006, §2(i); S008, comment 7(a)-1. Consumer Financial Protection Bureau +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "selected_definition_clauses_checked_other_premises_held", "scope": "Selectedstatutory/regulatorydefinitionssupporttheboundedwording; elsewherecitedscope/motor-dealer/judicial/actualexpresspromiseconditionsremainunaccepted.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C007 Saved research record

Extensions of credit include refinancing, renewals, consolidation, additional credit, and certain continuations at or after maturity. Credit transaction includes dealings concerning existing credit as well as applications.

Recorded check status: selected definition clauses checked other premises held

Area / type
A003 / Text
Limits and exceptions
This broad lifecycle coverage does not make every modification a new guaranty or automatically trigger release; the particular renewal comment has its own conditions. Regulation B’s open-end definition also excludes negotiated advances under an open-end real-estate mortgage or letter of credit.
Source / exact pinpoint
S006, §2(m), (q), (w), comment 2(w)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "selected_definition_clauses_checked_other_premises_held", "scope": "Selectedstatutory/regulatorydefinitionssupporttheboundedwording; elsewherecitedscope/motor-dealer/judicial/actualexpresspromiseconditionsremainunaccepted.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C008 Saved research record

Part 1002 generally applies to U.S. lending, including Puerto Rico and U.S. territories, and excludes persons covered by the specified §1029 motor-vehicle-dealer exclusion.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Text + Comment
Limits and exceptions
That is an exclusion from this part, not from ECOA itself. Section 5519 contains activity-based carvebacks. Exact counterpart-Regulation-B treatment for such an actor is not completed here.
Source / exact pinpoint
S005, §1(a), comments 1(a)-1–2; S014, §5519(a)–(d). Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C009 Saved research record

Section 7(d) does not apply to securities credit as defined in §3(b)(1): credit regulated under Securities Exchange Act §7, or credit by a broker/dealer regulated as such under that Act.

Recorded check status: complete exception body checked application held

Area / type
A003 / Text
Limits and exceptions
This is the specified signature-rule exception, not permission for every discriminatory practice and not a ruling on an actual securities obligation.
Source / exact pinpoint
S007, §3(b)(1), (b)(2)(vi). Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_exception_body_checked_application_held", "scope": "Alloperative3andcommentsread; exceptionsconditions/conjunctivequalifiersandremaininggenerallawrestrictionspreserved.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C010 Saved research record

Section 7(d) does not apply to defined incidental consumer credit: other than utility/securities credit, not under a credit-card account, not subject to a finance charge as defined in §1026.4, and not payable by agreement in more than four installments.

Recorded check status: complete exception body checked application held

Area / type
A003 / Text + Comment
Limits and exceptions
All stated definitional conditions matter. “Four” is an installment-count condition in §3(c)(1)(iii), not an invented qualification or payment schedule. A deferral can still be ECOA credit even though this exception applies.
Source / exact pinpoint
S007, §3(c)(1), (c)(2)(v), comment 3(c)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_exception_body_checked_application_held", "scope": "Alloperative3andcommentsread; exceptionsconditions/conjunctivequalifiersandremaininggenerallawrestrictionspreserved.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C011 Saved research record

Credit to governments, subdivisions, agencies, or instrumentalities is exempt from the part’s requirements except §4(a)’s general nondiscrimination rule.

Recorded check status: complete exception body checked application held

Area / type
A003 / Text + Comment
Limits and exceptions
Credit by a government agency to consumers is not within that exception merely because the creditor is governmental.
Source / exact pinpoint
S007, §3(d), comment 3(d)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_exception_body_checked_application_held", "scope": "Alloperative3andcommentsread; exceptionsconditions/conjunctivequalifiersandremaininggenerallawrestrictionspreserved.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C012 Saved research record

The defined public-utility-credit exception does not remove §7(d). Its listed exceptions concern specified marital-information and retention provisions.

Recorded check status: complete exception body checked application held

Area / type
A003 / Text + Comment
Limits and exceptions
The definition requires the specified service/facility and government-filed or regulated charges. Financing unrelated goods or improvements is not utility-service credit merely because a utility provides it.
Source / exact pinpoint
S007, §3(a), comments 3(a)-1–3. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_exception_body_checked_application_held", "scope": "Alloperative3andcommentsread; exceptionsconditions/conjunctivequalifiersandremaininggenerallawrestrictionspreserved.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C013 Saved research record

ECOA permits consideration/application of state property laws and recognizes signatures serving lien, title, inchoate-right, or earnings purposes, subject to the statutory prohibition on discriminatory creditworthiness evaluation. Regulation B preserves state property and estate laws and preempts inconsistent credit-discrimination law only to the stated extent.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Text
Limits and exceptions
This is not a uniform federal marital-property or recourse code. Married and unmarried applicants remain subject to equal evaluation standards except as law permits.
Source / exact pinpoint
S003, §1691d(a), (b), (f); S009, §6(b)(8), (c); S010, §11(a), (d). uscode.house.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C014 Saved research record

Section 1691d(c) addresses a particular case: state law prohibits separate consumer credit, each spouse voluntarily applies separately to the same creditor, and that state prohibition is preempted; its sole-responsibility proviso applies in that specified setting.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Text
Limits and exceptions
It must not be converted into a blanket statement that every separately named marital debt is solely one spouse’s debt under all state law.
Source / exact pinpoint
S003, §1691d(c). uscode.house.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C015 Saved research record

The Hawkins Eighth Circuit majority held that executing a guaranty alone did not make the claimants statutory applicants; it rejected their reliance on the predecessor regulatory definition. It affirmed summary judgment on the ECOA claim/defense; state-law counterclaims had been dismissed without prejudice. The Supreme Court affirmed by equal division.

Recorded check status: material majority checked later disposition and current forum held

Area / type
A003 / Opinion + Unknown
Limits and exceptions
The Supreme Court supplied no reasoned nationwide merits resolution. The appellate opinion used the then-operative Chevron framework; no claim is made that this is today’s general review framework. Current forum-specific treatment, statutory entitlement, Article III issues, and remedy remain unverified.
Source / exact pinpoint
S027, slip pp.3–8 / indexes 2–7; S028, p.495 / index 0. govinfo.gov +2

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "material_majority_checked_later_disposition_and_current_forum_held", "scope": "Hawkinsmajority/footnotesread; originalSCequaldivisionattributionunreopenedafterfreshfailure; noallcircuits/currentframework/citator/statutoryentitlement/remedyfinding.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C016 Saved research record

For individual credit, a creditor generally must first determine that the applicant does not independently qualify before requiring another signer. If the applicant qualifies for the requested amount and terms, the creditor cannot require a spouse’s or another non-joint applicant’s signature on a credit instrument, subject to the paragraph’s exceptions.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Text + Comment
Limits / what remains unproved
A neutral policy requiring everyone to obtain a cosigner does not defeat this protection. The business-role guaranty exception below is material. No actual qualification is assessed here.
Source / exact pinpoint
S008, §7(d)(1), comments 7(d)-1–2 and 7(d)(1)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C017 Saved research record

A joint applicant applies contemporaneously for shared or joint credit. Someone added because the creditor demands another signature as a condition of approval is not thereby a joint applicant.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
The joint-applicant exception permits obtaining the genuine applicant’s signature; it does not itself establish the scope or enforceability of a later contractual promise.
Source / exact pinpoint
S008, comment 7(d)(1)-2. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C018 Saved research record

Joint intent must be evidenced at application. Application signatures or initials affirming joint-credit intent may establish it, separately from accuracy certification. A promissory-note signature may not serve as the required proof of application-stage joint intent.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Text + Comment
Limits / what remains unproved
A joint financial statement, joint-asset evidence, marriage, or shared household must not silently become a joint application. A financial-statement signature certifying accuracy is insufficient.
Source / exact pinpoint
S008, §7(d)(1), comment 7(d)(1)-3. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C019 Saved research record

For unsecured credit supported by jointly owned property, the creditor must value the applicant’s own interest. It may not condition the extension on the nonapplicant owner’s signature if that interest supports the requested amount and terms.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
Joint title alone does not demonstrate a need for another signature. Actual ownership form, valuation, legal access, and the requested terms remain necessary facts.
Source / exact pinpoint
S008, comment 7(d)(2)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C020 Saved research record

Valuation may consider the existing ownership form, attachability, execution, severance or partition, resulting value, and associated costs.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
The creditor cannot premise the demand on speculative later changes such as divorce or a future transfer into a different tenancy.
Source / exact pinpoint
S008, comment 7(d)(2)-1(i). Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C021 Saved research record

If the applicant relies on joint property for unsecured credit and the interest is insufficient, the creditor may pursue the stated alternatives: an appropriate additional party, secured credit, or instruments necessary/reasonably believed necessary under the property-situs state’s law to reach the relied-on property upon death or default.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Text + Comment
Limits / what remains unproved
Property-access instruments should not impose personal liability unless state law makes that necessary. The commentary rejects routine demands for an instrument, such as a quitclaim deed, that forfeits the other owner’s interest.
Source / exact pinpoint
S008, §7(d)(2), comment 7(d)(2)-1(ii). Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C022 Saved research record

The official commentary says a creditor’s reasonable belief about necessary instruments should be supported by a thorough review of pertinent statutory and decisional law or a state attorney-general opinion.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
This is not permission based solely on a creditor’s preference. It does not prescribe a particular retained memorandum or decide whether an actual legal analysis was reasonable.
Source / exact pinpoint
S008, comments 7(d)(2)-2 and 7(d)(4)-2. Consumer Financial Protection Bureau +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C023 Saved research record

The unsecured community-property branch requires a married applicant who resides in a community-property state or relies on property there; a necessary/reasonably necessary state-law instrument; both inadequate management/control of sufficient community property under state law and insufficient separate property to qualify without community property.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Text + Comment
Limits / what remains unproved
Marriage or a community-property-state connection alone is insufficient. The residency comment allows a residence assumption unless the applicant indicates otherwise; it does not supply missing property-control law.
Source / exact pinpoint
S008, §7(d)(3)(i)–(ii), comment 7(d)(3)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C024 Saved research record

For secured credit, a creditor may require spouse/other signatures on instruments necessary or reasonably believed necessary under applicable state law to make the offered security available on default—for example, to create a lien, pass title, waive inchoate rights, or assign earnings.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Text
Limits / what remains unproved
Permission is tied to the legal collateral purpose. It is not a general permission to make every owner a personal guarantor.
Source / exact pinpoint
S008, §7(d)(4); S003, §1691d(a). Consumer Financial Protection Bureau +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C025 Saved research record

If a mortgage or security agreement alone makes the property available, the creditor may not require the spouse to sign the note. If state law actually requires both spouses’ note signatures for an enforceable lien, the commentary permits them.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
The relevant state rule must be identified; an assumption that every mortgage requires personal repayment liability is inadequate.
Source / exact pinpoint
S008, comments 7(d)(4)-1–2. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C026 Saved research record

A combined note/security instrument cannot be required where only a security-interest signature is needed unless the instrument clearly limits the spouse’s signature to granting security and excludes personal liability; a nearby legend is an example.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
The commentary does not mandate one magic phrase. Actual instrument language, capacity, and applicable law still control what was signed.
Source / exact pinpoint
S008, comment 7(d)(4)-3. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C027 Saved research record

When an additional party’s personal liability is necessary under the creditor’s standards to support the requested credit, the creditor may request a cosigner, guarantor, endorser, or similar party.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Text
Limits / what remains unproved
The spouse may serve, but the creditor cannot insist that the spouse be the additional party merely because a supporting obligor is needed.
Source / exact pinpoint
S008, §7(d)(5). Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C028 Saved research record

A creditor may impose eligibility conditions on additional parties, such as residence in its market area.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
Such conditions cannot discriminate on sex, marital status, or another prohibited basis. They cannot be used to disguise an otherwise prohibited spouse-only requirement.
Source / exact pinpoint
S008, comment 7(d)(5)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C029 Saved research record

An individual applicant actually relying on another person’s income may be required to obtain that person’s signature to make the income available. This includes a spouse’s income outside community-property treatment and a spouse’s separate income in a community-property state.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
The commentary separately permits, but does not require, a spouse’s signature where future earnings are not community property until earned—even if the creditor normally requires a nonspouse income-provider’s signature. Actual income reliance and state characterization are essential.
Source / exact pinpoint
S008, comment 7(d)(5)-2; S009, §6(c). Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C030 Saved research record

A creditor may require personal guarantees from business partners, directors, officers, and shareholders of closely held corporations even if the business itself is creditworthy, when based on that business relationship.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
The requirement cannot depend on a prohibited basis—for example, only married officers or only businesses associated with a protected group. This is not a universal exemption for all business-related additional signers.
Source / exact pinpoint
S008, comment 7(d)(6)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C031 Saved research record

Additional parties receive the relevant signature protections. A creditor cannot automatically demand a guarantor’s spouse’s signature.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Text + Comment
Limits / what remains unproved
The commentary allows a further signature in appropriate financial circumstances under §7(d)(2); that incorporates the property-access conditions, not unlimited permission for a spouse’s personal guaranty.
Source / exact pinpoint
S008, §7(d)(6), comment 7(d)(6)-2. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C032 Saved research record

If creditworthiness is reevaluated when an obligation is renewed, the creditor must determine whether an additional party remains warranted and release that party if not warranted.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment
Limits / what remains unproved
This is a conditional federal release duty. It is not automatic expiration at every renewal, nor does business creditworthiness alone eliminate a permissible business-role guaranty. Effect on prior obligations and release mechanics remains a contract/state-law issue.
Source / exact pinpoint
S008, comment 7(d)(5)-3, read with comment 7(d)(6)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C033 Saved research record

For an existing open-end account, specified adverse changes cannot be triggered merely by age, retirement, name, or marital-status change absent evidence of inability/unwillingness to repay. Reapplication based on marital change requires the stated spouse-income reliance and income-insufficiency information; the comment also addresses loss of another supporting person.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Text + Comment
Limits / what remains unproved
During permitted reapplication, existing contractual access continues. Joint-account closure requests or repudiation of responsibility for future charges are separately addressed. No inference of release from existing debt follows merely from closing an account.
Source / exact pinpoint
S008, §7(c)(1)–(2), comments 7(c)(1)-1–2 and 7(c)(2)-1. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C034 Saved research record

A creditor may condition authorized-user designation on that user becoming contractually liable, without prohibited discrimination. For an overdraft line attached to a transaction account, it may require all persons authorized to draw to assume overdraft liability.

Recorded check status: complete signature rule comments checked actual predicates held

Area / type
A003 / Comment + Synthesis
Limits / what remains unproved
Permission to require an agreement is different from proof that an agreement exists. Mere account access or authorized-user status does not prove the express undertaking.
Source / exact pinpoint
S008, comments 7(a)-1–3; S006, §2(i). Consumer Financial Protection Bureau +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_signature_rule_comments_checked_actual_predicates_held", "scope": "Complete7dcommentsandselecteda/creconciled. Generalqualificationrule, contemporaneousjointintent, propertynecessity, two communityconditions, income, choiceofadditionalparty, businessroleandconditionalrenewalreleaseallseparate; noactualinstrument/statequalification/liabilityacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C035 Saved research record

Section 8(d) permits specified marital/support-income/spouse-resource inquiries where financial need is a special-purpose-program criterion. Its separate signature sentence permits obtaining a spouse’s or another person’s signature on a program application or credit instrument if Federal or state law requires it.

Recorded check status: complete current special program body checked application held

Area / type
A003 / Text
Limits / what remains unproved
A program label or creditor preference does not satisfy the signature condition. Section 8(c)’s information permission is not a free-standing authorization to demand any spouse’s guaranty.
Source / exact pinpoint
S011, §8(c)–(d). Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_current_special_program_body_checked_application_held", "scope": "Complete8comments/operativeconditionsread;signaturemustberequiredbylaw, programqualificationand2026conditionsnotassumedactual;laterjudicial/orderhistoryheld.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C036 Saved research record

The special-program branch requires a qualifying §8(a) program: legally authorized assistance for an economically disadvantaged class; qualifying nonprofit assistance; or a qualifying for-profit program meeting the written-plan and need conditions. Current for-profit rules require the plan’s specified class, procedures, evidence, and explanation of otherwise-unavailable credit; additional conditions govern otherwise-prohibited common characteristics.

Recorded check status: complete current special program body checked application held

Area / type
A003 / Text + Comment
Limits / what remains unproved
Current §8(b)(3) bars race, color, national origin, and sex as for-profit-program eligibility characteristics; §8(b)(4) requires participant-specific evidence for other otherwise-prohibited characteristics. Anti-evasion and other Regulation B provisions remain applicable. No actual program is evaluated.
Source / exact pinpoint
S011, §8(a)(1)–(3), (b)(1)–(4), comments 8(a)-1–6 and 8(b)-1–2. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_current_special_program_body_checked_application_held", "scope": "Complete8comments/operativeconditionsread;signaturemustberequiredbylaw, programqualificationand2026conditionsnotassumedactual;laterjudicial/orderhistoryheld.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C037 Saved research record

The 2026 final rule states that special-program credit extended on or after July 21, 2026 must comply with its new requirements; prior extensions must comply with the applicable earlier program rules described in its effective-date discussion.

Recorded check status: selected effective prospective text checked version held

Area / type
A003 / Text + Currentness
Limits / what remains unproved
A preexisting program is not thereby authorized to make all future extensions indefinitely under old rules. This pass does not certify absence of later judicial orders.
Source / exact pinpoint
S012, printed pp.21620, 21658–21659 / indexes 0, 38–39. govinfo.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "selected_effective_prospective_text_checked_version_held", "scope": "StatedeffectiveJuly21,2026andextensionson/afterversusbeforeconfirmed;notwholefinalrule/laterordersoractualprogramdateacceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C038 Saved research record

Appendix B models are optional. Appropriate use/modification yields the specified compliance treatment for §1002.5(b)–(d) inquiries.

Recorded check status: signature intent limit checked optional model premise unreopened

Area / type
A003 / Text + Synthesis
Limits / what remains unproved
That limited effect is not a general contract-formation, guaranty-enforceability, joint-intent, or liability safe harbor.
Source / exact pinpoint
S013, introductory paragraphs 1–3; S008, comment 7(d)(1)-3. Consumer Financial Protection Bureau

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "signature_intent_limit_checked_optional_model_premise_unreopened", "scope": "7dintentlimitationschecked;AppendixBintrooptionalmodels/limitedinquirysafeharborandunseenmodelpixelsremainoriginalattribution,notfreshmodel/body/fieldverification.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C039 Saved research record

Part 444’s creditor is a covered lender or retail installment seller: lending money to consumers, or selling goods/services on deferred-payment or lease-purchase terms, within FTC jurisdiction. Consumer means a natural person seeking/acquiring goods, services, or money for personal, family, or household use. Section 444.3 concerns consumer credit in or affecting commerce.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text
Limits / exceptions
Its broad definition of debt—money due or alleged due—does not erase these actor, purpose, obligation, and commerce conditions. Business credit is not brought within this consumer rule merely by adding a natural-person guarantor.
Source / exact pinpoint
S015, §444.1(a)–(g), §444.3(a). ecfr.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C040 Saved research record

FTC Act §45(a)(2) excludes banks, savings-and-loan institutions, and federal credit unions as statutorily defined, along with other enumerated categories, from the FTC’s stated enforcement jurisdiction.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Text
Limits / exceptions
“Credit union” is not synonymous with “federal credit union.” Nor does “nonbank” alone establish coverage. Section 44’s organizational definition and §57a(f)’s institution definitions matter; no actual status was investigated.
Source / exact pinpoint
S018, §§44, 45(a)(2), 57a(f)(2)–(4); S015, §444.1(a)–(b). uscode.house.gov +2

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C041 Saved research record

Published FTC materials describe the rule as excluding real-estate purchases, while covering qualifying consumer loans secured by already-owned real estate.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Guidance
Limits / exceptions
This is the FTC’s published scope explanation, not an express real-estate-purchase phrase in §444.1. Do not convert it into an exclusion of every real-estate-secured loan or every mortgage-related transaction.
Source / exact pinpoint
S016, “What Transactions Are Covered”; S017, “What Are My Obligations…”. Federal Trade Commission +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C042 Saved research record

A cosigner under §444.1(k) is a natural person who becomes liable for another’s obligation without compensation. The definition expressly includes a signature demanded to extend credit to another or to forbear collection of another’s defaulted obligation.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text
Limits / exceptions
The rule is not confined to new-money originations. The underlying consumer-credit and actor requirements still apply.
Source / exact pinpoint
S015, §444.1(k). ecfr.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C043 Saved research record

Someone receiving no goods, services, or money in return for the credit obligation receives no compensation for this definition; labels do not control. FTC guidance distinguishes a genuine co-buyer sharing purchased goods or co-borrower sharing proceeds from a supporting cosigner.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text + Guidance
Limits / exceptions
A “co-borrower” caption cannot dispose of contrary facts. Conversely, a primary purchaser is not made a covered cosigner merely because another person also signs. Shared household membership alone does not establish the actual benefit or contractual role.
Source / exact pinpoint
S015, §444.1(k); S016, “Notice to Cosigners,” final paragraphs. ecfr.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C044 Saved research record

The rule expressly excludes a spouse whose signature is required to perfect a state-law security interest. FTC guidance also says no notice is needed for a security-agreement signer who has no personal liability.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text + Guidance
Limits / exceptions
A document that also imposes a personal undertaking requires analysis of its actual terms; “property owner” is not a universal cosigner exemption.
Source / exact pinpoint
S015, §444.1(k); S016, “Notice to Cosigners.” ecfr.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C045 Saved research record

Section 444.3(a)(1) prohibits direct or indirect misrepresentation of the nature or extent of cosigner liability to any person. Section 444.3(b) states that compliance with paragraph (c)’s preventive requirements does not violate paragraph (a).

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text
Limits / exceptions
Paragraph (b)’s statement concerns the specified paragraph (a); it is not a universal contractual-enforceability or all-laws immunity provision.
Source / exact pinpoint
S015, §444.3(a)(1), (b). ecfr.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C046 Saved research record

The creditor must inform the cosigner before obligation and give the prescribed disclosure before that event. For open-end credit, the specified event is execution of the agreement creating liability for future charges.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text
Limits / exceptions
Delivery after obligation does not satisfy the express prior-delivery condition. No fixed number of advance days is stated here.
Source / exact pinpoint
S015, §444.3(a)(2), (c). ecfr.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C047 Saved research record

The regulatory disclosure is a separate document containing the prescribed statement, without other statements under the literal rule.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text
Limits / exceptions
Section 444.3 does not specify a numerical font size. Staff explanations concerning permitted administrative additions and packet placement are separately classified below.
Source / exact pinpoint
S015, §444.3(c). ecfr.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C048 Saved research record

Under the heading Notice to Cosigner, the opening paragraph says the recipient is being asked to guarantee the debt, should consider that choice carefully, will have to pay if the borrower does not, and should assess both ability and willingness to accept that responsibility.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text — notice element 1
Limits / exceptions
This is the complete opening warning in paraphrase, not a finding that an enforceable guaranty has already been formed.
Source / exact pinpoint
S015, §444.3(c), heading and first notice paragraph. ecfr.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C049 Saved research record

The second paragraph warns of possible responsibility for up to the entire debt if the borrower fails to pay, and possible late fees or collection costs increasing the amount.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text — notice element 2
Limits / exceptions
It supplies no calculation of an actual balance, permissible charge, or award.
Source / exact pinpoint
S015, §444.3(c), second notice paragraph. ecfr.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C050 Saved research record

The third paragraph warns that the creditor can seek payment from the cosigner without first trying the borrower; can use the same collection methods, including suit or wage garnishment; and that default may enter the cosigner’s credit record.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text — notice element 3
Limits / exceptions
This warning is not an independent grant of collection powers or an override of state collection-sequence protections, contract terms, exemptions, or required judicial procedures.
Source / exact pinpoint
S015, §444.3(c), third notice paragraph; S017, state-law qualification immediately following the notice. ecfr.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C051 Saved research record

The final paragraph states: “This notice is not the contract that makes you liable for the debt.”

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text — notice element 4
Limits / exceptions
Notice receipt, including an acknowledgment, must not be substituted for the actual liability-creating instrument.
Source / exact pinpoint
S015, §444.3(c), final notice paragraph. ecfr.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C052 Saved research record

FTC staff permits letterhead, identifying details, an optional receipt-signature line, consistent state notices, and omission of a statement inaccurate under state law. It forbids distracting additions and permits attachment only when the notice comes first in the packet. Its guidance says revolving-account notice is given once at opening; FTC advice says it should match the agreement’s language.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Guidance
Limits / exceptions
These are published implementation explanations; they do not amend the literal regulation or establish a general notice-expiration/cancellation rule. No identifying details were entered here.
Source / exact pinpoint
S016, “Notice to Cosigners”; S017, language paragraph. Federal Trade Commission +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C053 Saved research record

Part 444 does not itself prescribe a signed acknowledgment, fixed notice-retention period, or periodic notice-expiration interval. An acknowledgment may evidence receipt, but its presence does not establish every delivery condition.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text + Synthesis
Limits / exceptions
Absence of a document from a reviewed set is not automatically proof of nondelivery. Other retention, disclosure-copy, electronic-delivery, or evidentiary laws are not negated by this limited reading.
Source / exact pinpoint
S015, complete §§444.1–.5; S016, optional acknowledgment/file-copy explanation. ecfr.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C054 Saved research record

FTC consumer advice recommends obtaining relevant papers and arranging statements/default alerts.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Guidance
Limits / exceptions
That advice is not a universal affirmative duty under part 444 to deliver every loan paper or later account statement. Product-specific and state-law rights remain outside this finding.
Source / exact pinpoint
S017, “If I Cosign a Loan, What Can I Do To Protect Myself?” Consumer Advice

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C055 Saved research record

Under §444.5, an appropriate state agency must apply, and the FTC must determine that an effective state requirement affords substantially equivalent or greater protection. The federal provision then ceases to operate only to the extent specified and while effective state administration/enforcement continues.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text
Limits / exceptions
Stronger state law alone is not an automatic exemption. Specific currently operative exemption determinations were not verified in this pass.
Source / exact pinpoint
S015, §444.5(a)(1)–(2) and concluding condition. ecfr.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C056 Saved research record

FTC Act §57a(g) separately permits petitions for person/class exemptions and specifies the Commission’s finding and procedural requirements.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Text
Limits / exceptions
Petition or review pendency does not itself stay the rule. No exemption is inferred merely from a request or from a failed source retrieval.
Source / exact pinpoint
S018, §57a(g)(1)–(3). uscode.house.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C057 Saved research record

A missing or late required notice raises a compliance issue under §444.3. The read provisions do not establish automatic debt cancellation, release, a notice-based rescission period, uniform unenforceability, or a private cause of action.

Recorded check status: complete FTC444 operative checked guidance and application held

Area / type
A003 / Text + Synthesis
Limits / exceptions
An actual remedy requires the applicable enforcement/remedies authority, forum, contract, state law, and facts. The FTC booklet dates the rule’s operation to March 1, 1985; that historical trigger is distinct from this report’s access date.
Source / exact pinpoint
S015, §444.3; S016, introduction and effective-date discussion. ecfr.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "complete_FTC444_operative_checked_guidance_and_application_held", "scope": "Wholeoperative444supportsdefinedcosigner/notice/timing/fourparagraphs/limitedabsence/exemptions. Additionalstaffguidance,statecollectionsequence,delivery/contract/remedyfactsremainunreopened/held; noticeitselfnotpromiseorautomaticrelease.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C058 Saved research record

Dodd-Frank repealed the former institution-specific FTC Act rulemaking authority. The Federal Reserve’s final rule formally removed former Regulation AA, 12 C.F.R. part 227, effective March 21, 2016. It explains that the statutory repeal nullified the relevant provisions and that Regulation AA did not transfer to CFPB under the FTC Act.

Recorded check status: Fed final repeal checked statutory actor version held

Area / type
A003 / Text + Final-rule history
Status / jurisdiction / limits
The 2010 enactment date, designated-transfer-date provision, and 2016 formal removal are distinct. The FTC’s own part 444 remained a separate rule.
Source / exact pinpoint
S018, §57a(f)(1), 2010 effective-date note; S020, pp.8133–8134 / indexes 0–1. uscode.house.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "Fed_final_repeal_checked_statutory_actor_version_held", "scope": "Fedformalremovalcomplete;statutory57aenactment/transferdatesoriginalunreopenedandotherstatutes/actualactorheld.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C059 Saved research record

NCUA removed and reserved part 706 effective October 3, 2014. Its final rule expressly retained the distinction between repealed regulations and continuing statutory supervisory/enforcement authority.

Recorded check status: NCUA selected repeal checked other authority held

Area / type
A003 / Final rule
Status / jurisdiction / limits
A federal-credit-union notice obligation cannot simply be asserted today by citing former §706 as a current rule.
Source / exact pinpoint
S021, p.59627 / index 0; removal instruction 3, p.59629 / index 2. govinfo.gov +1

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "NCUA_selected_repeal_checked_other_authority_held", "scope": "Part706removalandcontinuingstatutoryauthorityselectedread;notcurrentuniversalnoticeobligationoractorapplication.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C060 Saved research record

The joint agencies explained that former OTS part 535 was omitted from OCC republication because the relevant authority was unavailable and was effectively repealed July 21, 2011. Treasury later directed removal of obsolete OTS chapter V as non-substantive cleanup.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Guidance + Final-rule history
Status / jurisdiction / limits
The complete 2011 republication was not independently reconstructed. The 2017 Treasury document’s printed effective date is October 11, 2018; no correction was verified. Neither document is treated as creating a new cosigner-notice duty.
Source / exact pinpoint
S023, footnote 9; S022, OCC p.48950 / index 0; Treasury pp.47083–47084 / indexes 0–1. federalreserve.gov +2

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C061 Saved research record

Separate federal statutory prohibitions remain relevant. Section 5531 addresses UDAAP involving covered persons/service providers and consumer financial products/services; §5536 contains operative prohibitions. Section 45 supplies the FTC Act prohibition, with enforcement and actor qualifications.

Recorded check status: agency nonlegalization history checked current statutes held

Area / type
A003 / Text
Status / jurisdiction / limits
Statutory unfairness has specified injury, avoidability, and countervailing-benefit conditions; a regulatory repeal does not establish that every former practice is permissible. These statutes do not themselves reproduce §444.3(c)’s exact notice as a universal institutional obligation.
Source / exact pinpoint
S018, §45(a); S019, §§5531(a)–(d), 5536(a); S020–S021. uscode.house.gov +3

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "agency_nonlegalization_history_checked_current_statutes_held", "scope": "FreshFed/NCUAexplainnoautomaticlegalization;5531/5536unreopenedand45fresh404, noentirestatutorytest/currentactoracceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C062 Saved research record

As checked on D, CFPB’s guidance index still listed the 2014 credit-practices guidance, its withdrawal register did not list that item, and NCUA expressly marked its accompanying letter Active. Fed and OCC publisher pages remained posted without an observed rescission banner.

Recorded check status: selected positive withdrawal entries only publisher absence held

Area / type
A003 / Verified publisher status
Status / jurisdiction / limits
FDIC publisher status remains unresolved: both attempted official pages returned 403. The verified statuses are stated agency by agency; publication of an old document alone was not treated as a complete currentness check.
Source / exact pinpoint
S024–S025; failure F04 below. Consumer Financial Protection Bureau +4

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "selected_positive_withdrawal_entries_only_publisher_absence_held", "scope": "TwoECOAwithdrawalentriesfresh; thisclaimaboutjointguidancepublisherstatus/wholeindexabsenceisoriginalattributionunreopened, especiallyFDIC403held.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C063 Saved research record

The 2014 guidance says repeal is not a determination that former practices are permissible; statutory violations depend on facts and circumstances. Footnote 11 expresses the agencies’ view that continuing to provide a notice before obligation properly discloses cosigner liability.

Recorded check status: repeal statutory context checked guidance body unreopened

Area / type
A003 / Guidance + Synthesis
Status / jurisdiction / limits
This is a supervisory interpretation, not a newly enacted regulation applying the FTC’s exact affirmative notice duty to every exempt institution, and not an independently created private right. Operative assertions must rest on current statutes/rules.
Source / exact pinpoint
S023, guidance body and footnote 11; S019–S021. federalreserve.gov

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "repeal_statutory_context_checked_guidance_body_unreopened", "scope": "Repealcontextcheckedonly;2014jointguidance/footnote11exactwordsandpublisherstatusnotfresh,andnotnewaffirmativeinstitutionnoticeduty/privatecause.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C064 Saved research record

The CFPB’s proposed Regulation AA was withdrawn May 15, 2025. Its August 2026 regulatory-priorities statement again identifies the withdrawal.

Recorded check status: original attribution or unreopened material premise held

Area / type
A003 / Withdrawal / history
Status / jurisdiction / limits
The remaining proposal landing page does not make the proposal final or revive former Federal Reserve Regulation AA. No new universal cosigner-notice obligation is established by these materials.
Source / exact pinpoint
S026, withdrawal p.20569 / index 0; agenda p.52943 / index 151. govinfo.gov +2

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "original_attribution_or_unreopened_material_premise_held", "scope": "No selected fresh body establishes every material cited premise; retain exact original issuer/version/guidance/jurisdiction limits and fresh45 failure where applicable. No contradiction established, no acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C065 Saved research record

ECOA’s civil-liability provisions address an aggrieved applicant and authorize specified court relief; they also include a good-faith-conformity protection. A signature-rule violation is therefore not itself a complete adjudication of contract invalidity or of a particular claimant’s remedy.

Recorded check status: majority claim defense limit checked remedy statute held

Area / type
A003 / Text + Synthesis
Status / jurisdiction / limits
Statutory applicant status, court/claim posture, state defenses, relief, and later authority remain separate. No damages, limitation-period, or litigation-strategy analysis is supplied.
Source / exact pinpoint
S004, §1691e(a), (c), (e); S027–S028. uscode.house.gov +2

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "majority_claim_defense_limit_checked_remedy_statute_held", "scope": "Selectedmajoritysupportsclaim/defensecontroversy;1691eunreopened,SClaterdispositionfreshfailed;noautomaticcontractinvalidity,forumstanding,awardordeadlineconclusion.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}
R003-P1-C066 Saved research record

The audit must distinguish application intent, capacity, express promise, security consent, notice delivery, and governing property law. Evidence of one cannot automatically stand in for all the others.

Recorded check status: bounded cross source evidentiary synthesis checked application held

Area / type
A003 / Synthesis
Status / jurisdiction / limits
Neither household relationship, marriage, credit reporting, account access, nor an official model notice alone proves actual personal liability. This is an evidentiary limit of the researched federal sources, not a ruling that other law can never impose an obligation.
Source / exact pinpoint
S006, §2(i); S008, comments 7(d)(1)-3 and 7(d)(4)-3; S010, §11(d); S015, §444.3(c). Consumer Financial Protection Bureau +4

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "bounded_cross_source_evidentiary_synthesis_checked_application_held", "scope": "Expresspromise/jointintent/propertyconsent/noticeconceptsreconciledonlyatthegenericpublishedscope;missingstatecontract/formation/authority/factsremainsandotherlawnotnegated.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

Sources, pinpoints and access limits

Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.

R003-P1-S001 Saved research record

15 U.S.C. §1691, Scope of prohibition — House OLRC. https://uscode.house.gov/us/usc/119-121/t15/s1691/

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Necessary operative text: §1691(a), (b), and (c), including marital inquiry and special-program provisions; relevant amendment/effective-date notes. Other displayed provisions were not used for a general adverse-action survey.
Version, status, jurisdiction, and check limits
Fresh; D. Compilation through Public Law 119-121, October 9, 2026. Federal statute; no complete post-compilation session-law audit.
Direct source URLs
https://uscode.house.gov/us/usc/119-121/t15/s1691/
https://uscode.house.gov/us/usc/119-121/t15/s1691/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S002 Saved research record

15 U.S.C. §1691a, Definitions; rules of construction — House OLRC. https://uscode.house.gov/us/usc/119-121/t15/s1691a/

Recorded check status: fresh complete operative definition checked

Exact pinpoint and read extent
Complete operative subsections (a)–(g), including statutory applicant, credit, creditor, person, and regulatory-reference provisions; displayed amendment notes.
Version, status, jurisdiction, and check limits
Fresh; D. Compilation through October 9, 2026. Statutory definition must be distinguished from the regulation’s special guarantor inclusion.
Direct source URLs
https://uscode.house.gov/us/usc/119-121/t15/s1691a/
https://uscode.house.gov/us/usc/119-121/t15/s1691a/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_operative_definition_checked", "scope": "Complete1691a(a)–(g)body20–31; compilation cutoff10/9/2026; statutory applicant different from regulatory special guarantor clause.", "selected_evidence_keys": ["statutory1691a_currency_and_complete_operative"], "all_original_limits_retained": true}
R003-P1-S003 Saved research record

15 U.S.C. §1691d, Applicability of other laws — House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1691d/

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Complete operative (a)–(g); particular reliance on lien/property signatures, state property law, narrowly framed separate-credit preemption, and state-law preservation/exemption provisions.
Version, status, jurisdiction, and check limits
Fresh; D. Compilation through Public Law 119-124, October 15, 2026. No all-state property or remedies analysis.
Direct source URLs
https://uscode.house.gov/us/usc/119-124/t15/s1691d/
https://uscode.house.gov/us/usc/119-124/t15/s1691d/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S004 Saved research record

15 U.S.C. §1691e, Civil liability — House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s1691e/

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Operative body retrieved; used principally (a), (c), and (e): aggrieved-applicant liability, court-granted equitable/declaratory relief, and good-faith conformity protection. No deadline or award calculation.
Version, status, jurisdiction, and check limits
Fresh; D. Compilation through October 15, 2026. Does not resolve a particular guarantor’s statutory entitlement, jurisdiction, defenses, or remedy.
Direct source URLs
https://uscode.house.gov/us/usc/119-124/t15/s1691e/
https://uscode.house.gov/us/usc/119-124/t15/s1691e/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S005 Saved research record

12 C.F.R. §1002.1, Authority, scope and purpose — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/1/

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Complete operative section and official comments 1(a)-1 through -3.
Version, status, jurisdiction, and check limits
Fresh; D. Agency labels current. U.S. lending, including Puerto Rico and territories; generally excludes lending outside the U.S. Part-specific motor-vehicle-dealer exclusion is expressly distinguished from ECOA itself.
Direct source URLs
https://www.consumerfinance.gov/rules-policy/regulations/1002/1/
https://www.consumerfinance.gov/rules-policy/regulations/1002/1/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S006 Saved research record

12 C.F.R. §1002.2, Definitions — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/2/

Recorded check status: fresh selected definitions comments checked

Exact pinpoint and read extent
Complete necessary clauses: (e)–(j), (l)–(n), (q), (u), (w), (x), (z), (aa); relevant official comments to (e), (f), (g), (j), (l), (w), and (z).
Version, status, jurisdiction, and check limits
Fresh; D. Agency labels current. No general scoring, adverse-action, TILA, or debt-classification survey inferred from incidental displayed text.
Direct source URLs
https://www.consumerfinance.gov/rules-policy/regulations/1002/2/
https://www.consumerfinance.gov/rules-policy/regulations/1002/2/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_selected_definitions_comments_checked", "scope": "Selectedapplicant/application/contractualcredit/creditor/extension/openend definitions and relevant comments, not every scoring/adverse-action body.", "selected_evidence_keys": ["RegB2_applicant_application", "RegB2_selected_definitions_and_comments"], "all_original_limits_retained": true}
R003-P1-S007 Saved research record

12 C.F.R. §1002.3, Limited exceptions — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/3/

Recorded check status: fresh complete operative exceptions comments checked

Exact pinpoint and read extent
Complete (a)–(d) and associated comments; especially (b)(2)(vi), (c)(2)(v), and (d)(2).
Version, status, jurisdiction, and check limits
Fresh; D. Agency labels current. Essential limits on applying §1002.7(d) to securities, incidental, and government credit.
Direct source URLs
https://www.consumerfinance.gov/rules-policy/regulations/1002/3/
https://www.consumerfinance.gov/rules-policy/regulations/1002/3/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_operative_exceptions_comments_checked", "scope": "Complete3operative/comments41–113. Securities/incidental/government branches limit7d;utilitydoesnotremove7d; conditions all retained.", "selected_evidence_keys": ["RegB3_complete_operative_and_comments"], "all_original_limits_retained": true}
R003-P1-S008 Saved research record

12 C.F.R. §1002.7, Rules concerning extensions of credit — CFPB; eCFR cross-check. https://www.consumerfinance.gov/rules-policy/regulations/1002/7/ ; https://www.ecfr.gov/current/title-12/chapter-X/part-1002/section-1002.7

Recorded check status: fresh complete7d comments and selected a c checked

Exact pinpoint and read extent
Complete §7(d)(1)–(6) and every accompanying official comment; also complete relevant §7(a), §7(c), and comments. The CFPB body is the substantive reading source.
Version, status, jurisdiction, and check limits
Fresh; D. CFPB labels current. Initial eCFR page showed Title 12 currency through October 23, 2026; later canonical retrieval encountered an access challenge. No workaround; see failure log.
Direct source URLs
https://www.consumerfinance.gov/rules-policy/regulations/1002/7/
https://www.ecfr.gov/current/title-12/chapter-X/part-1002/section-1002.7
https://www.consumerfinance.gov/rules-policy/regulations/1002/7/?utm_source=chatgpt.com
https://www.ecfr.gov/current/title-12/chapter-X/part-1002/section-1002.7?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete7d_comments_and_selected_a_c_checked", "scope": "Complete7d85–150allcomments plusa/c; qualifiedsole/jointintent/property/income/additionalparty/renewal/businessrole distinct. OriginaleCFRchallengeunretried.", "selected_evidence_keys": ["RegB7_early_operative_and_comments", "RegB7_tail_comments_and_business_role"], "all_original_limits_retained": true}
R003-P1-S009 Saved research record

12 C.F.R. §1002.6, Evaluation of applications — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/6/

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
§6(b)(8), relevant marital-status commentary, and §6(c), concerning equal standards and state property law.
Version, status, jurisdiction, and check limits
Fresh; D. Agency labels current. Only provisions necessary to signature/property distinctions used.
Direct source URLs
https://www.consumerfinance.gov/rules-policy/regulations/1002/6/
https://www.consumerfinance.gov/rules-policy/regulations/1002/6/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S010 Saved research record

12 C.F.R. §1002.11, Relation to state law — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/11/

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Complete operative section and displayed comments; relied on (a), (b), (d), and (e).
Version, status, jurisdiction, and check limits
Fresh; D. Agency labels current. State property law remains a separate inquiry; no state-by-state preemption determination made.
Direct source URLs
https://www.consumerfinance.gov/rules-policy/regulations/1002/11/
https://www.consumerfinance.gov/rules-policy/regulations/1002/11/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S011 Saved research record

12 C.F.R. §1002.8, Special purpose credit programs — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/8/

Recorded check status: fresh complete current8 operative comments checked

Exact pinpoint and read extent
Complete current operative (a)–(d) and all displayed official comments. Signature sentence in (d); program prerequisites in (a)–(b); information provision in (c).
Version, status, jurisdiction, and check limits
Fresh; D. Agency labels current. Current 2026 program conditions used; no actual program eligibility or compliance finding.
Direct source URLs
https://www.consumerfinance.gov/rules-policy/regulations/1002/8/
https://www.consumerfinance.gov/rules-policy/regulations/1002/8/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_current8_operative_comments_checked", "scope": "Current8(a)–(d)/comments41–97; legallyrequiredsignature and currentprogramconditions; no actualprogram, allhistory orjudicialstatuscertificate.", "selected_evidence_keys": ["RegB8_complete_operative_and_comments"], "all_original_limits_retained": true}
R003-P1-S012 Saved research record

Equal Credit Opportunity Act (Regulation B), final rule — CFPB, 91 FR 21620. https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07804.pdf

Recorded check status: fresh selected final effective prospective portions checked

Exact pinpoint and read extent
Printed p.21620 / index 0, summary and effective date; pp.21658–21659 / indexes 38–39, relevant §8 discussion and effective-date section; pp.21668–21670 / indexes 48–50, relevant amendment instructions and revised §8 commentary.
Version, status, jurisdiction, and check limits
Fresh; D. Final, published April 22, 2026; stated effective July 21, 2026. Not a full 51-page read or judicial-status certification.
Direct source URLs
https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07804.pdf
https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07804.pdf?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_selected_final_effective_prospective_portions_checked", "scope": "SummaryeffectiveJuly21,2026 andselectedon-or-after/preextensiontext; notall51pages/preamble/amendmentinstructions orlaterorders.", "selected_evidence_keys": ["RegB2026_summary_effective_date", "RegB2026_effective_and_prospective_credit"], "all_original_limits_retained": true}
R003-P1-S013 Saved research record

Appendix B, Model Application Forms — CFPB. https://www.consumerfinance.gov/rules-policy/regulations/1002/b/ ; linked Form 1 images: https://files.consumerfinance.gov/f/images/cfpb_regulations_ER21DE11-046.original.png and https://files.consumerfinance.gov/f/images/cfpb_regulations_ER21DE11-047.original.png

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Complete introductory instructions 1–3 read. Image routes returned image markers, but their pixels were not available for verified visual inspection; no image-field transcription relied upon.
Version, status, jurisdiction, and check limits
Fresh; D. Optional official models; limited inquiry-compliance effect under §1002.5(b)–(d). Worksheet below relies on operative clauses and official commentary, not unseen form pixels.
Direct source URLs
https://www.consumerfinance.gov/rules-policy/regulations/1002/b/
https://files.consumerfinance.gov/f/images/cfpb_regulations_ER21DE11-046.original.png
https://files.consumerfinance.gov/f/images/cfpb_regulations_ER21DE11-047.original.png
https://www.consumerfinance.gov/rules-policy/regulations/1002/b/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S014 Saved research record

12 U.S.C. §5519, motor-vehicle-dealer exclusion — House OLRC. https://uscode.house.gov/us/usc/119-124/t12/s5519/

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Relevant (a)–(d), including activity-based exclusion, statutory carvebacks, preserved other-agency authority, and FTC rulemaking provision.
Version, status, jurisdiction, and check limits
Fresh; D. Compilation through October 15, 2026. Exact classification of any dealer and complete counterpart-Regulation-B treatment remain untested.
Direct source URLs
https://uscode.house.gov/us/usc/119-124/t12/s5519/
https://uscode.house.gov/us/usc/119-124/t12/s5519/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S015 Saved research record

16 C.F.R. part 444, Credit Practices — FTC / eCFR. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-444

Recorded check status: fresh complete operative444 checked no pixels

Exact pinpoint and read extent
Entire operative §§444.1–444.5 read, including complete definitions, §444.3(a)–(c), complete prescribed notice, and §444.5 exemption conditions.
Version, status, jurisdiction, and check limits
Fresh; D. eCFR Title 16 currency through October 23, 2026; source note 49 FR 7789, March 1, 1984. FTC-jurisdiction consumer transactions; no complete annual-CFR/session-history audit.
Direct source URLs
https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-444
https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-444?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_operative444_checked_no_pixels", "scope": "Alloperative114–185union; actor/purpose/cosigner/noticeelements/timing/exemptions complete; boundedabsenceofackretentionexpiration onlywithinpart444. Current10/27display distinctfromoriginal10/23.", "selected_evidence_keys": ["FTC444_currency_and_early_operative", "FTC444_complete_notice_and_exemptions"], "all_original_limits_retained": true}
R003-P1-S016 Saved research record

Complying with the Credit Practices Rule — FTC staff business guidance. https://www.ftc.gov/business-guidance/resources/complying-credit-practices-rule

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Complete page read; relied on “Introduction,” “What Transactions Are Covered,” “How Exemptions Are Granted,” and “Notice to Cosigners.”
Version, status, jurisdiction, and check limits
Fresh; D. December 2006 booklet, edited January 2025 for penalty information. Still published; staff guidance, not amended regulatory text. Historical bank-counterpart statements are not used as current coverage proof.
Direct source URLs
https://www.ftc.gov/business-guidance/resources/complying-credit-practices-rule
https://www.ftc.gov/business-guidance/resources/complying-credit-practices-rule?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S017 Saved research record

Cosigning a Loan FAQs — FTC Consumer Advice. https://consumer.ftc.gov/articles/cosigning-loan-faqs

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Complete page read; particularly obligations, state collection sequence, real-estate-purchase notice qualification, language, copies, and release advice.
Version, status, jurisdiction, and check limits
Fresh; D. Dated April 2024; generic advice. Broad introductory statements must be read subject to controlling actor/transaction coverage.
Direct source URLs
https://consumer.ftc.gov/articles/cosigning-loan-faqs
https://consumer.ftc.gov/articles/cosigning-loan-faqs?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S018 Saved research record

FTC Act jurisdiction, definitions, and rulemaking provisions — House OLRC. https://uscode.house.gov/us/usc/119-124/t15/s44/ ; https://uscode.house.gov/us/usc/119-121/t15/s45/ ; https://uscode.house.gov/us/usc/119-124/t15/s57a/

Recorded check status: fresh45 failed404 other statutory bodies unreopened

Exact pinpoint and read extent
Necessary §44 definitions; §45(a)(1)–(2); §57a(f)(1)–(4), (g)(1)–(3), and 2010 amendment/effective-date notes.
Version, status, jurisdiction, and check limits
Fresh; D. §45 compilation through October 9; other two through October 15, 2026. Grouped statutory usage, not three independent confirmations. No actual entity classification.
Direct source URLs
https://uscode.house.gov/us/usc/119-124/t15/s44/
https://uscode.house.gov/us/usc/119-121/t15/s45/
https://uscode.house.gov/us/usc/119-124/t15/s57a/
https://uscode.house.gov/us/usc/119-124/t15/s44/?utm_source=chatgpt.com
https://uscode.house.gov/us/usc/119-121/t15/s45/?utm_source=chatgpt.com
https://uscode.house.gov/us/usc/119-124/t15/s57a/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh45_failed404_other_statutory_bodies_unreopened", "scope": "Exact119-121§45URLfailedonce404;44/57aunreopened, original actor/enforcement/exemptionstatements attributed only. Noalternate route orcurrentactorclassification. ", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S019 Saved research record

12 U.S.C. §§5531 and 5536 — House OLRC. https://uscode.house.gov/us/usc/119-121/t12/s5531/ ; https://uscode.house.gov/us/usc/119-121/t12/s5536/

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Operative §5531(a)–(f) and §5536(a)–(b), including covered-person/service-provider framework, unfairness conditions, and statutory prohibitions.
Version, status, jurisdiction, and check limits
Fresh; D. Compilation through October 9, 2026. Separate statutory UDAP/UDAAP analysis; no institution-specific enforcement finding.
Direct source URLs
https://uscode.house.gov/us/usc/119-121/t12/s5531/
https://uscode.house.gov/us/usc/119-121/t12/s5536/
https://uscode.house.gov/us/usc/119-121/t12/s5531/?utm_source=chatgpt.com
https://uscode.house.gov/us/usc/119-121/t12/s5536/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S020 Saved research record

Unfair or Deceptive Acts or Practices (Regulation AA), final repeal — Federal Reserve, 81 FR 8133–8134. https://www.govinfo.gov/content/pkg/FR-2016-02-18/pdf/2016-03228.pdf

Recorded check status: fresh complete relevant Fed final rule unit checked

Exact pinpoint and read extent
Complete relevant Federal Reserve final-rule body, printed pp.8133–8134 / indexes 0–1; neighboring agency material excluded.
Version, status, jurisdiction, and check limits
Fresh; D. Published February 18, 2016; effective March 21, 2016. Removes former 12 C.F.R. part 227; explains statutory-authority repeal and non-transfer of that rulemaking authority.
Direct source URLs
https://www.govinfo.gov/content/pkg/FR-2016-02-18/pdf/2016-03228.pdf
https://www.govinfo.gov/content/pkg/FR-2016-02-18/pdf/2016-03228.pdf?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_relevant_Fed_final_rule_unit_checked", "scope": "Fedunit0–353readincludingMar21,2016effective/removal; unrelatedFAAexcluded. Historicalstatutorydiscussion notsubstitutecompletecurrent44/45/57a.", "selected_evidence_keys": ["Fed2016_metadata_early", "Fed2016_gap45_60", "Fed2016_complete_relevant_body_and_removal"], "all_original_limits_retained": true}
R003-P1-S021 Saved research record

Unfair or Deceptive Acts or Practices; Technical Amendments — NCUA, final rule. https://www.govinfo.gov/content/pkg/FR-2014-10-03/pdf/2014-22715.pdf

Recorded check status: fresh selected NCUA part706 discussion removal checked

Exact pinpoint and read extent
Complete part-706 discussion at p.59627 / index 0; relevant procedural discussion p.59628 / index 1; operative removal instruction 3 at p.59629 / index 2. Unrelated organizational amendments not treated as fully researched.
Version, status, jurisdiction, and check limits
Fresh; D. Effective October 3, 2014. Part 706 removed and reserved; continuing statutory authority expressly discussed.
Direct source URLs
https://www.govinfo.gov/content/pkg/FR-2014-10-03/pdf/2014-22715.pdf
https://www.govinfo.gov/content/pkg/FR-2014-10-03/pdf/2014-22715.pdf?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_selected_NCUA_part706_discussion_removal_checked", "scope": "Oct3,2014date,part706discussion/continuedstatutoryauthority andoperativeremoval selected; organizationalunrelatedsectionsnotcomplete.", "selected_evidence_keys": ["NCUA2014_effective_and_statutory_discussion", "NCUA2014_part706_and_operative_removal"], "all_original_limits_retained": true}
R003-P1-S022 Saved research record

Thrift-rule history — OCC and Treasury. OCC integration rule: https://www.govinfo.gov/link/fr/76/49047 . Treasury, Removal of Office of Thrift Supervision Regulations: https://www.govinfo.gov/content/pkg/FR-2017-10-11/pdf/2017-21904.pdf

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
OCC: summary/effective-date material at printed p.48950 / index 0 of a 250-page PDF; not the complete republication. Treasury: complete relevant item at pp.47083–47084 / indexes 0–1, including chapter-V removal instruction.
Version, status, jurisdiction, and check limits
Fresh; D. OCC document effective July 21, 2011. Treasury final published October 11, 2017; its printed DATES says October 11, 2018. No correction was verified. Treasury describes non-substantive removal of obsolete/superseded provisions.
Direct source URLs
https://www.govinfo.gov/link/fr/76/49047
https://www.govinfo.gov/content/pkg/FR-2017-10-11/pdf/2017-21904.pdf
https://www.govinfo.gov/link/fr/76/49047?utm_source=chatgpt.com
https://www.govinfo.gov/content/pkg/FR-2017-10-11/pdf/2017-21904.pdf?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S023 Saved research record

Interagency Guidance Regarding Unfair or Deceptive Credit Practices — Federal Reserve, CFPB, FDIC, NCUA, OCC. https://www.federalreserve.gov/frrs/guidance/interagency-guidance-regarding-unfair-or-deceptive-credit-practices.htm

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Complete guidance body and footnotes 1–12; especially footnote 9 on former OTS part 535 and footnote 11 on continued notice use.
Version, status, jurisdiction, and check limits
Fresh; D. Issued August 22, 2014. Guidance status checked separately in S024–S025. Its historical future-tense repeal statements are not current-rule statements.
Direct source URLs
https://www.federalreserve.gov/frrs/guidance/interagency-guidance-regarding-unfair-or-deceptive-credit-practices.htm
https://www.federalreserve.gov/frrs/guidance/interagency-guidance-regarding-unfair-or-deceptive-credit-practices.htm?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S024 Saved research record

Publisher status pages for the same joint guidance. Federal Reserve: https://www.federalreserve.gov/supervisionreg/caletters/caltr1405.htm ; OCC: https://www.occ.gov/news-issuances/bulletins/2014/bulletin-2014-42.html ; NCUA: https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/unfair-or-deceptive-credit-practices

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Relevant publisher-page bodies read. NCUA letter 14-FCU-03 explicitly displays Active; Fed/OCC pages remained published without an observed rescission banner.
Version, status, jurisdiction, and check limits
Fresh; D. These are status checks of one underlying guidance document, not independent legal authorities. FDIC publisher retrieval failed; see log.
Direct source URLs
https://www.federalreserve.gov/supervisionreg/caletters/caltr1405.htm
https://www.occ.gov/news-issuances/bulletins/2014/bulletin-2014-42.html
https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/unfair-or-deceptive-credit-practices
https://www.federalreserve.gov/supervisionreg/caletters/caltr1405.htm?utm_source=chatgpt.com
https://www.occ.gov/news-issuances/bulletins/2014/bulletin-2014-42.html?utm_source=chatgpt.com
https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/unfair-or-deceptive-credit-practices?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S025 Saved research record

Guidance and Withdrawn Guidance registers — CFPB. https://www.consumerfinance.gov/compliance/guidance/ ; https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/

Recorded check status: fresh positive advisory withdrawal dates only

Exact pinpoint and read extent
Current index’s 2014 credit-practices entry; withdrawal-register body checked, including relevant ECOA entries and absence of the joint credit-practices item.
Version, status, jurisdiction, and check limits
Fresh; D. Index last modified June 15, 2026; withdrawal register July 22, 2026. Existing-credit advisory withdrawn May 12, 2025; special-purpose-program advisory withdrawn June 17, 2026. Those withdrawn advisories are not operative support here.
Direct source URLs
https://www.consumerfinance.gov/compliance/guidance/
https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/
https://www.consumerfinance.gov/compliance/guidance/?utm_source=chatgpt.com
https://www.consumerfinance.gov/compliance/guidance/withdrawn-guidance/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_positive_advisory_withdrawal_dates_only", "scope": "Relevanttwoentrydatesfresh;wholewithdrawalregister/mainindex/jointitemabsence/publishercurrentstatusnotfreshlyrechecked.", "selected_evidence_keys": ["CFPB_positive_advisory_withdrawals", "CFPB_withdrawal_register_selected_tail"], "all_original_limits_retained": true}
R003-P1-S026 Saved research record

Proposed Regulation AA status — CFPB. Withdrawal: https://www.govinfo.gov/content/pkg/FR-2025-05-15/pdf/2025-08645.pdf ; older proposal page: https://www.consumerfinance.gov/rules-policy/rules-under-development/prohibited-terms-and-conditions-in-agreements-for-consumer-financial-products-or-services-regulation-aa/ ; 2026 agenda: https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16603.pdf

Recorded check status: original source attribution unreopened with all limits

Exact pinpoint and read extent
Complete withdrawal item, printed p.20569 / index 0; complete older landing-page body; relevant CFPB priorities statement at printed p.52943 / index 151 of 2026 agenda. Not the entire agenda or proposal.
Version, status, jurisdiction, and check limits
Fresh; D. Proposal withdrawn May 15, 2025; August 2026 agency statement again identifies that withdrawal. Old proposal landing page is not proof of a final/current obligation.
Direct source URLs
https://www.govinfo.gov/content/pkg/FR-2025-05-15/pdf/2025-08645.pdf
https://www.consumerfinance.gov/rules-policy/rules-under-development/prohibited-terms-and-conditions-in-agreements-for-consumer-financial-products-or-services-regulation-aa/
https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16603.pdf
https://www.govinfo.gov/content/pkg/FR-2025-05-15/pdf/2025-08645.pdf?utm_source=chatgpt.com
https://www.consumerfinance.gov/rules-policy/rules-under-development/prohibited-terms-and-conditions-in-agreements-for-consumer-financial-products-or-services-regulation-aa/?utm_source=chatgpt.com
https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16603.pdf?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_source_attribution_unreopened_with_all_limits", "scope": "Originalresearcherrecordretained; nofreshissuerbody/version/publisherstatusacceptance. Allstatedscope/currentness/failure/secondary/pixel/applicationlimitsremain.", "selected_evidence_keys": [], "all_original_limits_retained": true}
R003-P1-S027 Saved research record

Hawkins v. Community Bank of Raymore, 761 F.3d 937 — Eighth Circuit published opinion. https://www.govinfo.gov/content/pkg/USCOURTS-ca8-13-03065/pdf/USCOURTS-ca8-13-03065-0.pdf

Recorded check status: fresh complete material majority and footnotes checked

Exact pinpoint and read extent
Complete majority body, slip pp.1–8 / indexes 0–7; especially pp.3–6 and 8. Separate concurrence not relied upon as the holding.
Version, status, jurisdiction, and check limits
Fresh; D. Filed August 5, 2014; Eighth Circuit. Published summary-judgment appellate decision. Later history checked only to S028; no comprehensive later-treatment or current circuit survey.
Direct source URLs
https://www.govinfo.gov/content/pkg/USCOURTS-ca8-13-03065/pdf/USCOURTS-ca8-13-03065-0.pdf
https://www.govinfo.gov/content/pkg/USCOURTS-ca8-13-03065/pdf/USCOURTS-ca8-13-03065-0.pdf?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_material_majority_and_footnotes_checked", "scope": "Majority0–218plus226–227footnote6tailread;concurrenceexcludedasprecedent. HistoricalChevron/currentcitator/allcircuits/ArticleIII/statecounterclaims/actualremedyheld.", "selected_evidence_keys": ["Hawkins_majority_early", "Hawkins_majority_fill50_80", "Hawkins_majority62_104", "Hawkins_majority99_122", "Hawkins_majority117_162", "Hawkins_majority155_180", "Hawkins_majority169_209", "Hawkins_majority_conclusion_and_fn6_tail"], "all_original_limits_retained": true}
R003-P1-S028 Saved research record

Hawkins v. Community Bank of Raymore, 577 U.S. 495 — Supreme Court. https://www.govinfo.gov/content/pkg/USREPORTS-577/pdf/USREPORTS-577-495.pdf

Recorded check status: fresh disposition failed UnexpectedStatusCode original attribution held

Exact pinpoint and read extent
Complete published disposition, printed p.495 / index 0.
Version, status, jurisdiction, and check limits
Fresh; D. March 22, 2016; judgment affirmed by an equally divided Court. No reasoned Supreme Court majority resolving the statutory issue.
Direct source URLs
https://www.govinfo.gov/content/pkg/USREPORTS-577/pdf/USREPORTS-577-495.pdf
https://www.govinfo.gov/content/pkg/USREPORTS-577/pdf/USREPORTS-577-495.pdf?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_disposition_failed_UnexpectedStatusCode_original_attribution_held", "scope": "OneexactliteralSCpublishedPDFfailed; originalequaldivisionstatementpreservedattributed/unreopened; nowidebindingmeritsresolutioninferred.", "selected_evidence_keys": [], "all_original_limits_retained": true}

What was examined—and what is still missing

The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.

coverage-1 Saved research record

Q1 — ECOA statutory actor, applicant, credit, person

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered at necessary statutory scope.
Claim / example links
C001–C006; S001–S002
Exact remaining gap and next bounded permissible investigation
Actual role/request/purpose facts absent. Next: compare a generic document’s stated roles with the cited definitions.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 1, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-2 Saved research record

Q1 — Consumer versus business coverage

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Both may fall under Regulation B; FTC purpose rule is narrower.
Claim / example links
C002, C030, C039; H04
Exact remaining gap and next bounded permissible investigation
Mixed-purpose characterization may need generic terms and applicable published interpretation. No broad classification survey undertaken.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 2, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-3 Saved research record

Q1 — Participating creditor, assignee, referral-only actor

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered as a rule; actual participation unresolved.
Claim / example links
C003
Exact remaining gap and next bounded permissible investigation
Need role and decision-participation facts; do not infer §7(d) coverage from referral language limited to §4(a)–(b).

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 3, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-4 Saved research record

Q1 — Guarantor regulatory inclusion

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Inclusion is express for §7(d).
Claim / example links
C005, C031
Exact remaining gap and next bounded permissible investigation
Does not supply statutory plaintiff/defense status.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 4, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-5 Saved research record

Q1 — Statutory guarantor claim/defense and jurisdiction

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Partial. One complete appellate majority and its Supreme Court disposition read.
Claim / example links
C015, C065; S027–S028
Exact remaining gap and next bounded permissible investigation
Current governing forum’s published authority and precise posture remain missing. Next: bounded published-opinion review after a jurisdictional research scope is defined; no docket/status query.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 5, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-6 Saved research record

Q1 — Securities exception

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Express §7(d) exclusion.
Claim / example links
C009
Exact remaining gap and next bounded permissible investigation
Actual statutory securities-credit classification absent; next published-law analysis only if needed for a generic scenario.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 6, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-7 Saved research record

Q1 — Incidental-credit exception

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Complete conjunctive definition and signature exception identified.
Claim / example links
C010; H12
Exact remaining gap and next bounded permissible investigation
Need transaction terms for each element; no automatic exemption merely from “bill” or “service.”

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 7, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-8 Saved research record

Q1 — Government credit

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. To-government versus by-government distinction made.
Claim / example links
C011
Exact remaining gap and next bounded permissible investigation
Actual recipient class absent.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 8, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-9 Saved research record

Q1 — Utility credit

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Listed exception does not eliminate §7(d).
Claim / example links
C012
Exact remaining gap and next bounded permissible investigation
Need service and rate-regulation facts; no utility entity lookup.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 9, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-10 Saved research record

Q1 — Territory and §1029 dealer boundary

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Partial. Part-1002 boundary and Act preservation established.
Claim / example links
C008; S005, S014
Exact remaining gap and next bounded permissible investigation
Complete counterpart part-202 treatment for an excluded dealer not completed. Next: published counterpart regulation and transfer-rule analysis only.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 10, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-11 Saved research record

Q1 — Currentness/effective/later history

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Partial, expressly bounded. Current agency text and relevant final rules read.
Claim / example links
C037, C058–C064
Exact remaining gap and next bounded permissible investigation
No complete session-law lag audit, official annual-CFR audit, or universe of judicial orders. Next: targeted published amendments/opinions, without case-record searches.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 11, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-12 Saved research record

Q2 — Individually qualified applicant; Q6(a)

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered with exceptions visible.
Claim / example links
C016; H01
Exact remaining gap and next bounded permissible investigation
Actual qualification not assessed; contract consequence/remedy remains separate.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 12, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-13 Saved research record

Q2 — Genuine joint application; Q6(b)

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Contemporaneous intent and separate evidence requirements covered.
Claim / example links
C017–C018; H02
Exact remaining gap and next bounded permissible investigation
Need application-stage evidence, not just a later note or financial statement.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 13, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-14 Saved research record

Q2 — Unsecured joint property: valuation

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Existing-interest valuation and speculative-change prohibition covered.
Claim / example links
C019–C020; H10
Exact remaining gap and next bounded permissible investigation
State attachment/partition rules and value/cost facts missing. Next: state published law for a specified generic ownership form.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 14, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-15 Saved research record

Q2 — Unsecured joint property: instruments/options

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Necessity, death/default access, alternatives, and forfeiture limit covered.
Claim / example links
C021–C022; H10
Exact remaining gap and next bounded permissible investigation
Exact instrument and state-law necessity missing.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 15, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-16 Saved research record

Q2 — Community property; Q6(e)

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered rule; application unresolved. Both required financial/property conditions stated.
Claim / example links
C023; H05
Exact remaining gap and next bounded permissible investigation
State management/control, separate/community characterization, and sufficiency facts missing.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 16, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-17 Saved research record

Q2 — Secured collateral-only signature; Q6(c)

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Security access distinguished from personal promise.
Claim / example links
C024–C025; H03
Exact remaining gap and next bounded permissible investigation
State lien-creation requirements and full instrument missing; perfection/priority/remedies excluded.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 17, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-18 Saved research record

Q2 — Integrated note/security document

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Clear limitation requirement and example of nearby legend covered.
Claim / example links
C026; H03
Exact remaining gap and next bounded permissible investigation
Need the whole document; no unseen signature block or legend treated as inspected.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 18, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-19 Saved research record

Q2 — Additional personal party and spouse choice

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Necessity does not authorize a spouse-only condition.
Claim / example links
C027–C028; H01
Exact remaining gap and next bounded permissible investigation
Actual standards, reason, and eligibility restrictions missing.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 19, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-20 Saved research record

Q2 — Other person’s/spouse’s income

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Separate-income and future-earnings conditions covered.
Claim / example links
C029; H11
Exact remaining gap and next bounded permissible investigation
Actual reliance and state income characterization missing.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 20, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-21 Saved research record

Q2 — Business role and guarantor’s spouse; Q6(d)

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Qualified-business exception and spouse protection both covered.
Claim / example links
C030–C031; H04
Exact remaining gap and next bounded permissible investigation
Role, financial circumstances, guarantee terms, and state law missing.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 21, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-22 Saved research record

Q2 — Renewals, extensions, release

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered at definition and conditional-comment scope.
Claim / example links
C007, C032; H09
Exact remaining gap and next bounded permissible investigation
Reevaluation, continuing justification, and effect on existing obligations missing. General release/novation law excluded.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 22, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-23 Saved research record

Q2 — Existing open-end account changes

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered only as material to signature/reapplication issues.
Claim / example links
C033
Exact remaining gap and next bounded permissible investigation
Supporting-income facts and existing terms missing; no general adverse-action survey.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 23, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-24 Saved research record

Q2/Q5 — Authorized-user and overdraft distinctions

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Permissible required undertaking separated from actual agreement.
Claim / example links
C006, C034; H15
Exact remaining gap and next bounded permissible investigation
Express contractual undertaking and other possible legal bases unproved.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 24, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-25 Saved research record

Q2 — Special-purpose-program exception

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered rule; actual program unresolved. Current prerequisites and law-required signature condition covered.
Claim / example links
C035–C037; H13
Exact remaining gap and next bounded permissible investigation
Specific program law, date/version, and compliant generic materials missing; actual eligibility excluded.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 25, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-26 Saved research record

Q3 — FTC creditor/debt/consumer/commerce coverage

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered at rule-definition level.
Claim / example links
C039–C040
Exact remaining gap and next bounded permissible investigation
Actual institutional and transaction facts absent; statutory cross-reference classification not performed for any entity.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 26, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-27 Saved research record

Q3 — Real-estate-purchase scope

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered as published FTC interpretation, not invented rule wording.
Claim / example links
C041
Exact remaining gap and next bounded permissible investigation
Boundary cases such as mixed-purpose/refinancing structures not comprehensively researched. Next: targeted official published interpretation for a defined generic structure.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 27, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-28 Saved research record

Q3 — Cosigner versus co-borrower; Q6(f)

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Natural-person, another’s obligation, compensation, benefit, and label conditions covered.
Claim / example links
C042–C044; H06
Exact remaining gap and next bounded permissible investigation
Actual benefit allocation and obligation terms missing.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 28, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-29 Saved research record

Q3 — Defaulted obligation/forbearance

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Express definitional branch included.
Claim / example links
C042, C046; H14
Exact remaining gap and next bounded permissible investigation
New undertaking’s formation and prior delivery evidence missing.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 29, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-30 Saved research record

Q3 — Complete required notice content

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. All four paragraphs and heading accounted for.
Claim / example links
C048–C051; S015
Exact remaining gap and next bounded permissible investigation
Paraphrase is not a substitute compliance form; actual notice version not reviewed.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 30, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-31 Saved research record

Q3 — Timing and open-end trigger

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Before obligation; future-charge agreement execution for open-end credit.
Claim / example links
C046; H07
Exact remaining gap and next bounded permissible investigation
Actual chronology unproved. No invented advance-day rule or expiry period.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 31, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-32 Saved research record

Q3 — Format, packet placement, language

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered with authority levels separated. Rule versus staff implementation guidance distinguished.
Claim / example links
C047, C052
Exact remaining gap and next bounded permissible investigation
Complete generic packet, additions, and applicable state-language rules absent. Electronic-delivery law excluded.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 32, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-33 Saved research record

Q3 — Collection sequence and rights

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered as warning and limitation. No universal collection-first priority inferred.
Claim / example links
C050, C052
Exact remaining gap and next bounded permissible investigation
State sequence, contract waivers, judicial procedures, exemptions, and actual remedies remain missing.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 33, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-34 Saved research record

Q3 — Records, copies, acknowledgment

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered within part 444 and the official materials read.
Claim / example links
C051, C053–C054
Exact remaining gap and next bounded permissible investigation
Other retention/copy statutes and actual delivery evidence unreviewed; absence of a file copy is not decisive.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 34, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-35 Saved research record

Q3 — Missing/late notice; Q6(g)

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered at compliance level; remedy unresolved.
Claim / example links
C057; H07
Exact remaining gap and next bounded permissible investigation
Need formation timing, delivery proof, governing remedies law, and forum. No automatic release or private cause inferred.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 35, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-36 Saved research record

Q3 — FTC state/person exemptions

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Partial. Complete mechanisms read; specific current determinations not verified.
Claim / example links
C055–C056
Exact remaining gap and next bounded permissible investigation
A historical California exemption reference surfaced, but operative/current determination was not read. Next: the published FTC determination and any published amendment/revocation, without state-wide liability surveying.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 36, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-37 Saved research record

Q4 — Bank/CU/nonbank distinction; Q6(h)

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered framework; actual coverage unresolved.
Claim / example links
C040, C058–C064; H08
Exact remaining gap and next bounded permissible investigation
Exact statutory actor class absent; no roster used.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 37, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-38 Saved research record

Q4 — Federal Reserve and NCUA repeals

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. Actual final-rule bodies/instructions and dates read.
Claim / example links
C058–C059
Exact remaining gap and next bounded permissible investigation
No actual pre-repeal transaction adjudicated; other laws remain separate.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 38, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-39 Saved research record

Q4 — OTS/OCC history

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Partial historical reconstruction. Joint explanation and actual integration/removal documents consulted.
Claim / example links
C060
Exact remaining gap and next bounded permissible investigation
Full 2011 republication comparison and any correction to the later printed effective date not verified. Next: published correction/republication text only if that historical date matters.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 39, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-40 Saved research record

Q4 — 2014 guidance current status

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Partial across publishers. CFPB/NCUA status verified; Fed/OCC pages checked; FDIC blocked.
Claim / example links
C062–C063
Exact remaining gap and next bounded permissible investigation
FDIC publisher status not established. Next: an accessible official publication or withdrawal notice; no access workaround.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 40, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-41 Saved research record

Q4 — Statutory authority versus new notice duty

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered at bounded level. Repeal, statutes, and guidance separated.
Claim / example links
C061, C063
Exact remaining gap and next bounded permissible investigation
A particular conduct-based UDAAP determination requires its statutory elements and facts; none made.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 41, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-42 Saved research record

Q4 — Proposed replacement

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered for the identified proposal. Actual withdrawal and later agency acknowledgment read.
Claim / example links
C064
Exact remaining gap and next bounded permissible investigation
No assertion that an old proposal page is current law; no exhaustive inventory of every possible product-specific duty.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 42, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-43 Saved research record

Q5 — Blank liability/signature audit

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. W01–W28 provided, with blank findings.
Claim / example links
C038, C066; worksheet
Exact remaining gap and next bounded permissible investigation
Actual formation, authority, signatures, state-law effects, and remedies deliberately unresolved.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 43, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-44 Saved research record

Q6 — All eight required branches and additional failures

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Answered. H01–H08 map directly to (a)–(h); H09–H15 cover additional material branches.
Claim / example links
H01–H15
Exact remaining gap and next bounded permissible investigation
Hypotheses are assumptions for analysis, not records, actual qualification findings, or real liability decisions.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 44, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}
coverage-45 Saved research record

General debt/TILA/FDCPA gateways; comprehensive state/remedy/litigation surveys

Recorded check status: recorded; no individual primary acceptance inferred

Status and reason
Excluded by assignment.
Claim / example links
Parent holds below
Exact remaining gap and next bounded permissible investigation
No prior report assumed to have completed these dimensions.

Recorded coordinator check boundaries

coordinator acceptance
scoped_partial_not_accepted
coordinator review
{"at": "2026-10-29T08:28:15.255539+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "coverage_reconciliation": "[internal evidence reference]", "row": 45, "all_original_missing_evidence_retained": true, "parent_or_publication_acceptance": false}

Corrections, review and scope

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.

Recorded review disposition

reviewed scoped partial with holds

Other components in this research series

Download this complete public research record (JSON)
Record integrity

Original saved Markdown SHA-256: a23dd6ff2643693796cf65d0580d6834d70baf2d75659b28d65797a84ad68c8d. Public formatting, private-reference removal and correction annotations are separate from that immutable original.

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