SettleADebt.com Research Assignment R007: Measuring a Debt Situation
Scope, check date, and bottom line
Assigned area: A007 — Measuring a debt situation: inventory, balance sheet, income, essential expenses, assets, cash flow, debt-to-income ratio, disposable income, affordability, temporary shortfalls, and lasting shortfalls.
Research baseline and actual check date: October 22, 2026, America/Los_Angeles. This is a reusable research reference, not individualized legal, tax, bankruptcy, credit, or financial advice.
Geographic boundary: The core findings below are federal U.S. rules. Washington is used as a verified state example because its debt-adjusting statute expressly connects the debt inventory, payments, fees, and debtor ability to pay. Federal and Washington authorities must not be generalized to other states. Federal collection exemptions are included, but state exemptions can materially change collectibility. Tribal law, all-state exemption rules, state statutes of limitation, state cancellation-of-debt tax conformity, and each state's debt-adjusting/debt-settlement statutes were not completed as fifty-state modules in this A007 investigation and are publication holds where a state-specific statement would be required.
Evidence status: The principal federal regulations, statutes, current U.S. Trustee means-testing materials, Washington statutes, IRS materials, a Supreme Court decision, and a complete 22-page current Chase public cardmember agreement were opened rather than inferred from snippets. Several discovery-only authorities are separately marked and are not used for dispositive claims.
The central research conclusion is that “How much debt does this person have?” and “How much can this person afford?” are not single-number questions. A sound debt measurement requires at least four separate ledgers:
- Liability ledger: what is legally or allegedly owed, to whom, by whom, and under what contract, judgment, or statute.
- Balance-sheet ledger: assets, liabilities, collateral, liens, equity, liquidity, and legally protected property or income.
- Cash-flow ledger: dependable cash coming in, essential cash going out, required debt service, arrears, timing, and volatility.
- Legal/program ledger: consumer versus commercial purpose, secured versus unsecured, disputed versus admitted, collection stage, limitation/judgment status, priority, exemptions, assistance programs, and special program formulas.
That architecture follows directly from the way federal law treats the same household differently for mortgage ability-to-repay, credit-card ability-to-pay, bankruptcy means testing, Chapter 13 disposable income, tax collection, garnishment, federal-benefit protection, mortgage loss mitigation, and cancellation-of-debt taxation. There is no federal universal DTI, “disposable income,” essential-expense, or affordability formula applicable to every debt-resolution decision. 1
| Status-sensitive issue |
Finding as of 2026-10-22 |
| Bankruptcy means-testing data |
Current U.S. Trustee data set applies to cases filed on or after July 15, 2026. DOJ posted the update June 30, but June 30 is not its effective filing trigger. R007-C017. 2 |
| General Qualified Mortgage 43% DTI |
Historical, not a current universal General QM rule. Current 12 C.F.R. §1026.43 requires consideration/verification of DTI or residual income and uses the current QM framework rather than a universal 43% ceiling. R007-C015. 1 |
| Qualified-principal-residence cancellation exclusion |
Expired for ordinary new 2026 discharges, subject to the statutory transition for debt discharged under a qualifying written arrangement entered before January 1, 2026. R007-C031. 3 |
| Proposed/future/stayed/vacated authorities |
No proposed, stayed, or vacated rule is relied upon as current law in a substantive R007 claim. Discovery leads not verified through final authority were excluded. |
| Creditor settlement percentages |
None stated. No creditor-specific settlement percentage was verified and none should be inferred from this report. |
| Universal credit outcome |
None stated. No universal score increase, decrease, deletion, or recovery period is supported here. |
| Creditor policy |
No unpublished creditor policy is inferred. The Chase material below is an actual public agreement, not a representation of Chase's hardship or settlement policy. |
R007-C001 — Measurement must preserve different definitions rather than collapse them. “Gross income,” “current monthly income,” “disposable income,” “assets,” “available funds,” and “affordability” have materially different meanings across federal mortgage underwriting, credit-card underwriting, bankruptcy, IRS collection, and cancellation-of-debt taxation. The proper website model is therefore a multi-measure dashboard, not one proprietary “debt health” score presented as law. 1
R007-C002 — Consumer/commercial purpose must be an explicit field. The FDCPA defines a covered “debt” as an obligation arising from a transaction primarily for personal, family, or household purposes. Business-purpose obligations therefore cannot simply be analyzed under FDCPA rules because the debtor happens to be an individual. 15 U.S.C. §1692a(5) 4
The practical editorial consequence is not that commercial debts “do not count.” They still belong on an economic balance sheet when the person is legally liable, but the applicable consumer-protection framework can differ. An entity obligation, personal guaranty, co-borrowed debt, and purely personal consumer debt should be separate classifications rather than one category called “debt.”
Detailed findings: inventory and legal classification
A usable debt inventory should answer what, who, why, how much, secured by what, at what stage, and supported by which document. The credit report is one evidence source, not the master ledger.
The minimum debt record
For each obligation, the reusable A007 data model should preserve the following fields:
| Field |
What should be captured |
Why it matters |
| Debt ID |
Internal stable identifier |
Prevents duplicates after sales/transfers |
| Purpose |
Personal/family/household; commercial; mixed/unknown |
Determines whether consumer statutes such as FDCPA may apply. R007-C002 |
| Obligor |
Borrower, co-borrower, guarantor, authorized user, entity only, unknown |
Separates economic use from legal liability |
| Original creditor |
Legal name |
Validation and contract chain |
| Current owner/current creditor |
Legal name, if known |
Payment and settlement authority can change |
| Collector/servicer |
Separate from owner |
FDCPA/Regulation F status may turn on who is collecting |
| Account/loan number |
Masked identifier |
Reconciliation |
| Agreement |
Governing contract/version |
Interest, minimum payment, fees, security, remedies |
| Balance date |
Exact “as of” date |
A balance without a date becomes stale immediately |
| Principal |
If separately available |
Distinguishes principal from additions |
| Interest |
Rate, accrued amount, variable-rate index |
Future balance can change |
| Fees/costs |
Late, collection, legal, annual, other contract/statutory charges |
Needed for true payoff |
| Current balance |
Statement/validation amount |
Snapshot only |
| Payoff amount |
If different |
Often the relevant resolution number |
| Required payment |
Current minimum/installment |
DTI and cash-flow input |
| Past due |
Amount and missed-payment count |
Measures cure requirement |
| Status |
Current, delinquent, collection, litigation, judgment, enforcement, settled, discharged, disputed |
Changes urgency and remedies |
| Dispute |
What is disputed and when |
A disputed amount should not silently become an admitted liability |
| Limitation status |
Unknown/within/possibly time-barred/judgment |
Requires state-specific legal review |
| Security |
Secured/unsecured/unknown |
Determines collateral consequences |
| Collateral |
Asset and estimated value |
Needed for equity and enforcement analysis |
| Lien priority |
If known |
Relevant to recoverability and alternatives |
| Legal process |
Summons, judgment, garnishment, foreclosure, repossession notice |
Creates deadlines independent of cash-flow metrics |
| Protected-source flag |
Social Security, VA, other exempt/protected source |
Collectibility may differ from nominal income |
| Program |
Mortgage loss mitigation, tax collection, bankruptcy, etc. |
Each can use a different affordability formula |
| Evidence grade |
Agreement/judgment/statement; official notice; credit report; self-report |
Exposes uncertainty instead of hiding it |
R007-C003 — Regulation F provides a useful federal template for validating a collection account. For covered FDCPA debt collection, 12 C.F.R. §1006.34 generally requires validation information in the initial communication or within five days. The notice identifies the debt collector, current creditor, account information, an itemization date, the amount at that date, itemized interest/fees/payments/credits, and the current amount. The regulation defines a validation period generally ending 30 days after the consumer receives or is assumed to receive the information. 12 C.F.R. §1006.34(a)–(c) 5
This makes a validation notice strong inventory evidence, but its scope matters: Regulation F applies to FDCPA debt collectors, not automatically every original creditor or every commercial obligation.
R007-C004 — A timely written collection dispute has procedural consequences. Under 15 U.S.C. §1692g(b), when a consumer timely disputes a covered debt in writing, the debt collector must cease collection of the disputed debt or portion until the required verification is obtained and mailed; a timely request for the original creditor's name/address receives related protection. 15 U.S.C. §1692g 6
Therefore a measurement tool should not simply ask “balance?” It should ask “Is the liability, ownership, amount, or legal status disputed?” and preserve the dispute date and document.
R007-C005 — Time-barred status is separate from balance. Regulation F defines time-barred debt as debt for which the applicable statute of limitations has expired and prohibits a covered debt collector from bringing or threatening a legal action to collect it, except that the rule does not apply to proofs of claim in bankruptcy. 12 C.F.R. §1006.26 7
This does not supply a nationwide limitation period. Which statute applies, accrual, tolling, choice of law, judgment duration, and possible consequences of later conduct are state- and fact-specific. Accordingly, an old debt should be marked “limitation status requires jurisdiction-specific determination,” not simply deleted from the inventory or treated as legally collectible.
R007-C006 — Credit reports are an important discovery source, not proof that the inventory is complete. Federal law establishes at least one free annual file disclosure from each nationwide consumer reporting agency, while CFPB's current consumer guidance reports that free online reports from the nationwide agencies are presently available weekly. 15 U.S.C. §1681j and CFPB credit-report guidance 8
A credit report should be reconciled against statements, contracts, court dockets/orders supplied by the consumer, collection notices, and payoff information. It should not be treated as a legal admission, complete creditor list, or live payoff ledger.
R007-C007 — Credit-report disputes have a separate federal process. Under 15 U.S.C. §1681i(a), a consumer reporting agency generally must conduct a reasonable reinvestigation within 30 days after receiving a dispute, subject to the statutory rules governing additional information and extensions; unresolved disputes can generate a consumer statement. 15 U.S.C. §1681i 9
The collection-validation process and FCRA credit-report-dispute process should therefore be represented as different workflows.
Balance sheet, liability, security, priority, and collectibility
R007-C008 — Official bankruptcy schedules illustrate the minimum structural separation a serious debt inventory needs. The federal individual-debtor forms separately identify property on Schedule A/B, exemptions on Schedule C, secured claims on Schedule D, unsecured claims on Schedule E/F, executory contracts/leases on Schedule G, codebtors on Schedule H, income on Schedule I, and expenses on Schedule J. U.S. Courts bankruptcy forms 10
A debt-resolution inventory does not need to copy bankruptcy forms, but it should preserve these distinctions because balance, personal liability, security, priority, and household cash flow answer different questions.
A basic economic balance sheet is:
[
\text{Economic net worth}
= \sum \text{asset values at stated valuation basis}
- \sum \text{liabilities}
]
But that number should never be displayed without a valuation date and valuation basis. Cash value, fair market value, quick-sale value, collateral value for a particular proceeding, and tax basis are not interchangeable.
R007-C009 — Security and personal liability must remain separate. Regulation F itself recognizes that personal liability can be discharged in bankruptcy while an enforceable lien survives; §1006.30(b)(2)(ii) permits transfer of such a secured debt if the transferee is told that personal liability was discharged. 12 C.F.R. §1006.30(b) 11
For A007, that means a secured-debt row needs at least four distinct values: personal liability, lien balance, collateral value, and collateral equity. “Debt forgiven” and “lien gone” must not be treated as synonyms.
R007-C010 — Collectibility is not the same thing as liability. Some income/property may be legally protected from ordinary creditor process even though a valid debt remains outstanding. Social Security benefits receive substantial protection under 42 U.S.C. §407; VA benefits have protection under 38 U.S.C. §5301; and Treasury's 31 C.F.R. Part 212 establishes bank-account procedures for certain directly deposited federal benefits. 42 U.S.C. §407, 38 U.S.C. §5301, 31 C.F.R. Part 212 12
Treasury defines the automatically protected amount, in relevant covered accounts, by reference to benefit payments in a two-month lookback and the account balance. That does not resolve every exemption dispute or exception, but it demonstrates why “monthly income” and “amount an ordinary creditor can garnish” are different measurements. 13
R007-C011 — Federal wage-garnishment law provides another collectibility measure, not an affordability recommendation. For ordinary garnishment subject to 15 U.S.C. §1673(a), the maximum is generally the lesser of 25% of disposable earnings or the amount by which disposable earnings exceed 30 times the applicable federal minimum hourly wage. Separate rules apply to support, bankruptcy orders, and tax debts. 15 U.S.C. §1673 14
That ceiling should never be converted into a statement that the household “can afford” to pay that percentage. It is an enforcement limit. State law may require an additional, jurisdiction-specific exemption analysis.
Debt lifecycle
A practical A007 lifecycle model is:
| Stage |
Measurement emphasis |
Key failure if ignored |
| Current |
Balance, APR, required payment, payoff, secured status |
Understates future interest/minimums |
| Delinquent |
Arrears, cure amount, late fees, days delinquent |
Treats regular payment as sufficient to cure |
| Transferred/collection |
Current owner, collector, validation amount, dispute |
Pays wrong party or double counts accounts |
| Possibly time-barred |
Last relevant dates, applicable jurisdiction, legal status |
Assumes balance equals enforceability |
| Litigation |
Complaint amount, defenses/dispute, response date |
Cash-flow analysis misses court deadline |
| Judgment |
Judgment principal, interest, costs, enforcement status |
Uses pre-judgment balance |
| Garnishment/levy |
Exemption, protected source, withholding amount |
Treats nominal income as freely available |
| Secured enforcement |
Collateral, equity, cure, foreclosure/repo stage |
Funds unsecured debt while losing essential collateral |
| Settlement |
Written settlement terms, due dates, fees, tax implications |
Confuses offer amount with total resolution cost |
| Bankruptcy/discharge |
Secured lien, discharge status, priority/program treatment |
Assumes personal discharge extinguishes all interests |
| Post-resolution |
Proof of payment, release/zero balance, tax forms, credit-report reconciliation |
Cannot prove performance or correct errors |
R007-C012 — A “current balance” therefore is not enough to measure the debt situation. Regulation F expressly contemplates changes between an itemization date and current amount through interest, fees, payments, and credits, and an actual creditor contract can create additional mechanics such as variable APRs, minimum-payment formulas and payment allocation. 5
Detailed findings: income, expenses, assets, cash flow, DTI, disposable income, and affordability
Income is not one field
For A007, income should be stored in at least these parallel forms:
| Income measure |
Recommended meaning |
Typical use |
| Gross recurring income |
Before tax/payroll deductions |
DTI and underwriting comparisons |
| Net cash income |
Cash actually available after payroll withholding/deductions |
Household cash flow |
| Variable/irregular income |
Commissions, bonuses, overtime, gig/business income |
Volatility analysis |
| Program-defined income |
Income under the specific statutory/program definition |
Bankruptcy, benefits, underwriting |
| Protected-source income |
Social Security, VA or other specially protected funds |
Collectibility/exemption analysis |
| One-time income |
Bonus, buyout, asset sale, gift, tax refund |
Must not automatically be annualized |
| Expected future income |
Supported known change, not mere optimism |
Temporary-versus-lasting analysis |
R007-C013 — Mortgage ability-to-repay is a multidimensional analysis. For a covered mortgage transaction, 12 C.F.R. §1026.43(c)(2) requires a reasonable, good-faith ability-to-repay determination considering, at minimum, current or reasonably expected income/assets other than the dwelling securing the loan, employment status when relied upon, the covered-transaction payment, simultaneous loans, mortgage-related obligations, current debt obligations/alimony/child support, monthly DTI or residual income, and credit history. The creditor generally must verify relied-upon income/assets using reasonably reliable third-party records. 12 C.F.R. §1026.43(c) 1
This authority is important editorially because it defeats the idea that affordability is “income minus minimum card payments.”
R007-C014 — The federal mortgage DTI formula is explicit. Under §1026.43(c)(7)(ii), monthly DTI is total monthly debt obligations divided by total monthly income. The debt side incorporates the covered loan, simultaneous loans, mortgage-related obligations, and current debt/alimony/child support; the income side uses the current or reasonably expected income/assets the creditor considered. Residual income is the corresponding income minus obligations. 1
[
\text{Mortgage DTI}
\frac{\text{total monthly debt obligations}}
{\text{total monthly income}}
\times 100%
]
[
\text{Residual income}
\text{total monthly income}
\text{total monthly debt obligations}
]
R007-C015 — The frequently repeated “43% rule” should not appear on SettleADebt.com as a current universal federal affordability ceiling. The current General QM provisions in §1026.43 do not impose an across-the-board 43% General QM DTI maximum; the current framework includes pricing and other requirements while requiring consideration and verification of DTI or residual income. Historical pages or articles that still state 43% without a date/status label are unsafe for a current reference. 1
No inference should be drawn that some particular lender or loan program cannot independently use a DTI threshold. The point is narrower: 43% is not the universal current federal debt-situation threshold.
R007-C016 — Consumer credit cards use yet another ability-to-pay framework. Before opening a consumer credit-card account or increasing a credit line, 12 C.F.R. §1026.51(a) generally requires the issuer to consider ability to make required minimum periodic payments using income/assets and current obligations. The rule permits reasonable methodologies involving, for example, debt-to-income, debt-to-assets, or income remaining after obligations; it does not mandate one universal household DTI. 12 C.F.R. §1026.51 15
Essential expenses: no universal legal list
A website should distinguish at least three notions of “essential” expense:
Household-essential expense is an editorial budgeting concept: the cash cost necessary to maintain housing, food, utilities, transportation, insurance, medical care, childcare/dependent care and other facts actually relevant to that household.
Program-allowable expense is an amount a statute, regulation or government program permits in a specified calculation.
Contractual debt payment is an obligation under a loan/card/lease rather than an ordinary living expense, although secured housing and transportation payments can serve both functions economically.
Mixing these categories produces misleading “disposable income.”
R007-C017 — Current bankruptcy means-testing standards are filing-date specific. DOJ's U.S. Trustee Program states that its revised administrative-expense multipliers and IRS-derived expense standards apply to cases filed on or after July 15, 2026. The page was updated June 30, 2026; the effective filing trigger is July 15. UST means testing — cases filed on or after July 15, 2026 2
The same page says the median family income data then in use were Census Bureau data published in September 2025, formatted for the bankruptcy forms. DOJ's California four-person median on that table, for example, is $139,071, but that figure is a bankruptcy means-test input for the stated filing period, not a definition of middle class or an affordability recommendation. UST median-family-income table 16
R007-C018 — The bankruptcy standards must not be republished as a generic family budget. The U.S. Trustee expressly says the IRS-derived figures on its site are for completing bankruptcy forms and are not for tax administration. Its current National Standards include, for example, a one-person total of $867 for the listed food, housekeeping supplies, apparel/services, personal-care and miscellaneous components, with separate bankruptcy calculations shown on the page; its current out-of-pocket health-care standard is $90 per person under 65 and $163 per person age 65 or older. Those are statutory/form inputs for the applicable cases, not findings that a real household “should” spend those amounts. UST National Standards, UST health-care standard 17
R007-C019 — IRS collection standards are likewise purpose-limited. IRS Collection Financial Standards are used in federal tax collection to analyze ability to pay; the IRS Financial Analysis Handbook instructs collection personnel on securing, verifying and analyzing financial information to determine ability to pay delinquent tax. They should not be represented as universal consumer-debt settlement standards. IRS Collection Financial Standards, IRM 5.15.1 Financial Analysis Handbook 18
Disposable income also has multiple meanings
For editorial use, SettleADebt.com should avoid a bare field called “disposable income.” Instead it can calculate:
[
\text{Essential margin}
\text{dependable net cash income}
\text{essential non-debt cash expenses}
]
[
\text{Cash flow after required debt service}
\text{dependable net cash income}
\text{essential non-debt expenses}
\text{required debt payments}
]
These are A007 analytical measures, not statutory definitions.
R007-C020 — Chapter 13 “disposable income” is a statutory term. Under 11 U.S.C. §1325(b)(2), disposable income starts with current monthly income received by the debtor, subject to stated exclusions, and subtracts amounts reasonably necessary for support/maintenance and other specified categories. 11 U.S.C. §1325(b) 19
It therefore cannot safely be defined on a consumer website as merely “take-home pay minus expenses.”
R007-C021 — Historical income can materially mismeasure forward capacity. In Hamilton v. Lanning, 560 U.S. 505 (2010), the Supreme Court considered a Chapter 13 debtor whose statutory six-month current-monthly-income calculation was inflated by a one-time employer buyout even though her current employment income was much lower. The Court rejected an invariably mechanical projection and permitted account to be taken of changes in income or expenses that are known or virtually certain. Official U.S. Reports decision, 560 U.S. 505, especially pp. 505–513, 519–524 20
That holding is bankruptcy-specific, but it is a powerful A007 measurement lesson: a backward-looking average and a forward cash-flow forecast answer different questions.
Assets, liquidity, and tax insolvency
A serious asset inventory should separately record:
| Measure |
Formula or treatment |
What it answers |
| Asset FMV |
Current fair-market estimate at stated date |
Economic balance-sheet value |
| Secured equity |
Asset value − liens against it |
Gross collateral equity before exemptions/costs |
| Liquid funds |
Cash/readily available funds identified separately |
Near-term ability to meet obligations |
| Protected/exempt asset |
Flag based on applicable law |
Collectibility; not necessarily economic value |
| Retirement asset |
Separate account/type/protection/tax characteristics |
Avoids treating retirement dollars as cash equivalents |
| Tax-insolvency asset value |
Federal tax definition and FMV rules |
IRC §108 calculation |
| Program value |
Value required under a particular legal program |
Bankruptcy/tax/benefit-specific |
R007-C022 — Tax “insolvency” is not ordinary-language insolvency. For federal cancellation-of-debt tax purposes, IRC §108(d)(3) defines insolvent as the excess of liabilities over the fair market value of assets, and the §108(a)(1)(B) insolvency exclusion is limited by §108(a)(3) to the amount of insolvency. 26 U.S.C. §108 21
That calculation is sufficiently specialized that a website should not automatically reuse its ordinary net-worth figure as a tax answer without applying the tax definition and the required timing.
Affordability is a context-specific conclusion
R007-C023 — Washington supplies a particularly useful state-law example. For a debt-adjusting contract within Washington Chapter 18.28's scope, RCW 18.28.100 requires the contract to list every debt to be handled and the approximate total of known debts, set payments in precise terms reasonably within the debtor's ability to pay, state fees, and disclose the approximate number and amount of installments. It also gives the debtor a specified three-day cancellation mechanism and requires written notice within five days after the adjuster learns a listed creditor refuses the proposed payment arrangement. RCW 18.28.100(1)–(7) 22
This is a Washington rule, not a nationwide definition of affordability, and Chapter 18.28's definitions/exemptions must be checked before applying it to a particular provider.
R007-C024 — Washington also has numerical debt-adjusting fee limits. Within statutory scope, RCW 18.28.080 generally caps total debt-adjusting fees, including specified third-party/account-administration fees, at 15% of total debt listed in the contract; generally limits the amount retained from an individual payment to 15% of that payment, subject to the nonprofit fair-share language; permits an initial charge up to $25 as part of the total fee; and restricts additional cancellation/default fees as stated in the statute. RCW 18.28.080 23
R007-C025 — Federal telemarketing law regulates debt-relief fee timing rather than supplying a universal fee percentage. For a debt-relief service within the Telemarketing Sales Rule, 16 C.F.R. §310.4(a)(5) generally prohibits charging or receiving a fee until at least one debt has been renegotiated, settled, reduced or otherwise altered, the customer has agreed to the result, and the customer has made at least one payment pursuant to it; the regulation also prescribes how fees must be proportioned when multiple debts are enrolled. 16 C.F.R. §310.4(a)(5) 24
R007-C026 — A TSR-compliant dedicated account is not the provider's money. Where the debt-relief rule's dedicated-account mechanism is used, the account must satisfy regulatory conditions including consumer ownership of the funds and interest, an appropriately insured financial institution, independence requirements for the account administrator, and the consumer's ability to withdraw without penalty; upon withdrawal, remaining funds generally must be returned within seven business days, subject to money lawfully earned by the provider. 16 C.F.R. §310.4(a)(5)(ii) 24
The TSR's exemptions must also be respected. Notably, its exemptions for customer-initiated calls in response to advertising do not generally remove debt-relief calls from the rule in the circumstances expressly carved out, while business-to-business calls receive a separate exemption subject to stated exceptions. 16 C.F.R. §310.6(b)(5)–(7) 25
A real creditor contract shows why contractual cash flow must be measured
R007 opened Chase's complete 22-page public Cardmember Agreement, identifier COL00095, rather than relying on an advertisement or search snippet. Chase Cardmember Agreement COL00095 26
R007-C027 — Minimum payment is contract-specific. On PDF page 1, the Chase agreement's “Minimum Payment” provision calculates the minimum as past-due amounts plus specified special financing obligations plus the greater of $40 (or total amount owed if below $40) or a formula consisting of 1% of specified new-balance amounts plus periodic interest charges and late fees. On PDF page 10, it says the actual minimum appears on the monthly statement and includes past-due amounts. 26
R007-C028 — The same agreement shows why APR, default, fees and allocation belong in the inventory. It states that failing to make a minimum payment can constitute default, provides for specified penalty-APR consequences, and explains how minimum and above-minimum payments generally are allocated among balances. Those are contract terms for this agreement, not a universal Chase policy and not terms that can be imputed to another card. 26
The appropriate editorial lesson is therefore: do not estimate a card's required cash flow solely by applying a generic percentage to the reported balance. Read the governing statement/agreement.
Detailed findings: temporary and lasting shortfalls, settlement suitability, alternatives, consequences, and recovery
Temporary versus lasting shortfall
No federal authority located in this A007 investigation creates a universal legal definition of “temporary debt hardship” versus “permanent hardship.” Those should be expressly labeled analytical classifications, not law.
A useful A007 framework is:
| Question |
Temporary-shortfall evidence |
Lasting/structural-shortfall evidence |
| Cause |
Identified time-bounded event |
Permanent or indefinite income/expense change |
| End/recovery date |
Documented or credibly estimable |
No supported recovery date |
| Stabilized cash flow |
Positive once event ends |
Negative after reasonable stabilization |
| Arrears cure |
Mathematically feasible within relevant program/legal horizon |
Cure amount grows faster than capacity |
| Liquidity |
Unrestricted bridge funds cover gap without sacrificing necessities |
Bridge funds merely postpone recurring deficit |
| Collateral |
Cure/assistance protects essential secured asset |
Ongoing payment remains unaffordable |
| Forecast sensitivity |
Outcome survives plausible lower-income/higher-expense scenario |
Small adverse change worsens deficit materially |
| Assistance |
Program bridges time-limited disruption |
Modification, restructuring, discharge, sale or other structural solution may need comparison |
R007-C029 — The temporary/lasting classification should use both historical and forward-looking information. Lanning demonstrates the legal problem with mechanically projecting a one-time historical income event. A consumer cash-flow tool should likewise identify one-time receipts, one-time costs, known employment changes and temporary benefits instead of blindly annualizing every recent transaction. This is an analytical inference from the decision, not an extension of Chapter 13 law to non-bankruptcy budgeting. 20
A reusable “shortfall” formula is:
[
\text{Monthly shortfall}
\max(0,
\text{essential expenses}
+
\text{required priority/secured/debt payments}
\text{dependable net cash income})
]
and, for unrestricted liquid funds:
[
\text{Deficit runway}
\frac{\text{unrestricted liquid funds allocated to the gap}}
{\text{monthly recurring deficit}}
]
Neither formula decides what a household should spend or whether settlement is legally appropriate. It quantifies the assumptions so that a professional or consumer can see them.
Mortgage assistance is a concrete example of why timing matters
R007-C030 — Federal mortgage loss-mitigation rules contain specific procedural deadlines. Under 12 C.F.R. §1024.41(b), if a servicer receives a loss-mitigation application at least 45 days before a foreclosure sale, it generally must review for completeness and provide the specified written acknowledgement within five days, excluding legal public holidays, Saturdays and Sundays. If a complete application is received more than 37 days before a foreclosure sale, §1024.41(c) generally requires evaluation for available loss-mitigation options within 30 days. 12 C.F.R. §1024.41(b)–(c) 27
Section 1024.41(f) also contains the federal 120-day delinquency restriction on the first notice or filing required for many foreclosure processes, subject to the rule's exceptions. The correct legal analysis requires the actual loan, servicer, delinquency, foreclosure date and other applicable state/federal rules; A007 should not turn the 120-day rule into a promise that foreclosure cannot occur after that date. 27
R007-C031 — Loss mitigation is a process right, not a guaranteed modification. Section 1024.41(a) expressly states that it does not impose a duty on the servicer to provide any particular loss-mitigation option. 27
Washington supplies an additional secured-debt example: RCW 61.24.031 requires specified pre-foreclosure contact to assess the borrower's financial ability to pay a deed-of-trust obligation and explore foreclosure-avoidance options, including an assessment of ability to modify or restructure when a meeting is requested. That is a Washington overlay, not a federal or nationwide rule. RCW Chapter 61.24 28
Settlement suitability
A measurement report should not label a person “suitable for settlement” merely because unsecured debt is high. A defensible suitability screen asks separately:
| Dimension |
Measurement question |
Why it can change the conclusion |
| Liability |
Is the debt actually owed by this person? |
Authorized-user/entity/disputed issues |
| Purpose |
Consumer or commercial? |
Different statutes |
| Ownership |
Who currently owns it? |
Settlement authority/payment routing |
| Security |
Is collateral at risk? |
Settlement may not be the first priority |
| Priority |
Does another obligation have special legal/program treatment? |
APR alone should not rank debts |
| Collection stage |
Current, collection, suit, judgment, garnishment? |
Urgency/deadlines differ |
| Limitation |
Time-barred or unclear? |
Legal collectibility may diverge from face balance |
| Dispute |
Amount/ownership/status disputed? |
Verification may precede negotiation |
| Cash flow |
Can positive funds be accumulated without missing necessities or essential secured obligations? |
A settlement that cannot be funded is not affordable |
| Time |
How long to accumulate required funds? |
Litigation/interest/collateral events may occur first |
| Protected income/assets |
What is exposed to ordinary collection? |
Collectibility differs from net worth |
| Alternatives |
Hardship plan, loss mitigation, tax program, bankruptcy, direct payment or other route? |
Settlement is not the only resolution path |
| Tax |
Could cancellation generate COD income? |
Net economic cost can exceed settlement cash |
| Credit |
What is already being reported and what can validly change? |
No guaranteed score outcome |
| Contract/provider fees |
What legally/contractually may be charged and when? |
Gross settlement amount is not all-in cost |
| Creditor acceptance |
Is there an actual written offer/agreement? |
No settlement percentage should be assumed |
R007-C032 — No universal creditor settlement percentage was found or should be published from this research. Federal debt-relief regulation governs representations, fee timing and account arrangements but does not compel every unsecured creditor to accept a particular discount. An affordability model should therefore let an actual written creditor offer be entered as an input rather than forecast “typical” percentages as a fact. 24
Cancellation-of-debt tax consequences
R007-C033 — Federal tax law starts from inclusion. IRC §61(a)(11) includes income from discharge of indebtedness in gross income, subject to exceptions and exclusions elsewhere in the Code. 26 U.S.C. §61(a)(11) 29
R007-C034 — Bankruptcy and insolvency can change that result. Section 108 includes exclusions for debt discharged in a title 11 case and, subject to its limits, debt discharged while the taxpayer is insolvent. Insolvency is a tax-specific FMV balance-sheet test; the exclusion is limited to the amount of insolvency. 26 U.S.C. §108(a), (d)(3) 21
R007-C035 — A Form 1099-C reporting threshold is not a tax-free threshold. IRS states that applicable financial entities generally file Form 1099-C when $600 or more of debt is canceled, but a taxpayer's obligation to report the correct taxable cancellation amount does not depend simply on whether a correct Form 1099-C arrived. IRS, About Form 1099-C, IRS Topic 431 30
IRS further cautions that receiving a Form 1099-C does not, by itself, resolve whether the creditor actually canceled the obligation if collection continues; the specific facts must be verified. 31
R007-C036 — The federal qualified-principal-residence exclusion changed for 2026. Current IRS instructions state that the temporary qualified principal residence indebtedness exclusion and the temporary special student-loan cancellation exclusion that had been available under prior law expired December 31, 2025. For QPRI, the statute preserves the specified transition for a discharge occurring after 2025 pursuant to a qualifying written arrangement entered into before January 1, 2026. This means a new 2026 mortgage settlement cannot simply be promised tax-free treatment under the expired rule. 3
R007-C037 — Secured-debt tax analysis must distinguish recourse and nonrecourse liability. IRS Topic 431 explains that foreclosure/repository treatment differs depending on whether the borrower is personally liable: with recourse debt, disposition gain/loss and cancellation income may be separate calculations; with nonrecourse debt, the amount-realized rules differ and there generally is not separate ordinary cancellation income in the same manner. 31
State income-tax conformity was not researched across all jurisdictions. Any statement that federal exclusion automatically equals state exclusion is a publication hold.
Credit consequences
R007-C038 — A debt-resolution tool should measure credit-report facts, not promise a score outcome. The reliable federal process identified here is the right to obtain file disclosures and dispute inaccurate information; this investigation did not identify any authority establishing that settlement produces a universal number of points, a universal deletion right, or a guaranteed recovery period. 8
Accordingly, the post-resolution checklist should retain the settlement agreement, proof of all required payments, final creditor/collector confirmation, tax documents, and later credit reports. If a report is inaccurate, use the applicable dispute process; do not promise deletion of accurate information.
Failure modes and recovery
The most consequential A007 failure cases are measurement failures rather than arithmetic errors:
| Failure case |
Adverse outcome |
Recovery step |
| Sum only credit-report balances |
Missing/unreported debts; duplicates; stale balances |
Reconcile reports to statements, validation notices, court papers and contracts |
| Ignore a dispute |
Treats alleged debt as admitted |
Preserve dispute issue/date and verification evidence |
| Ignore collateral |
Unsecured settlement crowds out mortgage/auto cure |
Separate secured cash-flow and asset risk |
| Ignore protected funds |
Overstates ordinary creditor leverage |
Run federal/state exemption analysis |
| Use gross income for household cash flow |
Overstates funds actually available |
Maintain gross and net ledgers |
| Use net income for underwriting DTI |
Produces noncomparable ratio |
Use the program's required denominator |
| Use IRS/UST expense standards as “recommended budget” |
Artificially labels real essentials excessive or affordable |
Label program standards and actual expenses separately |
| Use one recent month |
Misses seasonality and one-time items |
Analyze history plus forward forecast |
| Treat temporary deficit as permanent |
May push toward irreversible resolution unnecessarily |
Identify credible recovery date and bridge need |
| Treat permanent deficit as temporary |
Arrears/interest/legal risk continue |
Run stabilized structural forecast |
| Assume settlement discount |
Funding plan is fictitious |
Use actual written offer only |
| Ignore fees |
Understates all-in cash requirement |
Apply actual contract and statutory fee rules |
| Ignore COD tax |
Net resolution cost understated |
Run federal tax screen; state review if relevant |
| Ignore lawsuit/foreclosure deadlines |
Rights can be lost while budgeting |
Legal-stage triage precedes optimization |
| Count protected/retirement assets as ordinary cash |
Distorts affordability and may create tax/protection consequences |
Maintain separate liquidity/protection classifications |
| Assume 1099-C means debt conclusively gone |
Liability/tax record can conflict |
Verify with creditor and tax authority rules |
Worked examples, comparisons, and publication opportunities
All examples below are mathematical illustrations, not client examples, creditor policies, settlement predictions, or individualized advice.
DTI can be positive-looking while cash flow is negative
Assume:
Gross monthly income = $7,200
Net monthly cash income after payroll deductions = $5,550
Monthly debt obligations for the DTI illustration:
- fully loaded mortgage obligation: $1,800
- auto loan: $450
- student loan: $280
- card minimums: $350
Total monthly debt obligations:
[
1{,}800+450+280+350=$2{,}880
]
Mortgage-style DTI:
[
$2{,}880 \div $7{,}200 = 0.40 = 40%
]
Now assume essential non-debt cash expenses are $2,900 per month.
Actual cash flow after those essentials and debt payments:
[
$5{,}550-$2{,}900-$2{,}880=-$230
]
The same household therefore has 40% DTI and a $230 monthly cash deficit under the stated assumptions. There is no conclusion here that 40% is acceptable or unacceptable. The lesson is that DTI and household cash flow measure different things. The DTI formula comes from the mortgage regulation; the cash-flow calculation is an A007 analytical measure. 1
Temporary versus lasting shortfall
Assume recurring net cash income of $5,000, normal essential expenses of $3,300, and required debt service of $1,400.
Stabilized monthly cash flow:
[
$5{,}000-$3{,}300-$1{,}400=+$300
]
Now add a documented temporary $900 monthly expense lasting three months.
Temporary cash flow:
[
$5{,}000-$3{,}300-$1{,}400-$900=-$600
]
Three-month cumulative deficit:
[
$600\times3=$1{,}800
]
If unrestricted liquidity earmarked for the gap is $2,400, the immediate mathematical bridge exists, though whether using it is prudent is a separate decision.
Change the facts: income falls permanently to $4,200 with normal expenses/debt service unchanged.
[
$4{,}200-$3{,}300-$1{,}400=-$500/month
]
Annualized recurring deficit:
[
$500\times12=$6{,}000
]
A $3,000 unrestricted reserve would mathematically cover six months of that unchanged deficit:
[
$3{,}000\div$500=6
]
The first case has a documented return to positive baseline cash flow; the second does not. That is a useful analytical distinction between bridgeable and structural shortfalls, not a legal test.
Federal tax insolvency
Assume, immediately before a hypothetical debt cancellation and using the correct federal-tax valuation rules:
FMV of assets = $85,000
Liabilities = $110,000
Tax insolvency amount:
[
$110{,}000-$85{,}000=$25{,}000
]
Assume $30,000 is canceled.
Under IRC §108's insolvency limitation, the insolvency exclusion can be no greater than the $25,000 insolvency amount under these simplified assumptions:
[
\min($30{,}000,$25{,}000)=$25{,}000
]
The remaining:
[
$30{,}000-$25{,}000=$5{,}000
]
is potentially includible unless another applicable exception or exclusion changes the result. The actual tax calculation can require additional rules, attributes and documentation, including Form 982; this example is not a tax return calculation. 21
Washington statutory debt-adjusting fee cap
Assume, solely for arithmetic, a Washington contract is actually subject to RCW Chapter 18.28 and lists $40,000 of debt.
The statutory 15% total-fee ceiling yields:
[
$40{,}000\times15%=$6{,}000
]
That is a maximum under the cited state provision, not an assumed or recommended provider fee.
If a particular payment is $500, the statute's 15%-of-payment limitation would yield:
[
$500\times15%=$75
]
subject to the statute's exact nonprofit-fair-share and other provisions. The federal TSR, when independently applicable, can further regulate when a debt-relief fee may be earned. 23
Contract-specific card minimum
Using the opened Chase COL00095 formula only, assume:
- no past-due amount;
- no special financing payment obligation;
- qualifying new balance used in the 1% component = $10,000;
- periodic interest charges on the relevant statement = $210;
- no late fee.
One percent of the relevant new balance:
[
$10{,}000\times1%=$100
]
Formula component:
[
$100+$210=$310
]
Compare against $40:
[
\max($40,$310)=$310
]
The illustrated minimum is therefore $310 under those assumptions and that contract formula. It is not a generic rule for Chase accounts, other issuers, or any real account; the actual statement controls the actual minimum. 32
Mortgage loss-mitigation deadline illustration
Assume a complete loss-mitigation application is delivered 50 days before a scheduled foreclosure sale.
Because 50 days is at least 45 days, the §1024.41(b) acknowledgement/completeness provisions are implicated.
Because 50 days is also more than 37 days, the §1024.41(c) complete-application evaluation provisions are implicated, including the general 30-day evaluation period.
That does not mean a modification must be approved; §1024.41(a) expressly disclaims a duty to offer a particular option. 27
Federal wage-garnishment formula
For ordinary garnishment covered by 15 U.S.C. §1673(a), let:
(E) = weekly disposable earnings
(M) = current applicable federal minimum hourly wage
The general federal maximum is:
[
\max\left(0,\min(0.25E,;E-30M)\right)
]
before considering statutory exceptions and any more protective applicable law. This is an enforcement formula, not a recommended debt payment. 14
Comparison of the main affordability measures
| Measure |
Numerator/input |
Denominator/subtraction |
Governing context |
Correct use |
Major misuse |
| Consumer DTI |
Monthly debt payments |
Gross monthly income |
General explanatory metric; mortgage has defined version |
Leverage comparison |
Calling one percentage universally “safe” |
| Reg Z mortgage DTI |
Defined monthly debt obligations |
Defined monthly income |
12 C.F.R. §1026.43 |
Mortgage ATR/QM analysis |
Using it as household cash-flow surplus |
| Residual income |
Monthly income |
Minus monthly obligations |
Reg Z mortgage |
Remaining income after specified obligations |
Assuming remaining amount equals discretionary cash |
| Credit-card ability to pay |
Income/assets/current obligations |
Reasonable issuer method |
12 C.F.R. §1026.51 |
Card opening/line increase |
Assuming a federal mandated DTI cutoff |
| Household cash flow |
Net cash received |
Actual cash outflows |
Analytical |
Day-to-day affordability |
Calling it bankruptcy disposable income |
| Chapter 13 disposable income |
Statutory current monthly income |
Statutorily permitted expenses/exclusions |
11 U.S.C. §1325 |
Chapter 13 plan analysis |
Copying it into ordinary budgeting |
| Bankruptcy means test |
Statutory income + filing-date standards |
Statutory deductions |
11 U.S.C. §707/UST forms |
Bankruptcy filing analysis |
Treating IRS standards as recommended living budget |
| IRS collection ability |
Verified financial information, assets, income |
IRS allowable expense framework |
Tax collection |
Federal tax collection |
Applying it to all private debts |
| Tax insolvency |
Liabilities |
FMV of assets |
IRC §108 |
COD exclusion limit |
Equating it to cash-flow insolvency |
| Collection exposure |
Earnings/assets subject to enforcement |
Exemptions/protected funds |
Federal + state law |
Legal collectibility |
Treating maximum garnishment as “affordable” |
Distinct publication and tool opportunities
| Opportunity |
Function |
Critical guardrail |
| Debt Situation Master Inventory |
Builds creditor/owner/liability/security/stage/evidence ledger |
Credit report is not conclusive debt ledger |
| DTI vs. Cash-Flow Calculator |
Displays gross-income DTI beside real net-cash surplus |
No universal “good DTI” verdict |
| Temporary or Structural Shortfall Analyzer |
Identifies recovery date, baseline deficit and runway |
Label as analytical, not legal eligibility |
| Cancellation-of-Debt Insolvency Worksheet |
FMV assets vs liabilities immediately before cancellation |
Strong tax disclaimer; Form 982/professional review |
| Collection-Exposure Layer |
Flags wages, federal benefits, collateral and legal stage |
Must load state-specific exemption modules |
| Mortgage Loss-Mitigation Deadline Tool |
120/45/37/30/5-day rule visualization |
Actual sale date/state law/servicer facts required |
| Annotated Regulation F Validation Notice |
Shows current creditor, itemization and dispute period |
Applies to covered debt collectors |
| Annotated Credit-Card Agreement |
Shows balance, minimum payment, APR, fees, allocation |
Contract-specific; never extrapolate creditor policy |
| Washington Debt-Adjuster Contract Checker |
Lists debt inventory, ability-to-pay, fees, cancellation |
First establish Chapter 18.28 scope/exemptions |
| Evidence Confidence Meter |
Marks contract/judgment/statement versus report/self-report |
Confidence score must not imply legal validity |
Evidence registers
Source register
“Opened” means the actual HTML authority or full document was opened in this research session. “Opened + screenshot” means a PDF was opened and relevant pages were visually inspected. “Discovery-only” means located but not relied on for a dispositive proposition.
| Source ID |
Title / issuer / direct source |
Pinpoint |
Version, effective trigger, status |
Jurisdiction / scope |
Check / access / limits |
| R007-S001 |
15 U.S.C. §1692a, Definitions — U.S. House OLRC |
§1692a(5)–(6) |
Current/preliminary U.S. Code |
Federal; FDCPA |
2026-10-22; opened HTML. 4 |
| R007-S002 |
15 U.S.C. §1692g, Validation of debts — OLRC |
§1692g(a)–(b) |
Current federal statute |
Federal; covered debt collectors |
2026-10-22; opened/search-verified primary text. 6 |
| R007-S003 |
12 C.F.R. §1006.34 — CFPB/OFR |
§1006.34(a)–(c) |
Current Regulation F |
Federal; FDCPA debt collectors |
2026-10-22; opened HTML. Validation period and itemization provisions verified. 5 |
| R007-S004 |
12 C.F.R. §1006.26 |
§1006.26(a)–(b) |
Current |
Federal; covered time-barred debt collection |
2026-10-22; opened HTML. 7 |
| R007-S005 |
12 C.F.R. Part 1006 |
§§1006.22, .30, .38 |
Current |
Federal; covered debt collectors |
2026-10-22; opened HTML. 11 |
| R007-S006 |
15 U.S.C. §1681j — OLRC |
§1681j(a) |
Current |
Federal; consumer reporting |
2026-10-22; opened primary text. 8 |
| R007-S007 |
15 U.S.C. §1681i — OLRC |
§1681i(a)–(c) |
Current |
Federal; CRA disputes |
2026-10-22; opened HTML. 9 |
| R007-S008 |
How do I get a copy of my credit reports? — CFPB |
Free-report availability |
Current operational agency guidance |
U.S. consumer reports |
2026-10-22; official agency source; operational availability can change. 33 |
| R007-S009 |
Bankruptcy Forms — U.S. Courts |
Schedules A/B, C, D, E/F, G, H, I, J |
Current forms repository |
Federal bankruptcy |
2026-10-22; official judiciary source. 10 |
| R007-S010 |
12 C.F.R. §1026.43 — CFPB/OFR |
§1026.43(c)(2)–(4), (c)(7), (e) |
Current Regulation Z |
Federal; covered mortgage credit |
2026-10-22; opened HTML. DTI/residual and current QM framework verified. 1 |
| R007-S011 |
12 C.F.R. §1026.51 — CFPB/OFR |
§1026.51(a) |
Current |
Federal; consumer credit-card accounts |
2026-10-22; opened HTML. 15 |
| R007-S012 |
UST Means Testing — cases filed on/after July 15, 2026 — DOJ |
Sections I–III |
Posted 2026-06-30; effective for cases filed on/after 2026-07-15 |
Federal bankruptcy |
2026-10-22; opened HTML. 2 |
| R007-S013 |
UST Median Family Income Table |
State/household table |
Applicable cases filed on/after 2026-07-15 |
Federal bankruptcy |
2026-10-22; opened HTML. 16 |
| R007-S014 |
UST National Expense Standards |
Food/clothing/other table |
Applicable cases filed on/after 2026-07-15 |
Federal bankruptcy |
2026-10-22; opened HTML. Not generic budget guidance. 17 |
| R007-S015 |
UST Out-of-Pocket Health Care Standards |
$90 under 65; $163 age 65+ |
Applicable cases filed on/after 2026-07-15 |
Federal bankruptcy |
2026-10-22; opened HTML. 34 |
| R007-S016 |
Collection Financial Standards — IRS |
National/local standards |
2026 standards |
Federal tax collection |
2026-10-22; opened official page. Not a general consumer budget. 18 |
| R007-S017 |
IRM 5.15.1 Financial Analysis Handbook — IRS |
IRM 5.15.1 |
Current page updated in 2026 |
Federal tax collection |
2026-10-22; opened HTML. 35 |
| R007-S018 |
11 U.S.C. §1325 — OLRC |
§1325(b)(1)–(4) |
Current/preliminary |
Federal Chapter 13 |
2026-10-22; primary text opened/search-verified. 19 |
| R007-S019 |
Hamilton v. Lanning, 560 U.S. 505 — U.S. Supreme Court / U.S. Reports |
560 U.S. 505–524 |
Decided 2010-06-07; precedential decision |
Federal bankruptcy |
2026-10-22; actual opinion PDF opened; p.505 screenshot inspected. 20 |
| R007-S020 |
16 C.F.R. §310.4 — FTC/OFR |
§310.4(a)(5) |
Current TSR |
Federal; covered debt-relief telemarketing |
2026-10-22; opened HTML; advance-fee/dedicated-account provisions verified. 24 |
| R007-S021 |
16 C.F.R. §310.6 |
§310.6(b)(5)–(7) |
Current |
Federal TSR exemptions |
2026-10-22; opened HTML. 25 |
| R007-S022 |
RCW 18.28.080 — Washington Legislature |
§18.28.080(1)–(3) |
Current page; statutory history through 2015 shown |
Washington; debt adjusters within Chapter 18.28 |
2026-10-22; opened HTML. Chapter-wide scope/exemptions require separate check before application. 23 |
| R007-S023 |
RCW 18.28.100 — Washington Legislature |
§18.28.100(1)–(8) |
Current page |
Washington debt-adjusting contracts |
2026-10-22; opened HTML. 22 |
| R007-S024 |
12 C.F.R. §1024.41 — CFPB/OFR |
§1024.41(a)–(f) |
eCFR Title 12 displayed up to date through 2026-10-19 |
Federal mortgage servicing |
2026-10-22; opened HTML. Three-day source lag relative to check date noted. 27 |
| R007-S025 |
RCW Chapter 61.24 — Washington Legislature |
RCW 61.24.031 |
Current |
Washington deeds of trust |
2026-10-22; opened HTML/search result. 28 |
| R007-S026 |
26 U.S.C. §61 — OLRC |
§61(a)(11) |
Current/preliminary |
Federal income tax |
2026-10-22; primary text. 29 |
| R007-S027 |
26 U.S.C. §108 — OLRC |
§108(a), (a)(3), (d)(3) |
Current/preliminary |
Federal COD income |
2026-10-22; primary text. 21 |
| R007-S028 |
IRS Topic 431 — Canceled debt |
Inclusion; recourse/nonrecourse; 1099-C |
Updated 2026-09-24 |
Federal individual income tax |
2026-10-22; opened HTML. 31 |
| R007-S029 |
About Form 1099-C — IRS |
$600 information-return threshold |
Page updated 2026 |
Federal information reporting |
2026-10-22; official page. 30 |
| R007-S030 |
About Form 982 — IRS |
Reduction of tax attributes / COD exclusions |
Current page |
Federal income tax |
2026-10-22; official source. 36 |
| R007-S031 |
Instructions for Forms 1099-A and 1099-C — IRS |
2026-expiration discussion |
Current 2026 guidance |
Federal tax |
2026-10-22; official source; used with Code. 3 |
| R007-S032 |
15 U.S.C. §1673 — OLRC |
§1673(a)–(b) |
Text through Public Law 119-120, Oct. 7, 2026 |
Federal wage garnishment |
2026-10-22; opened HTML. 14 |
| R007-S033 |
42 U.S.C. §407 — OLRC |
§407(a) |
Current/preliminary |
Social Security benefits |
2026-10-22; opened primary text. 12 |
| R007-S034 |
31 C.F.R. Part 212 — Treasury/OFR |
§§212.2–.6; App. C |
Current |
Bank accounts containing covered federal benefits |
2026-10-22; opened HTML. 37 |
| R007-S035 |
38 U.S.C. §5301 — OLRC |
§5301(a) |
Text through Public Law 119-120, Oct. 7, 2026 |
VA benefits |
2026-10-22; opened HTML. 38 |
| R007-S036 |
Chase Cardmember Agreement COL00095 — JPMorgan Chase Bank, N.A. |
PDF pp.1, 6, 10–11, 15; full agreement 22 pp. |
Publication date not separately stated; rate table references 2026 Prime Rate date |
Creditor contract example only |
2026-10-22; complete PDF opened; pp.1 and 10 screenshot-inspected. Not an individual borrower's account agreement. 26 |
| R007-S037 |
CFPB Credit Card Agreement Database |
Most recent quarterly agreements |
Current database as checked |
U.S. public issuer agreements |
2026-10-22; opened HTML. Database agreements do not prove a particular consumer's governing version. 39 |
| R007-S038 |
Ransom v. FIA Card Services listing, U.S. Reports vol. 562 — GovInfo |
562 U.S. 61 (2011) |
Historical precedential decision |
Federal bankruptcy |
Discovery-only for R007 holding analysis; opinion itself was not separately opened/screenshot before web-tool limit, so no dispositive claim relies on its holding. 40 |
Claim/evidence register
| Claim ID |
Precise claim |
Evidence / pinpoint |
Conditions and exceptions |
Jurisdiction/date / limitation |
| R007-C001 |
No single federal affordability/disposable-income formula governs all debt situations. |
S010 §1026.43; S011 §1026.51; S018 §1325(b); S016–17 IRS |
Different programs intentionally use different definitions |
Federal, checked 2026-10-22; synthesis |
| R007-C002 |
FDCPA “debt” is personal/family/household-purpose transaction debt. |
S001 §1692a(5) |
Does not mean business debt is unenforceable; means FDCPA scope differs |
Federal |
| R007-C003 |
Covered debt collectors generally must provide defined validation information and a validation period. |
S003 §1006.34(a)–(c) |
FDCPA/Reg F scope limitations |
Federal |
| R007-C004 |
Timely written dispute can require collection pause pending verification. |
S002 §1692g(b) |
Covered debt collector; statutory procedure must be followed |
Federal |
| R007-C005 |
Covered debt collector may not bring/threaten suit on time-barred debt; bankruptcy proof-of-claim exception. |
S004 §1006.26 |
Applicable limitation period comes from other law |
Federal |
| R007-C006 |
Statutory free annual CRA disclosure exists; current CFPB reports weekly online availability. |
S006; S008 |
Weekly availability is operational, not the statutory minimum |
Federal/current 2026 |
| R007-C007 |
FCRA provides a generally 30-day CRA reinvestigation process. |
S007 §1681i(a) |
Statutory extension/additional-information rules apply |
Federal |
| R007-C008 |
Official bankruptcy forms separately inventory property, security, unsecured debts, codebtors, income and expenses. |
S009 |
Form structure is not itself a general debt-settlement rule |
Federal |
| R007-C009 |
Personal liability and lien/security status can diverge. |
S005 §1006.30(b)(2)(ii) |
Bankruptcy-specific example; state lien law still relevant |
Federal |
| R007-C010 |
Protected benefits/collectibility must be measured separately from liability. |
S033–S035 |
Statutory exceptions can apply |
Federal |
| R007-C011 |
Ordinary federal wage garnishment has §1673 lesser-of formula. |
S032 §1673(a) |
Support, tax, Chapter 13 and other exceptions; state overlays |
Federal |
| R007-C012 |
Current debt balance may differ from itemization-date amount due to interest/fees/payments/credits and contract mechanics. |
S003 §1006.34(c); S036 |
Particular charges require authorization by contract/law |
Federal + contract example |
| R007-C013 |
Mortgage ATR requires multiple specified factors and verification. |
S010 §1026.43(c)(2)–(4) |
Covered transactions and regulatory exceptions |
Federal |
| R007-C014 |
Mortgage DTI = defined monthly debt obligations / defined monthly income; residual income is subtraction. |
S010 §1026.43(c)(7)(ii) |
Reg Z context, not universal consumer formula |
Federal |
| R007-C015 |
43% is not a current universal General QM DTI ceiling. |
S010 §1026.43(e) |
Loan/program-specific standards can still exist |
Federal/current |
| R007-C016 |
Credit-card ability-to-pay rule allows reasonable analysis using income/assets and current obligations; no one mandated DTI. |
S011 §1026.51(a) |
Consumer credit-card account scope |
Federal |
| R007-C017 |
Current UST standards apply to cases filed on/after July 15, 2026, despite June 30 update date. |
S012 |
Filing-date sensitive |
Federal bankruptcy |
| R007-C018 |
UST/IRS-derived bankruptcy standards are not generic consumer budgets. |
S012, S014, S015 |
Applicable to forms/cases stated |
Federal bankruptcy |
| R007-C019 |
IRS collection standards are tax-collection financial-analysis tools, not universal private-debt standards. |
S016–S017 |
IRS collection scope |
Federal tax |
| R007-C020 |
Chapter 13 has a statutory “disposable income” definition. |
S018 §1325(b)(2) |
Chapter 13 context |
Federal |
| R007-C021 |
Lanning allows known/virtually certain changes to matter in projected disposable-income analysis and illustrates distortion from one-time income. |
S019, 560 U.S. 505–524 |
Chapter 13 holding; broader use here only as analytical analogy |
Federal, 2010 precedent |
| R007-C022 |
Tax insolvency is liabilities exceeding FMV assets; exclusion capped by insolvency. |
S027 §108(a)(3), (d)(3) |
Other COD rules/attributes may apply |
Federal tax |
| R007-C023 |
Covered Washington debt-adjusting contracts must list debts and state payments reasonably within ability to pay. |
S023 §18.28.100(1)–(4) |
Chapter 18.28 scope/exemptions must be established |
Washington |
| R007-C024 |
Washington statute imposes specified 15% debt-adjusting fee caps. |
S022 §18.28.080 |
Only within statute's scope; exceptions matter |
Washington |
| R007-C025 |
TSR generally bars covered debt-relief fees until stated settlement/performance events occur. |
S020 §310.4(a)(5) |
TSR jurisdiction/scope |
Federal |
| R007-C026 |
TSR dedicated-account rules preserve consumer ownership/withdrawal and generally require remaining-fund return within seven business days. |
S020 §310.4(a)(5)(ii) |
Covered arrangement only |
Federal |
| R007-C027 |
Chase COL00095 contains a specific minimum-payment formula. |
S036 PDF p.1 and p.10 |
Contract-specific example, not issuer-wide promise |
Contract example, checked 2026-10-22 |
| R007-C028 |
Same agreement has contract-specific default/penalty/payment-allocation terms. |
S036 pp.6, 10–11 |
Actual consumer agreement can differ |
Contract example |
| R007-C029 |
Temporary/permanent hardship is an analytical classification; history alone can misstate future capacity. |
S019 plus R007 framework |
Not a statutory test outside particular programs |
Synthesis |
| R007-C030 |
§1024.41 contains 45-day/5-day and >37-day/30-day loss-mitigation procedures. |
S024 §1024.41(b)–(c) |
Servicer/loan/foreclosure facts and exceptions matter |
Federal mortgage servicing |
| R007-C031 |
§1024.41 does not require a servicer to offer a specific loss-mitigation option. |
S024 §1024.41(a) |
Other law/contract may create additional rights |
Federal |
| R007-C032 |
No verified universal creditor settlement percentage exists in this evidence set. |
S020–S021; source review |
Actual creditor agreement/offer controls |
Research conclusion |
| R007-C033 |
COD income is generally included in gross income under IRC §61(a)(11). |
S026 |
Subject to exceptions/exclusions |
Federal tax |
| R007-C034 |
Bankruptcy and insolvency can exclude qualifying COD income subject to §108. |
S027 |
Detailed requirements/attribute reduction apply |
Federal tax |
| R007-C035 |
$600 Form 1099-C threshold is an information-reporting threshold, not a blanket tax-free amount. |
S028–S029 |
Correct tax amount remains taxpayer-specific |
Federal tax |
| R007-C036 |
Temporary QPRI exclusion generally expired after 2025, with transition for qualifying pre-2026 written arrangements. |
S027, S031 |
Exact debt/arrangement dates control |
Federal tax/current 2026 |
| R007-C037 |
Recourse and nonrecourse secured debts can have different federal tax results on foreclosure/cancellation. |
S028 |
Property basis and other rules matter |
Federal tax |
| R007-C038 |
No universal credit-score outcome or deletion result was verified. |
S006–S008 |
FCRA accuracy/dispute rights remain |
Federal; research limitation |
| R007-C039 |
Credit report, contract/statement, collection validation and legal-process records should be reconciled rather than treated as interchangeable. |
S002–S009, S036 |
Evidence can conflict; legal review may be required |
Synthesis |
| R007-C040 |
DTI and real cash flow can produce materially different pictures. |
S010–S011 plus formulas |
Mathematical conclusion; no universal cutoff |
Synthesis |
| R007-C041 |
Protected income/asset status affects collection exposure, not necessarily whether the underlying liability exists. |
S032–S035 |
Exceptions/state law |
Federal + state overlay needed |
| R007-C042 |
Settlement affordability must include timing, required secured/priority payments, provider fees and legal-stage risk, not just settlement principal. |
S020, S022–S025, S036 |
Synthesis; particular facts control |
Multi-jurisdiction |
| R007-C043 |
A complete mortgage application can become more valuable procedurally as foreclosure deadlines approach, but application does not guarantee approval. |
S024 |
Exact sale date and completeness critical |
Federal |
| R007-C044 |
Post-resolution measurement should preserve proof of performance and reconcile tax/reporting records; inaccurate CRA data can be disputed. |
S007, S028–S030 |
Does not create right to delete accurate reporting |
Federal |
| R007-C045 |
State, tribal, individual-contract and creditor-policy overlays remain indispensable where federal law does not supply the answer. |
Source review/gap register |
No universal substitution permitted |
Research limitation |
Coverage, gaps, publication holds, and researcher self-check
Granular coverage table
| Assigned seed / required dimension |
Status |
Findings / claim references |
Missing evidence or limitation |
Exact next research action before broader publication |
| Inventory |
Answered |
C003–C008, C012, C039 |
None for federal framework |
State modules can add required state notices |
| Balance sheet |
Answered |
C008–C010, C022 |
Valuation rules can be program-specific |
Build program-specific valuation annotations |
| Income |
Answered |
C013–C021 |
Benefits/program definitions beyond researched programs vary |
Add program modules only when publishing about them |
| Essential expenses |
Answered |
C017–C020 |
No universal definition exists |
Keep actual and program-allowable expense columns separate |
| Assets |
Answered |
C008–C010, C022, C041 |
State exemptions not fifty-state verified |
Research exemptions state by state |
| Cash flow |
Answered |
C001, C040, worked formulas |
Analytical, not statutory |
Publish assumptions beside result |
| DTI |
Answered |
C014–C016, C040 |
Lender/program overlays vary |
Do not publish universal approval threshold |
| Disposable income |
Answered |
C019–C022 |
Bankruptcy/tax definitions differ |
Label every displayed metric by context |
| Affordability |
Answered |
C013–C026, C040–C043 |
No universal federal formula |
Use context-specific measure |
| Temporary shortfall |
Answered as analytical concept |
C021, C029 |
No universal statutory definition located |
Label “analytical classification” |
| Lasting shortfall |
Answered as analytical concept |
C029, worked example |
Same |
Stress-test stabilized forecast |
| Consumer vs commercial purpose |
Answered federally |
C002 |
State consumer laws can define scope differently |
State-by-state scope module |
| Liability |
Answered conceptually |
C003–C009, C039 |
Personal guarantees/state contract law not surveyed nationally |
Contract/jurisdiction review |
| Security/collateral |
Answered federally at framework level |
C009, C030–C031, C037 |
State repossession/deficiency/anti-deficiency law not surveyed |
Fifty-state secured-debt module |
| Priority |
Partial |
C008, C042 |
Full current bankruptcy/state priority hierarchy not reproduced |
Separate A007 priority appendix using current 11 U.S.C. §507 and state liens |
| Disputed debt |
Answered federally |
C004, C007 |
State validation rights may supplement |
State collection-law module |
| Collection stage |
Answered |
C003–C012 |
State lawsuit/judgment deadlines vary |
State SOL/judgment duration modules |
| Protected income |
Answered federally |
C010–C011, C041 |
State exemptions potentially more protective |
Fifty-state exemption module |
| Protected assets |
Partial |
Federal benefits covered; state property exemptions not completed |
C010, C041 |
Homestead, vehicle, bank, wage, retirement by state |
| Debt lifecycle |
Answered |
Lifecycle table; C003–C012 |
Charge-off/accounting standards not separately researched |
Add creditor-accounting article only if needed |
| Procedure/documents |
Answered |
Inventory schema; C003–C007, C023, C030 |
Specific program forms change |
Link only current forms |
| Deadlines |
Answered for researched federal/Washington examples |
Validation period; CRA dispute; WA cancellation; TSR account; mortgage deadlines |
Not every state court/collection deadline |
Jurisdiction module |
| Costs/formulas |
Answered for DTI, cash flow, WA fees, tax insolvency, garnishment, Chase contract |
C014, C022, C024, C027, examples |
No creditor settlement percentage |
Keep actual-offer input model |
| Settlement suitability |
Answered as analytical framework |
C032, C040–C043 |
Creditor willingness not public/universal |
Require actual offer/policy evidence |
| Alternatives |
Partial |
Mortgage loss mitigation, bankruptcy, IRS collection frameworks |
Student-loan, medical, utility and every creditor hardship program not covered |
Separate debt-type program investigations |
| Tax consequences |
Answered federally at core level |
C022, C033–C037 |
State conformity not researched |
Fifty-state COD tax module before state-specific claims |
| Credit consequences |
Partial/appropriately bounded |
C038, C044 |
Proprietary scoring models and medical-debt reporting developments not investigated |
Separate current credit-reporting assignment |
| Foreclosure assistance |
Answered federally + WA example |
C030–C031; S025 |
Investor/FHA/VA/GSE program overlays omitted |
Separate mortgage program modules |
| Recovery after settlement |
Answered at process level |
C044 |
Creditor-specific account-closing procedures vary |
Use actual settlement agreement |
| Federal law |
Answered for A007 core |
S001–S021, S024, S026–S035 |
eCFR timing limit noted below |
Federal Register delta check at publication |
| State law |
Partial, representative Washington example |
S022–S025 |
Not fifty-state |
Individual state investigations authorized by project |
| Tribal law |
Unresolved |
C045 |
No tribe-by-tribe primary-law survey completed |
Identify tribe, court, creditor and governing-law clause before publishing tribal rule |
| Program rules |
Answered for UST, IRS, Reg Z/RESPA examples |
S010–S017, S024 |
Other programs omitted |
Separate program modules |
| Creditor policy |
Excluded absent evidence |
C032 |
No verified settlement/hardship policies |
Obtain current first-party official policy before claim |
| Individual creditor contract |
Answered with representative public agreement |
C027–C028; S036 |
Not a specific consumer's contract |
Use actual governing agreement for individual analysis |
| All creditor contracts |
Unresolved/not appropriate as universal claim |
S037 database |
Hundreds of issuer/version combinations |
Contract-specific research on demand |
| Proposed law |
Excluded from current findings |
— |
Discovery leads were not verified to enactment/effective status |
Verify bill history before mentioning |
| Stayed/vacated rules |
No such authority relied upon |
— |
Separate current-rule checks needed for topics not researched |
Check docket/agency status in each module |
| Historical rules |
Answered where consequential |
C015; C021 |
Historical QM implementation dates not fully reconstructed |
Separate QM history article if publishing chronology |
| Expired rules |
Answered where consequential |
C036 |
State analogues unknown |
State tax review |
| Unknown rules/policies |
Explicitly preserved |
C032, C038, C045 |
Creditor/tribal/state-specific |
Do not infer; hold publication claim |
Gap register and publication holds
State-by-state collection exposure — hold. The federal garnishment and federal-benefit rules are verified, but a nationwide publication stating “creditors can take X” requires state-specific wage, bank, homestead, vehicle, household-property, retirement, wildcard and judgment exemptions. Federal law alone is not enough. 14
State statutes of limitation and revival — hold. Regulation F supplies the federal prohibition on suing or threatening suit on time-barred debts by covered collectors, but it does not determine the applicable state limitations period, accrual date, tolling, choice of law, judgment life or the effect of acknowledgments/payments. No state-universal chart should be inferred from R007. 7
State cancellation-of-debt tax treatment — hold. Federal COD rules are verified. State conformity, subtraction modifications and filing consequences were not investigated in fifty-state detail.
Tribal jurisdiction — hold. No tribe-by-tribe code, tribal-court, sovereign-immunity, lending-charter or governing-law investigation was conducted. “Tribal debt” cannot be treated as one legal jurisdiction.
Commercial and personal guarantees — hold for governing instrument. FDCPA's consumer-purpose boundary is clear, but whether an owner personally owes an entity's commercial debt depends on the operative agreement and law. A website should not infer guarantor liability from business ownership.
Secured deficiency/anti-deficiency rules — hold by state and debt type. Federal materials establish the need to separate lien, collateral and personal liability, but foreclosure/repo deficiency rights are state- and transaction-specific.
Current student-loan assistance — hold. Federal student-loan repayment/discharge rules have been unusually dynamic. They were not separately current-checked in A007 and no student-loan program eligibility statement should be grafted onto this report.
Medical-debt credit reporting — hold. Current regulatory/litigation developments were not independently researched in this assignment. R007 deliberately makes no current categorical claim about deletion, scoring, or reporting of medical debt.
Creditor hardship and settlement policy — hold. No creditor is assigned a settlement percentage, hardship threshold, litigation trigger or preferred balance because no verified first-party policy was obtained.
Ransom means-test holding — evidence hold. The official GovInfo volume index locating Ransom v. FIA Card Services, N.A., 562 U.S. 61 (2011), was found, but its actual opinion PDF was not separately opened/screenshot during the available tool session. Although the case is relevant to standardized bankruptcy expense deductions, its holding is not used as a dispositive R007 claim. 40
Current-regulation delta — narrow publication hold. The opened §1024.41 eCFR page stated that Title 12 was up to date as of October 19, 2026, while the R007 check date is October 22. No separate Federal Register delta check for October 20–22 was completed before the web research limit. The report therefore records the eCFR currency date rather than pretending the site's “checked on” date is the legal effective date. 27
Researcher self-check
| Check performed |
Result |
| Actual research date recorded |
Yes — 2026-10-22 America/Los_Angeles |
| Federal statutes opened from primary source |
Yes — FDCPA/FCRA, garnishment, Social Security, VA, IRC, Bankruptcy Code |
| Current regulations opened |
Yes — Regulation F, Regulation Z, RESPA/Reg X, TSR, Treasury Part 212 |
| Effective date distinguished from web update date |
Yes — UST June 30 update versus July 15 filing applicability explicitly separated |
| Current/historical rule distinguished |
Yes — 43% General QM DTI treated as historical, not current universal rule |
| Expired provision labeled |
Yes — QPRI general post-2025 expiration/transition identified |
| Proposed rules treated as current |
No |
| Stayed/vacated rules silently relied upon |
No known instance in claim set |
| Supreme Court authority opened |
Yes — Hamilton v. Lanning, official U.S. Reports PDF |
| PDF visual inspection used |
Yes — Lanning page 505 and Chase agreement pages 1 and 10 were screenshot-inspected |
| Complete real creditor agreement opened |
Yes — Chase COL00095, 22 pages; expressly labeled public example rather than individual contract/policy |
| Creditor settlement percentage invented |
No |
| Provider fee percentage generalized nationally |
No — Washington's statutory cap is expressly jurisdiction/scope limited |
| Universal DTI threshold stated |
No |
| Universal tax-free settlement promise stated |
No |
| Universal credit-score/deletion promise stated |
No |
| Consumer/commercial purpose separated |
Yes |
| Security and personal liability separated |
Yes |
| Disputed debt separated |
Yes |
| Collection stage separated |
Yes |
| Protected income/collectibility separated |
Yes |
| Program-specific definitions separated |
Yes — mortgage, cards, bankruptcy, tax collection, COD tax |
| Worked examples show assumptions/intermediate arithmetic |
Yes |
| Fifty-state coverage falsely claimed |
No |
| Tribal coverage falsely claimed |
No |
| Private borrower data accessed |
No |
| Private creditor account accessed |
No |
| Local/shared-library write claimed |
No |
| Independent legal/tax review claimed |
No — this is the researcher's source/coverage self-check only |
The strongest publication-safe formulation for A007 is therefore:
A debt situation is measured by reconciling verified liabilities, legal status, assets and collection exposure with both actual cash flow and the specific affordability formula—if any—that governs the decision being considered. DTI, net worth, statutory disposable income, protected income, and household surplus are different measures and should remain different.
That statement is supported across the primary mortgage, card, bankruptcy, collection, tax, garnishment, federal-benefit, state debt-adjusting, and actual-contract authorities reviewed in R007. 1