FIND THE EXPLANATION
Treat the purchase, financing, promotion, and refund as connected records with different obligations.
Read the complete guide →This address preserves a dated source document behind the guide. The complete explanation covers the questions, comparisons and next steps for this subject.
If you came here to check a specific citation, open the original archive below. It includes its source dates and recorded qualifications.
The explanation above is written for readers. These original working documents preserve the evidence trail, including technical language, dated passages and known corrections. They have not all received independent professional review. Use the marked limits before relying on a particular rule or figure.
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.
The Holder Rule preserves qualifying seller-related claims and defenses through specified financing arrangements. Coverage, the existence of an underlying claim, and the relief available against a holder are separate questions. A notice does not establish that the seller violated the law, and the rule’s recovery limitation does not establish an award. The FTC’s Commission opinions recognize both defensive use and affirmative recovery, subject to the underlying claim and the applicable legal framework. ecfr.gov+2
A consequential coverage distinction emerged from the historical primary materials: the Commission expressly distinguished seller-issued credit cards from non-seller credit cards in its 1977 notice. Consequently, an unqualified statement that every credit-card transaction is excluded would be too broad. That distinction also reinforces why a BNPL label cannot resolve coverage.
This is a completed, bounded reference investigation with the source-access and application holds identified below. It is not component, parent, operational, or publication acceptance.
| Item | Recorded scope or limitation |
|---|---|
| Actual source-access date | October 27, 2026, America/Los_Angeles. A public-web clock check during the research returned 3:24:56 p.m. PDT. |
| Operative regulation read | Complete displayed 16 CFR Part 433, including every definition in § 433.1, both notice provisions in § 433.2, and the complete historical-contract exception in § 433.3. |
| eCFR version limit | The complete Part 433 page and the separate § 433.2 page displayed currency through October 23, 2026. The separately retrieved § 433.3 page displayed October 22, 2026. The complete-part retrieval included § 433.3. Neither a retrieval date nor a title-wide amendment date proves that every intervening Federal Register issue has been audited. |
| U.S. Code version limit | The successful House compilations identified their coverage as laws in effect through Public Law 119-121, October 9, 2026. That is a compilation boundary, not certification of a complete October 27 session-law audit. |
| Foundations | No prior report, other research chat, unreviewed Library output, or coordinator finding supplied a premise. |
| Method | Public authority research only. No local files, coordinator records, hashes, imports, subagents, browser control, API research, contacts, filings, or publication. |
| Individual information | No borrower, customer, seller, lender, account, property, licensing, or other party-specific investigation. No identifiers were entered into a records-search system. |
| Court-opinion limitation | An official published-opinion candidate was located, but its body could not be retrieved through the attempted official URLs. No holding, disposition, or later litigation history from that opinion is adopted here. Incidental case-navigation search results were not opened or used. |
| Model/UI provenance | No user-interface model selector or model label was inspected. This report makes no claim of verified GPT-6 Pro UI provenance. |
| Calculations | No recovery, award, deadline, or legal-calendar calculation was necessary or performed. Historical effective dates below are source statements, not calculated consumer deadlines. |
The eCFR expressly identifies itself as an authoritative but unofficial editorial compilation rather than the official legal edition. The different displayed currency dates are preserved above. ecfr.gov+3
Full identifiers appear in the source and claim tables. Elsewhere, S001, C001, H001, and E01 abbreviate the corresponding R012-P1 identifiers.
Authority labels:
All entries were accessed or attempted October 27, 2026, PDT. “PDF index” means the zero-based page index. Multiple sections, mirrors, landing pages, and formats of the same document are grouped; they are not independent corroboration.
| Source ID | Issuer / title | Complete literal HTTPS URL(s) | Exact read bounds / pinpoints | Version, jurisdiction, status, and limits |
|---|---|---|---|---|
| R012-P1-S001 | OFR/GPO, eCFR — 16 CFR Part 433, Preservation of Consumers’ Claims and Defenses | https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-433 ; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-433/section-433.2 ; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-433/section-433.3 | Complete Part 433 body: §§ 433.1(a)–(j), 433.2(a)–(b), 433.3(a)–(b)(4), authority and source notes. HTML; no PDF index. | Fresh complete body read. U.S. federal regulation. Complete-part/§ 433.2 pages through October 23; separate § 433.3 through October 22. A separate § 433.1 URL later encountered an access screen; its complete body had already been read in the part. ecfr.gov+2 |
| R012-P1-S002 | Congress / House OLRC — 15 USC 44 and 45, necessary FTC Act definitions and jurisdiction | https://uscode.house.gov/us/usc/119-121/t15/s44/ ; https://uscode.house.gov/us/usc/119-121/t15/s45/ | § 44 definitions, particularly commerce, corporation, and banks; § 45(a)(1)–(2) complete clauses. Adjacent § 45(a)(3)–(4) encountered, but no international-law conclusion drawn. HTML. | Fresh selected statute read. U.S. federal. Through PL 119-121, October 9, 2026. Full FTC enforcement/remedies framework excluded. uscode.house.gov+1 |
| R012-P1-S003 | Congress / House OLRC — 15 USC 1602 and 1605, necessary TILA definitions | https://uscode.house.gov/us/usc/119-121/t15/s1602/ ; https://uscode.house.gov/us/usc/119-121/t15/s1605/ | § 1602(f)–(i), with adjacent card definitions; complete § 1605(a), including its cash-comparison and closing-agent qualifications. § 1605(b)–(e) also displayed/read, without a comprehensive charge-classification conclusion. HTML. | Fresh selected statute read. U.S. federal. Through PL 119-121, October 9, 2026. Earlier query-form URLs failed; successful publication-specific URLs recovered the necessary text. No full TILA/product classification. uscode.house.gov+1 |
| R012-P1-S004 | OFR/GPO, eCFR — 12 CFR 1026.2, necessary Reg Z definitions | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.2 | § 1026.2(a)(12), (14), complete (16), and complete (17)(i)–(v); adjacent definitions inspected for context. HTML. | Fresh selected regulation read. U.S. federal. Displayed through October 23, 2026. Borrowed-definition work only; not an approval of every current Reg Z provision or product. ecfr.gov+1 |
| R012-P1-S005 | OFR/GPO, eCFR — 12 CFR 1026.4, necessary finance-charge definition | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.4 | Complete § 1026.4(a)(1)–(3); (b) introduction and ordinary retail-credit examples; (c)(1)–(2). Additional displayed exclusions were inspected but are not a full fee audit. HTML. | Fresh selected regulation read. U.S. federal. Displayed through October 23, 2026. Actual finance-charge classification remains unknown. ecfr.gov+2 |
| R012-P1-S006 | CFPB — Supplement I official interpretations of § 1026.2 | https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-2/ | Complete comments 2(a)(16)-1 through -5; 2(a)(17)(i)-1 and -2; related general creditor discussion. HTML. | Fresh selected official-commentary read. U.S. federal. Agency presentation; not an independent current-CFR-edition audit. Complete eCFR appendix retrieval exceeded the tool’s size limit. No CFPB circular, bulletin, or separate advisory was used. Consumer Financial Protection Bureau |
| Source ID | Issuer / title | Complete literal HTTPS URL(s) | Exact read bounds / pinpoints | Version, jurisdiction, status, and limits |
|---|---|---|---|---|
| R012-P1-S007 | FTC — 1975 final rule and Statement of Basis and Purpose, 40 FR 53506 | https://www.ftc.gov/system/files/documents/federal_register_notices/1975/11/40_fr_53506.pdf | Pixels read: printed p. 53506, PDF index 0; pp. 53523–53528, indices 17–22. Index 24, p. 53530, was also seen but its dissent material is not relied on. Necessary operative clauses and relevant majority discussion were read; the entire 25-page package was not. | Fresh selected historical final-rule/SBP read. U.S. federal. Promulgated November 14, published November 18, 1975; stated effective date May 14, 1976. PDF text extraction returned zero lines; screenshots supplied the successful read. Later correction and interpretations control identified conflicts. |
| R012-P1-S008 | FTC — 1975 correction, 40 FR 58131 | https://www.ftc.gov/system/files/documents/federal_register_notices/1975/12/40_fr_58131.pdf | Printed p. 58131, PDF index 0; both Part 433 correction blocks read in text and pixels. Unrelated aviation/securities material excluded. | Fresh historical correction read. U.S. federal. Published December 15, 1975. Includes correction of the purchase-money notice’s reference to services; no new recovery regime. ftc.gov |
| R012-P1-S009 | FTC Bureau of Consumer Protection — Staff Guidelines, May 4, 1976, corrected electronic pamphlet | https://www.ftc.gov/system/files/documents/rules/holder-due-course-rule/760504hidcrule.pdf | Complete parsed pamphlet read, PDF indices 0–12. Printed pp. 1–19 occupy indices 2–11, generally two printed pages per PDF page. Principal pinpoints: pp. 2, 6–9, 10–17, 18–19. Pixels seen only at index 6, printed pp. 8–9, including the strikeout/correction note. | Fresh staff guidance, not Commission-adopted interpretation. U.S. federal. Preface expressly disclaims formal Commission adoption. Its dollar-ceiling statement was corrected in 2021; its card discussion must be read with the later 1977 Commission clarification. ftc.gov+4 |
| R012-P1-S010 | FTC — Statement of Enforcement Policy, 41 FR 34594, August 16, 1976 | https://www.govinfo.gov/content/pkg/FR-1976-08-16/pdf/FR-1976-08-16.pdf ; https://www.federalregister.gov/citation/41-FR-34594 | No complete body read. Full-issue PDF exceeded retrieval size; citation route unavailable. Search excerpts and the 2022 opinion’s citation established a research lead only. Printed opening pinpoint 34594; usable PDF index not established. | Discovery/access failure. U.S. federal historical Commission policy. Its detailed referral/cooperation interpretation is not represented as freshly verified. Borderline referral cases remain held. |
| R012-P1-S011 | FTC — 1977 two-party open-end exemption and invitation to comment, 42 FR 19487–19490 | https://www.ftc.gov/system/files/documents/federal_register_notices/1977/04/42_fr_19490.pdf | Relevant notice visually read across all four PDF pages, indices 0–3, printed pp. 19487–19490. Critical: p. 19488 n.2, seller versus non-seller cards; p. 19490, adopted § 433.3. Appended petition distinguished from adopted text. | Fresh historical agency action/interpretation. U.S. federal. Published April 14, 1977; immediate exemption then keyed to contracts before August 1, 1977. Later modified by S012. |
| R012-P1-S012 | FTC — 1977 modification; denial of permanent exemption, 42 FR 46509–46510 | https://www.ftc.gov/system/files/documents/federal_register_notices/1977/09/42_fr_46510.pdf | Complete relevant majority notice and amendatory text, printed pp. 46509–46510, PDF indices 0–1, read in text and pixels. Separate dissent following the operative text is not the adopted rule. | Fresh historical final modification. U.S. federal. Published September 16, 1977; historical-contract cutoff moved to before November 1, 1977. Broader permanent exemption denied. ftc.gov+1 |
| R012-P1-S013 | FTC — 1988 regulatory-flexibility review, 53 FR 44456–44457 | https://www.govinfo.gov/content/pkg/FR-1988-11-03/pdf/FR-1988-11-03.pdf ; https://archives.federalregister.gov/issue_slice/1988/11/3/44438-44458.pdf ; https://www.federalregister.gov/citation/53-FR-44456 | Original body not read. Full PDF exceeded retrieval size; archival slice unavailable; citation route returned an access/CAPTCHA page. No challenge interaction attempted. | Access failure. U.S. federal historical review. S015’s footnote 46 provides a Commission account of the earlier decision; that account is not substituted for a claimed original-document read. |
| R012-P1-S014 | FTC Commission — May 3, 2012 advisory opinion on affirmative recovery | https://www.ftc.gov/system/files/documents/advisory_opinions/16-c.f.r.part-433-federal-trade-commission-trade-regulation-rule-concerning-preservation-consumers-claims/120510advisoryopinionholderrule.pdf | Complete five-page parsed opinion, printed pp. 1–5, PDF indices 0–4, including footnotes. No pixels inspected. | Fresh Commission advisory opinion. U.S. federal interpretation. Issued May 3, 2012; reiterated in S015. Its descriptions of judicial decisions are not independent reads of those opinions. ftc.gov+3 |
| R012-P1-S015 | FTC — 2019 Confirmation of Rule, 84 FR 18711–18715 | https://www.federalregister.gov/documents/2019/05/02/2019-08886/trade-regulation-rule-concerning-preservation-of-consumers-claims-and-defenses ; https://www.govinfo.gov/content/pkg/FR-2019-05-02/pdf/2019-08886.pdf | Complete relevant HTML body and footnotes read. Official PDF pp. 18711–18712, indices 0–1, parsed; pp. 18713–18715, indices 2–4, visually read. Principal pinpoints: § B; § C.1–6; nn. 2, 5, 26, 28, 32, 36, 46. | Fresh final confirmation/explanation. U.S. federal. Effective May 2, 2019; applicable as of April 23, 2019. Retained without modification. Commentary is distinguished from amendatory text and later fee clarification. federalregister.gov+3 |
| R012-P1-S016 | FTC staff — Staff Note Regarding the Holder Rule and Large Transactions | https://www.ftc.gov/system/files/documents/rules/holder-due-course-rule/p104805_-_holder_rule_2021_staff_note.pdf | Complete three-page parsed note, printed pp. 1–3, PDF indices 0–2. No pixels inspected. | Fresh staff correction. U.S. federal. Dated April 12, 2021; explains that the earlier asserted transaction ceiling was unsupported. Not a newly enacted dollar threshold. ftc.gov+2 |
| R012-P1-S017 | FTC Commission — Statement on the Holder Rule and Attorneys’ Fees and Costs | https://www.ftc.gov/system/files/documents/advisory_opinions/commission-statement-holder-rule-attorneys-fees-costs/p124802_commission_statement_on_the_holder_rule_and_attorneys_fees_and_costs.pdf | Complete four-page parsed opinion, printed pp. 1–4, PDF indices 0–3, including all footnotes. Principal analysis pp. 2–4. No pixels inspected. | Fresh Commission advisory opinion. U.S. federal. January 18, 2022. Clarifies independent fee/cost authority versus seller-only liability passed through the notice. Does not itself award fees or establish a state cause. ftc.gov+2 |
| Source ID | Issuer / title | Complete literal HTTPS URL(s) | Read / failure boundary | Use and limit |
|---|---|---|---|---|
| R012-P1-S018 | FTC — rule and advisory-opinion publication pages | https://www.ftc.gov/legal-library/browse/rules/holder-due-course-rule ; https://www.ftc.gov/legal-library/browse/advisory-opinions/16-cfr-part-433-federal-trade-commission-trade-regulation-rule-concerning-preservation-consumers ; https://www.ftc.gov/legal-library/browse/advisory-opinions/commission-statement-holder-rule-attorneys-fees-costs | Landing pages and linked-document descriptions read. Targeted official-domain amendment/withdrawal searches also performed. | Fresh discovery/status check, U.S. federal. Establishes publication availability and document identity, not exhaustive currentness, absence of litigation, or universal continued judicial acceptance. Federal Trade Commission+2 |
| R012-P1-S019 | Supreme Court of California — Pulliam v. HNL Automotive Inc., published-opinion candidate | https://supreme.courts.ca.gov/sites/default/files/supremecourt/default/2022-08/S267576.pdf ; https://www.courts.ca.gov/opinions/documents/S267576.PDF ; https://www.courts.ca.gov/opinions/archive/S267576.PDF | Official publication found in search; body attempts returned 403 or unavailable. No majority body, pinpoints, disposition, or later history verified. | Discovery/failure only. California. No substantive holding borrowed from snippets, headnotes, FTC footnotes, or incidental docket results. |
| R012-P1-S020 | FTC — Volume 88 index and table of contents, searched as an alternative historical publication route | https://www.ftc.gov/legal-library/browse/cases-proceedings/commission-decision-volumes/volume-88 ; https://www.ftc.gov/sites/default/files/documents/commission_decision_volumes/volume-88/ftc_volume_decision_88_july_-_december_1976_members_of_the_commission_and_table_of_contents.pdf | Index opened; table-of-contents searches did not recover the needed enforcement statement. No substantive opinion from the volume used. | Discovery only. U.S. federal historical compilation. Unsuccessful keyword searches are not evidence that the statement does not exist. |
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions, status, and limits |
|---|---|---|---|
| R012-P1-C001 | Currency: the complete Part 433 retrieval displayed October 23, 2026 currency. | S001, page banner and complete part. | Observed source status. Access on October 27 does not eliminate the intervening-currentness hold. |
| R012-P1-C002 | Statute version: the successful House text was bounded by PL 119-121, October 9, 2026. | S002–S003, compilation headers. | Observed source status. No later session-law audit claimed. |
| R012-P1-C003 | Command: § 433.2 addresses a seller’s specified practices in consumer goods/services transactions affecting statutory commerce. | S001, § 433.2 introduction; S002, §§ 44, 45(a)(1). | Regulation/statute. Actual commerce and actor predicates remain unknown. |
| R012-P1-C004 | Jurisdiction versus contract: FTC jurisdictional exclusions do not themselves establish immunity from a contract’s preserved claims. | S002, § 45(a)(2); S007, pp. 53523–53524. | The statutory exclusions include banks, specified savings institutions, federal credit unions, and specified carrier/regulated activities. Do not equate regulatory jurisdiction with contractual-holder liability. |
| R012-P1-C005 | Person/consumer: the rule’s person definition includes business organizations; its consumer definition requires a natural person seeking or acquiring personal, family, or household goods/services. | S001, § 433.1(a)–(b). | Regulation. These definitions perform different roles. |
| R012-P1-C006 | Seller: ordinary-course selling or leasing of consumer goods/services is required. | S001, § 433.1(j). | Regulation. A marketing label or platform role is insufficient. |
| R012-P1-C007 | Creditor: § 433.1(c) addresses ordinary-course purchase-money lending or deferred-sale financing, with a transaction-specific card-issuer proviso. | S001, § 433.1(c), (h). | Regulation. Apply with C025’s seller/non-seller distinction. |
| R012-P1-C008 | Instrument: a consumer credit contract evidences or embodies debt from either defined financing route. | S001, § 433.1(i). | Regulation. A payment schedule alone does not establish the required transaction. |
| R012-P1-C009 | Purchase-money route: requires a consumer cash advance for a TILA/Reg Z finance charge, substantially or wholly applied to a purchase, plus the specified seller-creditor connection. | S001, § 433.1(d)(1)–(2). | Regulation. All predicates matter; product and arrangement unknown. |
| R012-P1-C010 | Financed-sale route: § 433.1(e) borrows the TILA/Reg Z credit-sale concept. | S001, § 433.1(e); S003, § 1602(h); S004, § 1026.2(a)(16). | Regulation/statute. Seller-as-creditor classification must be established. |
| R012-P1-C011 | Ordinary Reg Z creditor test: requires regular qualifying consumer-credit extensions and initial payability to that creditor. | S003, § 1602(g); S004, § 1026.2(a)(17)(i), (v). | For the ordinary test, qualifying terms involve a finance charge or a written agreement for more than four installments, excluding a down payment. Other tests exist; this is not a complete BNPL test. |
| R012-P1-C012 | Installment labels: installment count, deferral, or a pay-in-four label does not by itself establish either Holder Rule route. | S001, § 433.1(d)–(e); S003–S005. | Inference. No universal inclusion or exclusion of BNPL follows. |
| R012-P1-C013 | Finance charge: actual credit-related charges, including indirect charges, must be classified; comparable cash charges are excluded from the basic definition. | S003, § 1605(a); S005, § 1026.4(a). | Statute/regulation. An advertised zero-interest rate does not complete that inquiry. |
| R012-P1-C014 | Late-charge qualification: the cited exclusion concerns actual unanticipated late-payment/default-type charges. | S005, § 1026.4(c)(2). | Regulation. A charge’s name alone does not establish the exclusion. No actual fee classified. |
| R012-P1-C015 | Arranging versus selling on credit: seller assistance with a loan initially payable to a financial institution is not itself a Reg Z credit sale. | S006, comment 2(a)(16)-2. | Official interpretation. The separate § 433.1(d) purchase-money route may still matter. |
| R012-P1-C016 | Immediate assignment: simultaneous assignment does not, by itself, change the initially payable party under the cited Reg Z creditor test. | S006, comment 2(a)(17)(i)-2. | Official interpretation. Contract structure remains necessary evidence. |
| R012-P1-C017 | Seller-creditor link: the rule includes referral and common-control, contractual, or business-arrangement alternatives; arrangements may be informal. | S001, § 433.1(d), (f)–(g). | Regulation. Detailed unilateral-steering/cooperation boundaries remain held because S010 was not fully retrieved. |
| R012-P1-C018 | Unrelated relationship: ordinary commercial dealings alone do not establish the required sales-financing affiliation under staff’s explanation. | S009, printed pp. 16–17. | Staff guidance. No actual relationship assessed. |
| R012-P1-C019 | No invented numeric shortcut: Part 433 supplies no percentage definition of substantial application and no numeric referral quota. | S001, complete § 433.1. | Text-based inference. An invented threshold cannot replace the factual/legal inquiry. |
| R012-P1-C020 | Independent loan: spending independently obtained loan proceeds at a retailer does not alone establish the purchase-money connection. | S001, § 433.1(d); S009, pp. 12–13. | Conditional coverage conclusion. Stipulated absence of both relationship alternatives defeats that route, not every possible claim. |
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions, status, and limits |
|---|---|---|---|
| R012-P1-C021 | Purpose/person: purely commercial purchases and organizational purchasers do not satisfy the ordinary consumer coverage described here. | S001, § 433.1(b); S009, p. 9. | Regulation/staff explanation. Mixed-purpose facts remain unresolved. |
| R012-P1-C022 | Real estate: buying an interest in real property differs from financing consumer goods/services secured by real property. | S009, p. 9; S007, p. 53525. | Historical official explanation. A home-improvement purchase is not automatically excluded merely because real estate secures payment. |
| R012-P1-C023 | Other historical exclusions: staff identifies securities and commodities purchases as outside its goods/services coverage discussion. | S009, p. 9. | Staff guidance. Its separate public-utility statement is not converted here into a fully audited modern sector exemption. |
| R012-P1-C024 | Leases: only qualifying debt/credit-sale arrangements satisfy this route; a lease label is insufficient. | S003, § 1602(h); S004, § 1026.2(a)(16)(i)–(ii); S015, p. 18713 n.26. | The Reg Z lease branch requires the specified value-based payment commitment and ownership/nominal-option terms, and excludes leases terminable without penalty at any time. Not all leases qualify. |
| R012-P1-C025 | Cards: the 1977 Commission explanation expressly distinguishes excluded non-seller card lending from seller-issued card financing under the financed-sale route. | S011, p. 19488 n.2. | Commission interpretation. Retailer branding does not identify the legal issuer or financing route. |
| R012-P1-C026 | Historical-contract exception: § 433.3 protects only its specified pre-November 1, 1977 open-end contracts that do not cut off claims/defenses. | S001, § 433.3(a), (b)(2)–(4); S012, p. 46510. | Requires the defined open-end arrangement and absence of negotiability or limiting terms described in (b)(4). Its open-end definition excludes specified negotiated mortgage advances and letters of credit. No general modern exemption. |
| R012-P1-C027 | Transaction size: the Holder Rule contains no maximum transaction-value exemption of the kind asserted in the old staff pamphlet. | S016, pp. 1–3; S007, p. 53527. | Text plus staff correction. Do not import TILA’s separate dollar exemption wholesale. ftc.gov |
| R012-P1-C028 | § 433.2(a): a seller may not take or receive a covered contract lacking the prescribed notice. | S001, § 433.2(a). | Regulation. Direct or indirect seller conduct; antecedent coverage required. |
| R012-P1-C029 | § 433.2(b): a seller may not accept qualifying loan proceeds toward payment unless the associated consumer credit contract contains the prescribed notice. | S001, § 433.2(b). | Regulation. Applies to partial as well as complete payment; not merely to loans later assigned. |
| R012-P1-C030 | Notice form: both regulatory versions require their prescribed provision in bold type of at least ten points. | S001, § 433.2(a)–(b). | Regulation. The versions’ wording differs; see § 4 below. Actual font and contract unknown. |
| R012-P1-C031 | Location: staff permits any location that makes the notice clearly part of the credit contract. | S009, p. 17. | Staff guidance. No actual document-format approval; Part 433 contains no separate notice-signature command. |
| R012-P1-C032 | Multiple instruments: staff permits appropriate incorporation by reference when the documentation clearly subjects the obligation to the notice. | S009, pp. 10, 17–18. | Staff guidance. A detached disclosure or ambiguous reference is not automatically sufficient. |
| R012-P1-C033 | Qualification/waiver: additional language restricting the required notice conflicts with staff’s unqualified-notice explanation and the Commission’s stated anti-cutoff purpose. | S009, p. 6; S015, § C.5, pp. 18714–18715. | Interpretive finding. Does not adjudicate every later settlement, release, arbitration term, or waiver question. |
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions, status, and limits |
|---|---|---|---|
| R012-P1-C034 | Preserved subject matter: legally sufficient seller-related claims/defenses concerning the financed transaction can be asserted against a holder through the notice. | S014, p. 2; S009, pp. 7–8. | Commission/staff interpretation. An unrelated dispute with the seller is not automatically transferred. |
| R012-P1-C035 | Underlying merits: the rule does not create a new substantive seller claim merely because financing exists. | S014, p. 2; S007, p. 53524. | Commission explanation. Applicable substantive law and proof remain necessary. |
| R012-P1-C036 | Defensive use: preserved claims may defeat or reduce an asserted unpaid obligation. | S014, pp. 2–4. | Commission interpretation. Extent depends on the claim; no automatic payment-suspension or cancellation instruction follows. |
| R012-P1-C037 | Affirmative use: the Commission recognizes a claim for return of money already paid under the relevant contract. | S014, pp. 2–5. | Commission interpretation. A valid underlying basis and applicable procedural rules remain required. |
| R012-P1-C038 | Monetary ceiling: notice-derived affirmative recovery is limited by the debtor’s payments under the relevant contract. | S001, § 433.2, final sentence of each notice; S014, p. 5. | Regulation/interpretation. Face amount, remaining balance, and the assignee’s purchase price are not substitutes for that textual measure. |
| R012-P1-C039 | Down payments: staff distinguishes a payment under the installment-sale contract from a separate seller payment outside a direct-loan contract. | S009, p. 7. | Staff guidance. Contract attribution is necessary; no universal inclusion of every cash down payment. |
| R012-P1-C040 | Rescission: the Commission rejects a universal requirement of rescission entitlement or worthless goods before affirmative recovery. | S014, pp. 3–5; S015, § B, p. 18712. | Commission interpretation. This does not create an independent rescission right or establish every court’s treatment. ftc.gov |
| R012-P1-C041 | Independent liability: the notice’s limitation does not erase independently available rights against the holder. | S017, pp. 2–3. | Commission interpretation. A separate cause and its elements must actually apply. |
| R012-P1-C042 | Independent fees/costs: applicable law may authorize an award against the holder because of its own litigation role, outside the notice-derived ceiling. | S017, pp. 2–3. | Commission interpretation. Requires that law’s entitlement, party, success, and other predicates; no universal award. |
| R012-P1-C043 | Seller-only fees/costs: liability available only against the seller and transmitted through the notice remains within the derivative recovery limit; offsets are separately recognized. | S017, p. 3; S015, § C.3, p. 18713. | Commission interpretation. Relabeling derivative liability as fees does not create a fresh uncapped allowance. ftc.gov |
| R012-P1-C044 | Nonmonetary relief: the Commission does not read the monetary sentence as categorically barring other forms of relief. | S015, p. 18713 n.32; S017, p. 4 n.7. | Commission interpretation. Entitlement to any injunction or other remedy remains a separate question. |
| R012-P1-C045 | Omitted notice: required omission is a compliance problem, but absence does not establish that all seller-related claims against a holder are extinguished. | S001, § 433.2; S015, § C.4, p. 18714. | Regulation/Commission explanation. State-law incorporation or other preservation requires separate authority; no universal automatic insertion conclusion. |
| R012-P1-C046 | Notice present: inclusion alone does not establish mandatory rule coverage, a valid underlying claim, or overall legal compliance. | S001; S014, p. 2. | Inference. The effect of voluntarily included wording outside mandatory coverage is a separate contract/state-law question. |
| R012-P1-C047 | Time: Part 433 supplies no universal consumer assertion or filing period. | S001, complete rule; S009, pp. 7–8. | Text-based inference/staff explanation. Applicable limitation, accrual, tolling, recoupment, and procedural law are unresolved; defensive and affirmative uses must be examined separately. |
| R012-P1-C048 | Paid-amount uncertainty: this investigation establishes no actual payment total or treatment of disputed payment components. | S001, notice limitation; C039. | Unknown. Refunds, credits, trade-ins, third-party payments, finance charges, and separate-contract payments require tracing and legal classification. |
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions, status, and limits |
|---|---|---|---|
| R012-P1-C049 | Original timing: the rule was promulgated November 14, published November 18, 1975, with May 14, 1976 effectiveness. | S007, p. 53506; S009, pp. 2, 19. | Historical agency dates. No consumer deadline calculated. |
| R012-P1-C050 | Correction: the December 1975 correction repaired wording and citations, including the purchase-money notice’s services reference. | S008, p. 58131. | Historical correction. Use current corrected text. |
| R012-P1-C051 | Staff status: the 1976 pamphlet expressly states it was informal, advisory, and not formally adopted by the Commission. | S009, printed p. 2. | Authority-status finding. It cannot silently override regulation or later Commission action. |
| R012-P1-C052 | 1976 policy gap: detailed Commission enforcement-policy treatment of seller-creditor relationships was not fully recovered. | S010; S017, p. 2 n.3. | Access hold. Search text is not a substitute for the body. |
| R012-P1-C053 | 1977 changes: the April cutoff was subsequently changed; the September action denied the requested broader permanent exemption. | S011, pp. 19487–19490; S012, pp. 46509–46510. | Historical final actions. Current § 433.3, not the earlier cutoff or petition appendix, supplies the displayed operative text. |
| R012-P1-C054 | 1988 gap: the original review notice was not read; its reported disposition appears in the 2019 Commission notice. | S013; S015, p. 18715 n.46. | Agency account plus access hold. No claim of fresh original-1988 verification. |
| R012-P1-C055 | 2019 action: the Commission retained the rule unchanged; the action states May 2 effectiveness and April 23, 2019 applicability. | S015, opening dates, introduction, conclusion. | Final confirmation. Not a newly adopted collection-notice or lender-insertion amendment. |
| R012-P1-C056 | 2012 status: the affirmative-recovery opinion is Commission interpretation, reiterated in 2019. | S014; S015, § B. | It is not a declaration that every contrary judicial application has been overruled. |
| R012-P1-C057 | 2021 status: the dollar-ceiling correction explains the existing rule rather than establishing a new transaction ceiling. | S016, pp. 1–3. | Staff correction. Historical pamphlet language is not current authority for a ceiling. |
| R012-P1-C058 | 2022 status: the fee opinion clarifies independent versus derivative liability without amending Part 433. | S017, pp. 2–4; S001. | Commission advisory interpretation. Fee entitlement remains dependent on separate law. |
| R012-P1-C059 | Judicial hold: no published judicial majority holding or later case history is established by this pass. | S019, retrieval failures. | Unknown. FTC descriptions of cases were not promoted into independently verified holdings. |
| R012-P1-C060 | BNPL hold: no complete BNPL, marketplace, digital-account, or pay-in-four classification is established. | C008–C017, C025. | Inference/scope hold. Actual instruments, payment obligations, charges, issuer roles, and arrangements remain unknown. |
| R012-P1-C061 | Currentness hold: targeted official searches and current publication pages do not prove exhaustive absence of later amendments, withdrawals, stays, or vacatur. | S001–S006, S018. | Research limitation. No such unverified status is assigned. |
| R012-P1-C062 | Unadopted expansion: the 2019 review did not adopt suggested additional consumer communications or broader direct lender notice duties. | S015, § C.1, C.6. | Final-review finding. Other laws may impose duties; those are not resolved here. |
| R012-P1-C063 | Card-source tension: broad card-exclusion shorthand must be qualified by the 1977 Commission’s express seller/non-seller explanation. | S009, p. 10; S011, p. 19488 n.2; S015, p. 18711 n.2. | Source reconciliation. No 2019 textual amendment eliminating the distinction was adopted. Specific products remain held. |
| R012-P1-C064 | Application boundary: none of these generic findings establishes actual liability, standing, recoverable amount, eligibility, or a filing decision. | Scope of this investigation; C035, C045–C048, C059–C061. | Explicit hold. No individual facts were investigated. |
The complete prescribed provisions were read in § 433.2. The following is an analytical comparison, not substitute notice language.
| Feature | § 433.2(a) | § 433.2(b) | Audit implication |
|---|---|---|---|
| Seller event | Taking or receiving the covered consumer credit contract. | Accepting qualifying purchase-money proceeds toward the sale or lease. | Identify the actual route and event; C028–C029. |
| First sentence, paraphrased | Makes a holder subject to the debtor’s seller-related claims and defenses for goods/services obtained under the contract or through its proceeds. | Makes a holder subject to the debtor’s seller-related claims and defenses for goods/services obtained through the loan proceeds. | Compare the entire provision with the regulation. |
| Exact distinguishing fragment | Includes “PURSUANT HERETO OR”. | Omits those words. | Do not treat the two forms as textually identical. |
| Exact proceeds fragment | “WITH THE PROCEEDS HEREOF”. | Same fragment. | The relationship to the financed purchase remains material. |
| Final sentence | Same in both versions; quoted below. | Same. | Establish the relevant contract and payments before considering its monetary limitation. |
| Form | Prescribed notice, headed “NOTICE”, in bold type of at least ten points. | Same express type-size/bold requirement. | Neither parsed text nor this chat establishes the font in an actual agreement. |
| Location / multiple documents | C031–C032. | C031–C032. | Staff’s clear-contract-term standard does not approve ambiguous incorporation. |
The common final sentence is:
RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.
These limited quotations and the comparison are tied to the complete operative provision at https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-433/section-433.2. ecfr.gov
Assent remains separate. Part 433’s insertion requirement does not establish whether an actual electronic presentation, linked document, signature process, or later modification became an enforceable contract term under the governing law. No such process was examined.
“Covered” below means the stipulated facts satisfy the identified generic route. It does not mean the consumer has proved a claim or is entitled to relief.
| Generic pattern | Result within this pass | Critical discriminator | Claim / example links |
|---|---|---|---|
| Direct seller installment sale, with qualifying consumer-credit terms and instrument | Covered route established by stipulation | Seller’s legal role and credit-sale predicates | C005–C011, C028; E01 |
| Seller and lender cooperate to provide a finance-charge loan substantially financing that seller’s goods/services | Covered purchase-money route established by stipulation | Complete § 433.1(d) predicates, not merely a checkout financing button | C009, C017, C029; E02 |
| Consumer independently obtains cash credit; no seller referral or qualifying affiliation | Purchase-money route not established | Stipulated absence of the required connection | C020; E03 |
| Occasional recommendation or one-sided steering, cooperation facts unclear | Unresolved edge | S010 body gap and unknown course of dealing | C017–C019, C052; E12 |
| Pure business-purpose equipment purchase | Consumer route fails on stipulated purpose | Commercial purpose, notwithstanding installment payments | C021; E04 |
| Purchase by an organization | Ordinary consumer definition fails | Natural-person requirement | C005, C021; E04 |
| Financing acquisition of an interest in land | Outside the goods/services framework discussed here | Subject of purchase | C022; E05 |
| Consumer home-improvement goods/services financed with a real-estate lien | Potentially covered | The purchase and financing predicates, not collateral alone | C022; E05 |
| Purchase financed through a non-seller credit-card issuer acting in that capacity | Card exclusion relevant | Actual issuer role and transaction structure | C007, C025; E13 |
| Seller’s own card used for a qualifying seller-financed purchase | Potentially covered financed-sale route | Express 1977 distinction | C025, C063; E13 |
| Retailer-branded card with issuer and initial payee unknown | Unknown | Branding does not resolve the two preceding rows | C016, C025, C060 |
| Lease satisfying all borrowed credit-sale conditions | Potentially covered | Full lease conditions and credit-contract predicates | C024; E15 |
| Ordinary lease failing those conditions | This credit-sale route fails | No automatic coverage from the word lease | C024; E15 |
| BNPL/pay-in-four/deferred-payment/marketplace product without its legal structure | Unknown | Charges, instruments, roles, seller connection, card status | C012–C017, C060; E10 |
| Large-dollar consumer purchase otherwise satisfying coverage | No size-only exclusion established | Corrected historical guidance | C027, C057; E14 |
| Notice voluntarily appears in an otherwise uncovered arrangement | Mandatory coverage unproved; contractual effect unresolved | Separate incorporation and governing-law analysis | C046; E06 |
This matrix applies the claim register; it does not classify any existing product.
Every finding field is intentionally blank. This is an audit design, not a request to obtain records or enter identifiers.
| Field | Blank finding | Question / evidence category needed | Related claims |
|---|---|---|---|
| W01 — Applicable jurisdiction | ______ | Which substantive, contract, and procedural laws would govern? | C035, C047 |
| W02 — Relevant legal version | ______ | Which enactment, effective date, and source currency apply to the transaction? | C001–C002, C049–C061 |
| W03 — Purchaser category | ______ | Natural person or organization? | C005, C021 |
| W04 — Purchase purpose | ______ | Personal/family/household, commercial, or mixed? | C005, C021 |
| W05 — Purchased subject | ______ | Goods, services, real-property interest, securities, commodities, or mixed transaction? | C006, C022–C024 |
| W06 — Seller role | ______ | Who performs the legal seller role, and is it ordinary-course activity? | C006 |
| W07 — FTC jurisdiction predicate | ______ | Relevant commerce and actor-jurisdiction questions? | C003–C004 |
| W08 — Initial obligation structure | ______ | Credit sale, loan, qualifying lease, other arrangement, or unresolved? | C008–C016 |
| W09 — Initial payability | ______ | To whom is the debt initially payable under the instrument? | C011, C015–C016 |
| W10 — Qualifying credit terms | ______ | Finance-charge and installment obligations; applicable creditor test? | C011–C014 |
| W11 — Card capacity | ______ | Seller-issued versus non-seller-issued financing; actual transaction capacity? | C007, C025 |
| W12 — Purchase-money use | ______ | Is the advance substantially or wholly applied to the relevant purchase? | C009, C019 |
| W13 — Referral facts | ______ | Nature, repetition, and cooperation involved in referrals? | C017, C052 |
| W14 — Affiliation facts | ______ | Common control, express agreement, informal understanding, or course of dealing? | C017–C018 |
| W15 — Historical exception | ______ | Any genuine § 433.3 issue, including all non-cutoff conditions? | C026 |
| W16 — Complete instrument set | ______ | Which documents embody the obligation and are incorporated? | C008, C032 |
| W17 — Correct notice version | ______ | Is the applicable § 433.2(a) or (b) wording complete? | C028–C030 |
| W18 — Notice typography | ______ | Actual bold type and point size; reliable visual/document evidence? | C030 |
| W19 — Notice placement | ______ | Clearly a contract term, including any cross-reference? | C031–C032 |
| W20 — Contradictory terms | ______ | Any purported restriction of preserved claims or defenses? | C033 |
| W21 — Assent/incorporation | ______ | Applicable contract law and actual presentation/acceptance evidence? | C031–C032, C046 |
| W22 — Holder relationship | ______ | Relevant contract, assignment chain, and capacity in which rights are asserted? | C034, C038 |
| W23 — Underlying seller claim | ______ | Exact cause/defense, elements, breach, causation, injury, and available relief? | C034–C035 |
| W24 — Transaction linkage | ______ | Does the claim concern the financed purchase or a separate dealing? | C034 |
| W25 — Desired legal use | ______ | Defense, setoff, affirmative recovery, nonmonetary relief, or separate liability? | C036–C044 |
| W26 — Payment attribution | ______ | Payments under this contract versus other agreements; no amount assumed? | C038–C039, C048 |
| W27 — Payment components | ______ | Principal, interest, fees, down payment, trade-in, credits, refunds, and third-party payments? | C048 |
| W28 — Independent holder conduct | ______ | Separate legal duty and facts, if any? | C041 |
| W29 — Attorney-fee/cost authority | ______ | Statute/contract/rule; against which party; success and other conditions? | C042–C043 |
| W30 — Time and procedure | ______ | Accrual, limitation, tolling, notice prerequisites, recoupment, forum, and procedural posture? | C047, C059 |
| W31 — Missing-notice consequence | ______ | Applicable incorporation, preservation, or independent-remedy authority? | C045 |
| W32 — Source and court status | ______ | Complete primary text, controlling published opinions, and any later authority still missing? | C052, C054, C059–C061 |
| W33 — Audit disposition | ______ | Which questions are answered, held, or outside this component? | C064 |
These are analytical hypotheticals involving roles only. They contain no actual or invented customer, provider, account, property, or record identifiers. No example supplies a legal award or instruction to stop paying.
| Example | Stipulated facts | Rule-specific result versus unknown | Evidence needed / adverse misclassification |
|---|---|---|---|
| R012-P1-E01 — Direct seller installment | A retail seller enters a qualifying consumer credit sale for household goods; the obligation is initially payable to the seller and later assigned. | The financed-sale notice route applies on these stipulations. Whether the goods were defective and whether a claim succeeds remain unknown. C010–C011, C016, C028, C035. | Need the instrument, initial-payee structure, and underlying claim law. Failure: assuming assignment removes seller-related defenses, or assuming covered financing proves a breach. |
| R012-P1-E02 — Qualifying arranged purchase-money loan | A seller and lender have a cooperative financing arrangement. A consumer receives a finance-charge advance, substantially applies it to the seller’s goods, and the seller accepts those proceeds. | The stipulated purchase-money predicates are met; the § 433.2(b) notice condition matters. Assignment is not a prerequisite to this route. C009, C017, C029. | Need the loan instrument, arrangement, purchase nexus, and charge characterization. Failure: treating every loan made by a separate lender as outside the rule. |
| R012-P1-E03 — Independent cash loan | A consumer chooses an unaffiliated lender independently. The seller neither refers consumers to it nor has the defined affiliation. | The stipulated transaction fails the seller-connection requirement for the purchase-money route. Other contract or statutory rights remain open. C020. | Need reliable relationship facts. Failure: treating later expenditure of borrowed money at a shop as sufficient coverage. |
| R012-P1-E04 — Business purpose / organizational purchaser | Equipment is purchased exclusively for commercial operations; alternatively, the purchaser is an organization. | The ordinary consumer predicate used in this pass fails. A mixed-purpose transaction would require a different analysis. C005, C021. | Need purpose and legal purchaser category. Failure: equating a natural person’s signature, retail setting, or installment schedule with consumer coverage. |
| R012-P1-E05 — Real estate versus real-estate security | One arrangement finances a land interest. Another finances household improvements and takes a real-estate lien. | The two transactions cannot be classified identically merely because both involve real estate. The second still requires all financing predicates. C022. | Need what was purchased and what merely secures repayment. Failure: excluding all secured home-improvement financing, or including every land-acquisition loan. |
| R012-P1-E06 — Notice present, claim unknown | An instrument contains a Holder notice; no legally sufficient seller claim has been established. | The notice alone establishes neither damages nor cancellation. If mandatory coverage is absent, its voluntary contractual effect is also a separate issue. C035, C046. | Need underlying cause, transaction facts, and incorporation law. Failure: treating the notice as a refund guarantee. |
| R012-P1-E07 — Required notice missing | A transaction satisfies the rule, but the relevant contract omits the prescribed provision. | The seller-command issue is identifiable. Whether another law supplies notice-equivalent rights or another remedy remains unresolved. C028–C029, C045. | Need governing incorporation/preservation law and any controlling opinion. Failure: saying omission always destroys claims—or that federal law always inserts the notice automatically. |
| R012-P1-E08 — Affirmative versus defensive use | A legally sufficient seller claim is stipulated. The consumer has an unpaid obligation and has also made some payments. | Defensive reduction and affirmative recovery are distinct analyses. The monetary ceiling does not automatically determine the defensible balance or guarantee repayment of everything paid. C036–C040. | Need underlying relief, payment attribution, and procedural law. Failure: using one undifferentiated recovery cap for every form of relief. |
| R012-P1-E09 — Independent assignee misconduct | A holder is alleged to have committed a separate violation of a law imposing duties directly on it. | The independent theory must be tested on its own elements; the Holder notice is not a universal shield or automatic source of that liability. C041. | Need the independent duty, actor coverage, conduct, injury, and remedy. Failure: capping all holder misconduct at debtor payments merely because the contract also contains a notice. |
| R012-P1-E10 — BNPL classification unknown | A checkout option is described only as BNPL or pay-in-four; its charges, instruments, creditor roles, and legal card status are unspecified. | Coverage is unknown. Neither route is established by the label. C012–C017, C025, C060. | Need actual legal structure and applicable product authority in a separate authorized pass. Failure: declaring all such products covered, excluded, or credit cards. |
| R012-P1-E11 — Attorney fees depend on separate authority | A consumer succeeds on a preserved claim. One possible fee law addresses the holder’s litigation role; another permits liability only against the seller. | Those are materially different routes under the 2022 interpretation. Neither hypothetical establishes an amount or entitlement without the separate authority’s conditions. C042–C043. | Need exact fee statute/contract/rule and posture. Failure: announcing that fees are always capped, always uncapped, or automatically awarded. |
| R012-P1-E12 — Referral edge | A seller recommends a financing source, but repetition, lender agreement, and cooperative activity are unclear. | The borderline relationship remains unresolved, including the S010 source gap. C017–C019, C052. | Need the complete Commission policy and arrangement facts. Failure: treating one recommendation or a fabricated referral quota as dispositive. |
| R012-P1-E13 — Seller card versus branded non-seller card | One seller extends its own qualifying card credit. A different retail purchase uses a card legally issued by a non-seller acting in that role. | The 1977 explanation requires different treatment of the routes; branding does not decide which arrangement exists. C025, C063. | Need issuer capacity and initial debt structure. Failure: applying the shorthand exclusion to every card bearing a retailer’s name. |
| R012-P1-E14 — Large transaction / payment attribution | A large consumer transaction otherwise meets coverage. Some money was paid under a separate sale arrangement rather than the loan instrument at issue. | Size alone supplies no stated ceiling exemption. The separate payment cannot simply be added to a notice-derived recovery measure without attribution analysis. C027, C039, C048. | Need contract boundaries and payment tracing. Failure: relying on the corrected historical dollar exclusion or treating all money spent as money paid under the relevant contract. |
| R012-P1-E15 — Lease and timing | A document is called a lease; termination and ownership terms are unspecified. A later dispute is also alleged to be untimely. | Lease coverage and timeliness are independently unresolved. Part 433 supplies no universal deadline that resolves either affirmative or defensive use. C024, C047. | Need complete lease terms and governing time/recoupment law. Failure: assuming every lease is covered or that expiration of a claim period necessarily answers every defensive-use question. |
| Issue | Materials actually inspected | Resolution for this pass | Remaining limitation |
|---|---|---|---|
| Original rule and correction | S007 selected final-rule/SBP pages; S008 correction; S001 complete current text | Original effective date and corrected notice text distinguished. | Unread historical pages are not represented as read. |
| Historical open-end exception | S011 complete relevant notice; S012 majority modification; current § 433.3 | Earlier August cutoff and petition proposals do not replace the displayed November 1, 1977 cutoff and conditions. | No actual old contract assessed. |
| Credit-card shorthand | S009’s broad staff wording; S011 p. 19488 n.2; S015 n.2 | Preserve the express seller/non-seller distinction. | Actual issuer role and any product-specific later authority remain unknown. |
| Transaction-value exemption | S009 corrected page; S016 complete note; S007 p. 53527 | The old staff dollar-ceiling assertion is not retained. | Separate TILA exemptions and product regulation remain outside this pass. |
| Rescission-only affirmative recovery | S007 pp. 53524, 53527; complete S014; S015 § B | Report the Commission’s rejection of that universal restriction. | No determination of controlling judicial treatment in a particular jurisdiction. |
| Attorney fees/costs | Complete S015 discussion and S017 opinion | Distinguish independent authority against the holder from seller-only derivative liability. | Exact state cause, fee law, posture, and judicial authority remain open. |
| Missing notice | S015 § C.4 and current § 433.2 | No categorical extinguishment or universal automatic-insertion conclusion. | State incorporation and remedies require their own primary-law pass. |
| Direct duties on lenders | S009’s historical proposal discussion; S015 § C.6 and n.46; S001 | Current direct command remains addressed to sellers; the 2019 review did not adopt the proposed expansion. | Original 1988 body not retrieved; other-law lender duties excluded. |
| Later status | S018 publication pages and targeted official-domain searches | No subsequently operative change was established by the retrieved materials. | This is not a finding that no later change, withdrawal, stay, or vacatur exists. |
These distinctions are supported by the actual agency texts, including the 1977 card footnote, the 2021 correction, and the 2022 fee analysis. ftc.gov+2
Answered means the bounded generic question is addressed by the identified materials. It does not mean facts are known, a judicial application is settled, or the component is accepted.
| Coverage ID | Assigned subquestion / major branch | Status and claim/example links | Exact missing authority or facts | Next bounded permissible investigation |
|---|---|---|---|---|
| R012-P1-H001 | Complete operative Part 433 | Answered: C003–C010, C026, C028–C030 | Post-displayed-currency audit remains incomplete | Check subsequent official amendments only |
| R012-P1-H002 | Person, consumer, seller, creditor definitions | Answered generically: C005–C007 | Actual roles/purpose | No actual inquiry in this pass |
| R012-P1-H003 | Consumer credit contract / instrument | Answered generically: C008 | Actual complete instrument set | Generic document-structure research if separately needed |
| R012-P1-H004 | Financed-sale definition | Answered: C010–C011; E01 | Actual seller-creditor status | Separate product classification |
| R012-P1-H005 | Purchase-money definition and proceeds | Answered: C009, C029; E02 | Finance charge, use, relationship facts | Generic targeted clause interpretation |
| R012-P1-H006 | Referral boundary | Partial: C017–C019, C052; E12 | Complete S010 body; cooperative-course facts | Recover official 1976 policy and any final modification |
| R012-P1-H007 | Common control / contract / arrangement | Answered text; application held: C017–C018 | Actual relationship; S010 edge interpretation | Same bounded policy inquiry |
| R012-P1-H008 | Independent lender loan | Answered conditionally: C020; E03 | Whether independence is true | No actual provider inquiry authorized |
| R012-P1-H009 | Business and organizational purchases | Answered for stipulated pure cases: C021; E04 | Mixed purpose, purchaser category | Narrow mixed-purpose primary-law study |
| R012-P1-H010 | Real-estate purchase exclusion | Answered at generic boundary: C022; E05 | Nature of purchased interest | Product-specific real-property classification remains separate |
| R012-P1-H011 | Real-estate-secured goods/services | Answered conditionally: C022; E05 | Purchase and financing predicates | Narrow home-improvement financing law if assigned |
| R012-P1-H012 | Credit-card purchases | Answered distinction; product held: C025, C063; E13 | Actual issuer and transaction role | Product-specific classification, with 1977 distinction preserved |
| R012-P1-H013 | Seller open-end credit / historical exception | Answered: C026, C053 | Genuine pre-cutoff contract and non-cutoff terms | No modern blanket exemption inferred |
| R012-P1-H014 | Leases and ownership options | Answered conditional test: C024; E15 | Full lease and termination terms | Separate lease/product classification |
| R012-P1-H015 | Large transactions | Answered: C027, C057; E14 | Other coverage predicates | No dollar-threshold model required |
| R012-P1-H016 | Commodities/securities / utility statements | Partial: C023 | Modern sector-specific authority, especially utilities | Narrow sector inquiry; no blanket transplantation of TILA exemptions |
| R012-P1-H017 | Both notice clauses | Answered: C028–C030; § 4 | Actual document | No customer contract sought |
| R012-P1-H018 | Type size and bold form | Answered rule; application held: C030 | Actual typography | Generic form inspection only if later needed |
| R012-P1-H019 | Location / incorporation / multiple documents | Answered staff framework: C031–C032 | Actual incorporation and governing contract law | Targeted generic incorporation authority |
| R012-P1-H020 | Assent / electronic presentation | Unresolved by scope: worksheet W21 | Governing law and actual assent evidence | Separate electronic-contract pass |
| R012-P1-H021 | Seller acceptance / partial proceeds | Answered: C029 | Actual acceptance and loan connection | No factual transaction inquiry |
| R012-P1-H022 | Unlawful-practice command versus private claim | Answered distinction: C003–C004, C034–C035 | Specific cause, enforcement route, standing | Separate remedies/standing inquiry if authorized |
| R012-P1-H023 | Notice present but claim unknown | Answered: C035, C046; E06 | Underlying substantive claim | Jurisdiction/cause-specific public law |
| R012-P1-H024 | Notice missing | Partial: C045; E07 | Applicable incorporation/remedy law and controlling opinion | Single-jurisdiction missing-notice pass |
| R012-P1-H025 | Defensive use | Answered Commission framework: C036; E08 | Underlying claim and defensive procedure | Cause- and jurisdiction-specific defensive-use law |
| R012-P1-H026 | Affirmative recovery | Answered Commission framework: C037–C040; E08 | Claim, payments, procedural entitlement | Narrow published-opinion/underlying-law inquiry |
| R012-P1-H027 | Amount-paid limit | Answered textual measure; facts held: C038–C039, C048 | Payments and their legal attribution | Payment-component authority only; no actual computation |
| R012-P1-H028 | Holder/assignee relationship | Answered generic preservation: C034, C038 | Actual chain and capacity | No assignment-record search authorized |
| R012-P1-H029 | Independent assignee misconduct | Answered distinction: C041; E09 | Separate duty and cause | Separate actor/conduct-specific public-law pass |
| R012-P1-H030 | Attorney fees and costs | Answered federal interpretation; local law held: C042–C043; E11 | Fee source, party coverage, posture, controlling holding | Targeted fee-authority and published-opinion inquiry |
| R012-P1-H031 | Rescission | Answered negative universal prerequisite: C040 | Actual rescission law and entitlement | Separate rescission/remedy pass |
| R012-P1-H032 | Nonmonetary remedies | Partial: C044 | Remedy elements and jurisdiction | Specific remedy authority, not an award prediction |
| R012-P1-H033 | Time limits / accrual / defensive survival | Unresolved beyond distinction: C047; E15 | Applicable statute, accrual, tolling, recoupment law | Separate bounded time-law pass |
| R012-P1-H034 | Published majority opinions | Unresolved: C059; S019 | Successfully retrieved majority body and later-authority treatment | Recover an official published opinion; no docket-status query |
| R012-P1-H035 | 1975/1977 operative history | Answered for used changes: C049–C053 | Other historical pages not relied on | Only if a remaining historical issue requires them |
| R012-P1-H036 | Original 1988 review | Partial: C054 | Original notice body | Public official notice retrieval |
| R012-P1-H037 | 2019 review / proposed versus adopted | Answered: C055, C062 | Exhaustive subsequent amendment history | Official final-rule check |
| R012-P1-H038 | 2021/2022 interpretive changes | Answered within authority status: C057–C058 | Later withdrawal or judicial treatment not exhaustively audited | Targeted publisher-status / published-authority check |
| R012-P1-H039 | CFPB withdrawn-guidance condition | Not triggered by a relied-on circular/bulletin/advisory | No such instrument used; S006 is regulatory commentary | If one is used later, check its withdrawal register and publisher status |
| R012-P1-H040 | BNPL and full Reg Z classification | Excluded/held: C012, C060; E10 | Product structure and full relevant authority | Separate A012 product/BNPL component |
| R012-P1-H041 | Comparison matrix | Delivered: § 5 | All actual product facts remain unknown | No operational classification approved |
| R012-P1-H042 | Blank audit | Delivered: § 6, W01–W33 | All finding fields intentionally blank | No records request or identifier entry |
| R012-P1-H043 | Qualitative failure branches | Delivered: E01–E15 | No individual predicates established | No amount or deadline example necessary |
| R012-P1-H044 | Currentness / litigation status | Partial: C001–C002, C061 | Intervening issue/session-law audit and later published-authority review | Bounded public-primary updates |
| R012-P1-H045 | All other parent dimensions | Excluded as instructed: C064; § 12 | Unaddressed A012 authorities and facts | Separate authorized components |
The table distinguishes successful body reading, partial historical reading, failed retrieval, and discovery. A failed route is not a finding that no law exists.
| Log item | Action / source | Result and effect |
|---|---|---|
| L01 | S001 complete Part 433 | Successful complete HTML body read. Later separate § 433.1 URL, https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-433/section-433.1, returned an access screen. No challenge interaction; the earlier complete-part read supplied the definition body. |
| L02 | Initial House query-form URLs | These returned 404: https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1602&num=0&edition=prelim and https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1605&num=0&edition=prelim. Alternate title/section query forms also failed. S003’s publication-specific House URLs successfully recovered the necessary bodies. |
| L03 | Complete eCFR Supplement I | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/appendix-Supplement%20I%20to%20Part%201026 exceeded the tool’s content-size limit. S006 supplied the selected official commentary; no complete-appendix read claimed. |
| L04 | Four initial FTC historical-page clicks | Link-resolution errors occurred before the short landing pages were fully displayed. Reading those pages exposed the correct links; S007, S008, S011, and S012 were then successfully opened. These were recovered navigation failures. |
| L05 | S007 original 1975 scan | Parser returned zero text lines. Necessary selected pages were actually read as screenshots. No claim that all 25 pages were read. |
| L06 | S008, S011, S012 historical scans | OCR interleaved columns and unrelated material. Screenshots verified the correction, the seller-card footnote, and the adopted exemption text. Proposed petition text and separate dissent were distinguished from adopted action. |
| L07 | S010 1976 Federal Register issue | Full PDF failed at approximately 50 MB. Citation route unavailable. Alternate public-document attempts also failed: https://www.ftc.gov/system/files/documents/federal_register_notices/1976/08/41_fr_34594.pdf, https://www.govinfo.gov/content/pkg/FR-1976-08-16/html/FR-1976-08-16.htm, and https://www.govinfo.gov/content/pkg/FR-1976-08-16/text/FR-1976-08-16.txt. Material relationship-interpretation gap retained. |
| L08 | S013 1988 Federal Register issue | Full PDF failed at approximately 56 MB; archival slice unavailable; citation route led to access/CAPTCHA page. No interaction with the challenge. Original-body gap retained. |
| L09 | Screenshot attempts for oversized issues | The tool could not render the unsuccessful issue references as PDFs. These attempts supplied no additional body evidence. |
| L10 | S014, S016, S017 | Complete parsed opinions/note read through their final pages and footnotes. No pixel inspection claimed. |
| L11 | S015 2019 confirmation | Complete HTML body/footnotes read; official PDF checked as specified in the source register. Mirrors remain one source group. |
| L12 | S019 court opinion | Three official opinion URLs failed. Search metadata was discovery only. No headnote or search-excerpt holding substituted. |
| L13 | S020 alternative historical compilation | Index/TOC search did not recover S010. No substantive legal conclusion drawn from the absence of keyword matches. |
| L14 | Publication and update searches | Official FTC pages and targeted later-change searches inspected. They did not establish an exhaustive amendment, withdrawal, or later-litigation census. |
| Assigned question | Principal answer locations | Claims | Sources | Remaining boundary |
|---|---|---|---|---|
| 1. Definitions, seller/consumer/contract coverage, financing patterns and exclusions | Claim register § 3.1–3.2; comparison matrix | C003–C027, C060, C063 | S001–S007, S009–S012, S015–S016 | S010 relationship-edge gap; actual product/purpose/arrangement; mixed-purpose and complete BNPL classification |
| 2. Complete notice clauses, format, placement, seller acceptance, presence/absence | § 4; worksheet W16–W21 and W31 | C028–C033, C045–C046 | S001, S009, S015 | Actual documents, typography, assent, incorporation, and state-law missing-notice consequences |
| 3. Preservation, defensive/affirmative use, amount paid, independent liability, fees, rescission, timing | Claim register § 3.3; E06–E11, E14–E15 | C034–C048, C056, C058–C059 | S001, S007, S009, S014–S017 | Underlying cause, governing law, payment attribution, judicial holdings, limitations and remedies |
| 4. Amendments, review history, current/proposed/historical status and conflicts | §§ 2, 8, 10 | C001–C002, C049–C063 | S001–S020 as individually qualified | Original 1976/1988 bodies, complete later-status audit, court-opinion access |
| 5. Comparison matrix, blank audit, qualitative failure branches, coverage and remaining questions | §§ 5–7, 9, 12 | Entire register; especially C060–C064 | Sources linked through claims | Analytical deliverables only; no individual classification or acceptance |
| Research/owner standards | §§ 1, 2, 10, 12 | C001–C002, C052, C054, C059–C064 | Retrieval record and source-status entries | No independent review, UI provenance verification, operational approval, or publication |
| Check | Result |
|---|---|
| Complete operative Part 433 read | Yes, through the complete-part retrieval, including both notices and the entire § 433.3 exception. |
| Both financing routes kept separate | Yes. Seller-financed credit sales and qualifying seller-connected purchase-money loans were not collapsed. |
| Borrowed TILA definitions distinguished from wholesale incorporation of TILA exemptions | Yes. The corrected transaction-value issue is explicit. |
| Seller-issued versus non-seller cards preserved | Yes. The 1977 Commission footnote was read in pixels and used to qualify broad shorthand. |
| Staff guidance distinguished from Commission interpretation | Yes. The pamphlet’s express status and its corrected/conflicting statements are identified. |
| Underlying cause distinguished from notice preservation | Yes. No breach, fraud, warranty claim, or entitlement was assumed. |
| Defensive and affirmative uses distinguished | Yes. No automatic cancellation, payment-suspension, or recovery calculation. |
| Independent holder liability and fee authority separated from derivative liability | Yes. No universal cap or universal fee award stated. |
| Missing notice handled conditionally | Yes. Neither automatic extinguishment nor universal automatic incorporation asserted. |
| Proposed, retained, corrected, and historical materials separated | Yes. No proposal or dissent treated as adopted operative text. |
| Published-case body requirement honored | Yes by withholding the unverified holding. The court-source failure remains a substantive gap. |
| PDF text versus pixels distinguished | Yes. Exact visual-read bounds appear in the source register. |
| No legal arithmetic or deadline model | Yes. None necessary. |
| Source completeness / independent corroboration | Limited. Grouped formats are not independent sources; no independent reviewer performed this self-check. |
| Actual-person and operational boundaries | Preserved. No records lookup, decision, filing, contact, or publication. |
All actual product, purpose, retail transaction, seller-lender arrangement, consumer credit contract, notice, assent, payments, underlying claim, assignment, holder capacity, and state facts remain unknown.
The following A012 dimensions remain unaccepted and outside this component except for the expressly limited cross-references above: complete BNPL/product and Reg Z classification; disclosures; APR; usury; default and late fees; returns and refunds; error resolution; credit reporting; collections; settlement; limitations; remedies; litigation; tax; insolvency; state, local, tribal, international, and country law; and every other unaddressed parent dimension.
No component, parent, operations, or publication acceptance is given.
END R012 PASS-01
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.
Item · Recorded scope or limitation · 10 data rows
| Item | Recorded scope or limitation |
|---|---|
| Actual source-access date | October 27, 2026, America/Los_Angeles. A public-web clock check during the research returned 3:24:56 p.m. PDT. |
| Operative regulation read | Complete displayed 16 CFR Part 433, including every definition in § 433.1, both notice provisions in § 433.2, and the complete historical-contract exception in § 433.3. |
| eCFR version limit | The complete Part 433 page and the separate § 433.2 page displayed currency through October 23, 2026. The separately retrieved § 433.3 page displayed October 22, 2026. The complete-part retrieval included § 433.3. Neither a retrieval date nor a title-wide amendment date proves that every intervening Federal Register issue has been audited. |
| U.S. Code version limit | The successful House compilations identified their coverage as laws in effect through Public Law 119-121, October 9, 2026. That is a compilation boundary, not certification of a complete October 27 session-law audit. |
| Foundations | No prior report, other research chat, unreviewed Library output, or coordinator finding supplied a premise. |
| Method | Public authority research only. No local files, coordinator records, hashes, imports, subagents, browser control, API research, contacts, filings, or publication. |
| Individual information | No borrower, customer, seller, lender, account, property, licensing, or other party-specific investigation. No identifiers were entered into a records-search system. |
| Court-opinion limitation | An official published-opinion candidate was located, but its body could not be retrieved through the attempted official URLs. No holding, disposition, or later litigation history from that opinion is adopted here. Incidental case-navigation search results were not opened or used. |
| Model/UI provenance | No user-interface model selector or model label was inspected. This report makes no claim of verified GPT-6 Pro UI provenance. |
| Calculations | No recovery, award, deadline, or legal-calendar calculation was necessary or performed. Historical effective dates below are source statements, not calculated consumer deadlines. |
Source ID · Issuer / title · Complete literal HTTPS URL(s) · 6 data rows
| Source ID | Issuer / title | Complete literal HTTPS URL(s) | Exact read bounds / pinpoints | Version, jurisdiction, status, and limits |
|---|---|---|---|---|
| R012-P1-S001 | OFR/GPO, eCFR — 16 CFR Part 433, Preservation of Consumers’ Claims and Defenses | https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-433 ; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-433/section-433.2 ; https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-433/section-433.3 | Complete Part 433 body: §§ 433.1(a)–(j), 433.2(a)–(b), 433.3(a)–(b)(4), authority and source notes. HTML; no PDF index. | Fresh complete body read. U.S. federal regulation. Complete-part/§ 433.2 pages through October 23; separate § 433.3 through October 22. A separate § 433.1 URL later encountered an access screen; its complete body had already been read in the part. ecfr.gov +2 |
| R012-P1-S002 | Congress / House OLRC — 15 USC 44 and 45, necessary FTC Act definitions and jurisdiction | https://uscode.house.gov/us/usc/119-121/t15/s44/ ; https://uscode.house.gov/us/usc/119-121/t15/s45/ | § 44 definitions, particularly commerce, corporation, and banks; § 45(a)(1)–(2) complete clauses. Adjacent § 45(a)(3)–(4) encountered, but no international-law conclusion drawn. HTML. | Fresh selected statute read. U.S. federal. Through PL 119-121, October 9, 2026. Full FTC enforcement/remedies framework excluded. uscode.house.gov +1 |
| R012-P1-S003 | Congress / House OLRC — 15 USC 1602 and 1605, necessary TILA definitions | https://uscode.house.gov/us/usc/119-121/t15/s1602/ ; https://uscode.house.gov/us/usc/119-121/t15/s1605/ | § 1602(f)–(i), with adjacent card definitions; complete § 1605(a), including its cash-comparison and closing-agent qualifications. § 1605(b)–(e) also displayed/read, without a comprehensive charge-classification conclusion. HTML. | Fresh selected statute read. U.S. federal. Through PL 119-121, October 9, 2026. Earlier query-form URLs failed; successful publication-specific URLs recovered the necessary text. No full TILA/product classification. uscode.house.gov +1 |
| R012-P1-S004 | OFR/GPO, eCFR — 12 CFR 1026.2, necessary Reg Z definitions | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.2 | § 1026.2(a)(12), (14), complete (16), and complete (17)(i)–(v); adjacent definitions inspected for context. HTML. | Fresh selected regulation read. U.S. federal. Displayed through October 23, 2026. Borrowed-definition work only; not an approval of every current Reg Z provision or product. ecfr.gov +1 |
| R012-P1-S005 | OFR/GPO, eCFR — 12 CFR 1026.4, necessary finance-charge definition | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.4 | Complete § 1026.4(a)(1)–(3); (b) introduction and ordinary retail-credit examples; (c)(1)–(2). Additional displayed exclusions were inspected but are not a full fee audit. HTML. | Fresh selected regulation read. U.S. federal. Displayed through October 23, 2026. Actual finance-charge classification remains unknown. ecfr.gov +2 |
| R012-P1-S006 | CFPB — Supplement I official interpretations of § 1026.2 | https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-2/ | Complete comments 2(a)(16)-1 through -5; 2(a)(17)(i)-1 and -2; related general creditor discussion. HTML. | Fresh selected official-commentary read. U.S. federal. Agency presentation; not an independent current-CFR-edition audit. Complete eCFR appendix retrieval exceeded the tool’s size limit. No CFPB circular, bulletin, or separate advisory was used. Consumer Financial Protection Bureau |
Source ID · Issuer / title · Complete literal HTTPS URL(s) · 11 data rows
| Source ID | Issuer / title | Complete literal HTTPS URL(s) | Exact read bounds / pinpoints | Version, jurisdiction, status, and limits |
|---|---|---|---|---|
| R012-P1-S007 | FTC — 1975 final rule and Statement of Basis and Purpose, 40 FR 53506 | https://www.ftc.gov/system/files/documents/federal_register_notices/1975/11/40_fr_53506.pdf | Pixels read: printed p. 53506, PDF index 0; pp. 53523–53528, indices 17–22. Index 24, p. 53530, was also seen but its dissent material is not relied on. Necessary operative clauses and relevant majority discussion were read; the entire 25-page package was not. | Fresh selected historical final-rule/SBP read. U.S. federal. Promulgated November 14, published November 18, 1975; stated effective date May 14, 1976. PDF text extraction returned zero lines; screenshots supplied the successful read. Later correction and interpretations control identified conflicts. |
| R012-P1-S008 | FTC — 1975 correction, 40 FR 58131 | https://www.ftc.gov/system/files/documents/federal_register_notices/1975/12/40_fr_58131.pdf | Printed p. 58131, PDF index 0; both Part 433 correction blocks read in text and pixels. Unrelated aviation/securities material excluded. | Fresh historical correction read. U.S. federal. Published December 15, 1975. Includes correction of the purchase-money notice’s reference to services; no new recovery regime. ftc.gov |
| R012-P1-S009 | FTC Bureau of Consumer Protection — Staff Guidelines, May 4, 1976, corrected electronic pamphlet | https://www.ftc.gov/system/files/documents/rules/holder-due-course-rule/760504hidcrule.pdf | Complete parsed pamphlet read, PDF indices 0–12. Printed pp. 1–19 occupy indices 2–11, generally two printed pages per PDF page. Principal pinpoints: pp. 2, 6–9, 10–17, 18–19. Pixels seen only at index 6, printed pp. 8–9, including the strikeout/correction note. | Fresh staff guidance, not Commission-adopted interpretation. U.S. federal. Preface expressly disclaims formal Commission adoption. Its dollar-ceiling statement was corrected in 2021; its card discussion must be read with the later 1977 Commission clarification. ftc.gov +4 |
| R012-P1-S010 | FTC — Statement of Enforcement Policy, 41 FR 34594, August 16, 1976 | https://www.govinfo.gov/content/pkg/FR-1976-08-16/pdf/FR-1976-08-16.pdf ; https://www.federalregister.gov/citation/41-FR-34594 | No complete body read. Full-issue PDF exceeded retrieval size; citation route unavailable. Search excerpts and the 2022 opinion’s citation established a research lead only. Printed opening pinpoint 34594; usable PDF index not established. | Discovery/access failure. U.S. federal historical Commission policy. Its detailed referral/cooperation interpretation is not represented as freshly verified. Borderline referral cases remain held. |
| R012-P1-S011 | FTC — 1977 two-party open-end exemption and invitation to comment, 42 FR 19487–19490 | https://www.ftc.gov/system/files/documents/federal_register_notices/1977/04/42_fr_19490.pdf | Relevant notice visually read across all four PDF pages, indices 0–3, printed pp. 19487–19490. Critical: p. 19488 n.2, seller versus non-seller cards; p. 19490, adopted § 433.3. Appended petition distinguished from adopted text. | Fresh historical agency action/interpretation. U.S. federal. Published April 14, 1977; immediate exemption then keyed to contracts before August 1, 1977. Later modified by S012. |
| R012-P1-S012 | FTC — 1977 modification; denial of permanent exemption, 42 FR 46509–46510 | https://www.ftc.gov/system/files/documents/federal_register_notices/1977/09/42_fr_46510.pdf | Complete relevant majority notice and amendatory text, printed pp. 46509–46510, PDF indices 0–1, read in text and pixels. Separate dissent following the operative text is not the adopted rule. | Fresh historical final modification. U.S. federal. Published September 16, 1977; historical-contract cutoff moved to before November 1, 1977. Broader permanent exemption denied. ftc.gov +1 |
| R012-P1-S013 | FTC — 1988 regulatory-flexibility review, 53 FR 44456–44457 | https://www.govinfo.gov/content/pkg/FR-1988-11-03/pdf/FR-1988-11-03.pdf ; https://archives.federalregister.gov/issue_slice/1988/11/3/44438-44458.pdf ; https://www.federalregister.gov/citation/53-FR-44456 | Original body not read. Full PDF exceeded retrieval size; archival slice unavailable; citation route returned an access/CAPTCHA page. No challenge interaction attempted. | Access failure. U.S. federal historical review. S015’s footnote 46 provides a Commission account of the earlier decision; that account is not substituted for a claimed original-document read. |
| R012-P1-S014 | FTC Commission — May 3, 2012 advisory opinion on affirmative recovery | https://www.ftc.gov/system/files/documents/advisory_opinions/16-c.f.r.part-433-federal-trade-commission-trade-regulation-rule-concerning-preservation-consumers-claims/120510advisoryopinionholderrule.pdf | Complete five-page parsed opinion, printed pp. 1–5, PDF indices 0–4, including footnotes. No pixels inspected. | Fresh Commission advisory opinion. U.S. federal interpretation. Issued May 3, 2012; reiterated in S015. Its descriptions of judicial decisions are not independent reads of those opinions. ftc.gov +3 |
| R012-P1-S015 | FTC — 2019 Confirmation of Rule, 84 FR 18711–18715 | https://www.federalregister.gov/documents/2019/05/02/2019-08886/trade-regulation-rule-concerning-preservation-of-consumers-claims-and-defenses ; https://www.govinfo.gov/content/pkg/FR-2019-05-02/pdf/2019-08886.pdf | Complete relevant HTML body and footnotes read. Official PDF pp. 18711–18712, indices 0–1, parsed; pp. 18713–18715, indices 2–4, visually read. Principal pinpoints: § B; § C.1–6; nn. 2, 5, 26, 28, 32, 36, 46. | Fresh final confirmation/explanation. U.S. federal. Effective May 2, 2019; applicable as of April 23, 2019. Retained without modification. Commentary is distinguished from amendatory text and later fee clarification. federalregister.gov +3 |
| R012-P1-S016 | FTC staff — Staff Note Regarding the Holder Rule and Large Transactions | https://www.ftc.gov/system/files/documents/rules/holder-due-course-rule/p104805_-_holder_rule_2021_staff_note.pdf | Complete three-page parsed note, printed pp. 1–3, PDF indices 0–2. No pixels inspected. | Fresh staff correction. U.S. federal. Dated April 12, 2021; explains that the earlier asserted transaction ceiling was unsupported. Not a newly enacted dollar threshold. ftc.gov +2 |
| R012-P1-S017 | FTC Commission — Statement on the Holder Rule and Attorneys’ Fees and Costs | https://www.ftc.gov/system/files/documents/advisory_opinions/commission-statement-holder-rule-attorneys-fees-costs/p124802_commission_statement_on_the_holder_rule_and_attorneys_fees_and_costs.pdf | Complete four-page parsed opinion, printed pp. 1–4, PDF indices 0–3, including all footnotes. Principal analysis pp. 2–4. No pixels inspected. | Fresh Commission advisory opinion. U.S. federal. January 18, 2022. Clarifies independent fee/cost authority versus seller-only liability passed through the notice. Does not itself award fees or establish a state cause. ftc.gov +2 |
Source ID · Issuer / title · Complete literal HTTPS URL(s) · 3 data rows
| Source ID | Issuer / title | Complete literal HTTPS URL(s) | Read / failure boundary | Use and limit |
|---|---|---|---|---|
| R012-P1-S018 | FTC — rule and advisory-opinion publication pages | https://www.ftc.gov/legal-library/browse/rules/holder-due-course-rule ; https://www.ftc.gov/legal-library/browse/advisory-opinions/16-cfr-part-433-federal-trade-commission-trade-regulation-rule-concerning-preservation-consumers ; https://www.ftc.gov/legal-library/browse/advisory-opinions/commission-statement-holder-rule-attorneys-fees-costs | Landing pages and linked-document descriptions read. Targeted official-domain amendment/withdrawal searches also performed. | Fresh discovery/status check, U.S. federal. Establishes publication availability and document identity, not exhaustive currentness, absence of litigation, or universal continued judicial acceptance. Federal Trade Commission +2 |
| R012-P1-S019 | Supreme Court of California — Pulliam v. HNL Automotive Inc., published-opinion candidate | https://supreme.courts.ca.gov/sites/default/files/supremecourt/default/2022-08/S267576.pdf ; https://www.courts.ca.gov/opinions/documents/S267576.PDF ; https://www.courts.ca.gov/opinions/archive/S267576.PDF | Official publication found in search; body attempts returned 403 or unavailable. No majority body, pinpoints, disposition, or later history verified. | Discovery/failure only. California. No substantive holding borrowed from snippets, headnotes, FTC footnotes, or incidental docket results. |
| R012-P1-S020 | FTC — Volume 88 index and table of contents, searched as an alternative historical publication route | https://www.ftc.gov/legal-library/browse/cases-proceedings/commission-decision-volumes/volume-88 ; https://www.ftc.gov/sites/default/files/documents/commission_decision_volumes/volume-88/ftc_volume_decision_88_july_-_december_1976_members_of_the_commission_and_table_of_contents.pdf | Index opened; table-of-contents searches did not recover the needed enforcement statement. No substantive opinion from the volume used. | Discovery only. U.S. federal historical compilation. Unsuccessful keyword searches are not evidence that the statement does not exist. |
Claim ID · Precise claim / area · Source and pinpoint · 20 data rows
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions, status, and limits |
|---|---|---|---|
| R012-P1-C001 | Currency: the complete Part 433 retrieval displayed October 23, 2026 currency. | S001, page banner and complete part. | Observed source status. Access on October 27 does not eliminate the intervening-currentness hold. |
| R012-P1-C002 | Statute version: the successful House text was bounded by PL 119-121, October 9, 2026. | S002–S003, compilation headers. | Observed source status. No later session-law audit claimed. |
| R012-P1-C003 | Command: § 433.2 addresses a seller’s specified practices in consumer goods/services transactions affecting statutory commerce. | S001, § 433.2 introduction; S002, §§ 44, 45(a)(1). | Regulation/statute. Actual commerce and actor predicates remain unknown. |
| R012-P1-C004 | Jurisdiction versus contract: FTC jurisdictional exclusions do not themselves establish immunity from a contract’s preserved claims. | S002, § 45(a)(2); S007, pp. 53523–53524. | The statutory exclusions include banks, specified savings institutions, federal credit unions, and specified carrier/regulated activities. Do not equate regulatory jurisdiction with contractual-holder liability. |
| R012-P1-C005 | Person/consumer: the rule’s person definition includes business organizations; its consumer definition requires a natural person seeking or acquiring personal, family, or household goods/services. | S001, § 433.1(a)–(b). | Regulation. These definitions perform different roles. |
| R012-P1-C006 | Seller: ordinary-course selling or leasing of consumer goods/services is required. | S001, § 433.1(j). | Regulation. A marketing label or platform role is insufficient. |
| R012-P1-C007 | Creditor: § 433.1(c) addresses ordinary-course purchase-money lending or deferred-sale financing, with a transaction-specific card-issuer proviso. | S001, § 433.1(c), (h). | Regulation. Apply with C025’s seller/non-seller distinction. |
| R012-P1-C008 | Instrument: a consumer credit contract evidences or embodies debt from either defined financing route. | S001, § 433.1(i). | Regulation. A payment schedule alone does not establish the required transaction. |
| R012-P1-C009 | Purchase-money route: requires a consumer cash advance for a TILA/Reg Z finance charge, substantially or wholly applied to a purchase, plus the specified seller-creditor connection. | S001, § 433.1(d)(1)–(2). | Regulation. All predicates matter; product and arrangement unknown. |
| R012-P1-C010 | Financed-sale route: § 433.1(e) borrows the TILA/Reg Z credit-sale concept. | S001, § 433.1(e); S003, § 1602(h); S004, § 1026.2(a)(16). | Regulation/statute. Seller-as-creditor classification must be established. |
| R012-P1-C011 | Ordinary Reg Z creditor test: requires regular qualifying consumer-credit extensions and initial payability to that creditor. | S003, § 1602(g); S004, § 1026.2(a)(17)(i), (v). | For the ordinary test, qualifying terms involve a finance charge or a written agreement for more than four installments, excluding a down payment. Other tests exist; this is not a complete BNPL test. |
| R012-P1-C012 | Installment labels: installment count, deferral, or a pay-in-four label does not by itself establish either Holder Rule route. | S001, § 433.1(d)–(e); S003–S005. | Inference. No universal inclusion or exclusion of BNPL follows. |
| R012-P1-C013 | Finance charge: actual credit-related charges, including indirect charges, must be classified; comparable cash charges are excluded from the basic definition. | S003, § 1605(a); S005, § 1026.4(a). | Statute/regulation. An advertised zero-interest rate does not complete that inquiry. |
| R012-P1-C014 | Late-charge qualification: the cited exclusion concerns actual unanticipated late-payment/default-type charges. | S005, § 1026.4(c)(2). | Regulation. A charge’s name alone does not establish the exclusion. No actual fee classified. |
| R012-P1-C015 | Arranging versus selling on credit: seller assistance with a loan initially payable to a financial institution is not itself a Reg Z credit sale. | S006, comment 2(a)(16)-2. | Official interpretation. The separate § 433.1(d) purchase-money route may still matter. |
| R012-P1-C016 | Immediate assignment: simultaneous assignment does not, by itself, change the initially payable party under the cited Reg Z creditor test. | S006, comment 2(a)(17)(i)-2. | Official interpretation. Contract structure remains necessary evidence. |
| R012-P1-C017 | Seller-creditor link: the rule includes referral and common-control, contractual, or business-arrangement alternatives; arrangements may be informal. | S001, § 433.1(d), (f)–(g). | Regulation. Detailed unilateral-steering/cooperation boundaries remain held because S010 was not fully retrieved. |
| R012-P1-C018 | Unrelated relationship: ordinary commercial dealings alone do not establish the required sales-financing affiliation under staff’s explanation. | S009, printed pp. 16–17. | Staff guidance. No actual relationship assessed. |
| R012-P1-C019 | No invented numeric shortcut: Part 433 supplies no percentage definition of substantial application and no numeric referral quota. | S001, complete § 433.1. | Text-based inference. An invented threshold cannot replace the factual/legal inquiry. |
| R012-P1-C020 | Independent loan: spending independently obtained loan proceeds at a retailer does not alone establish the purchase-money connection. | S001, § 433.1(d); S009, pp. 12–13. | Conditional coverage conclusion. Stipulated absence of both relationship alternatives defeats that route, not every possible claim. |
Claim ID · Precise claim / area · Source and pinpoint · 13 data rows
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions, status, and limits |
|---|---|---|---|
| R012-P1-C021 | Purpose/person: purely commercial purchases and organizational purchasers do not satisfy the ordinary consumer coverage described here. | S001, § 433.1(b); S009, p. 9. | Regulation/staff explanation. Mixed-purpose facts remain unresolved. |
| R012-P1-C022 | Real estate: buying an interest in real property differs from financing consumer goods/services secured by real property. | S009, p. 9; S007, p. 53525. | Historical official explanation. A home-improvement purchase is not automatically excluded merely because real estate secures payment. |
| R012-P1-C023 | Other historical exclusions: staff identifies securities and commodities purchases as outside its goods/services coverage discussion. | S009, p. 9. | Staff guidance. Its separate public-utility statement is not converted here into a fully audited modern sector exemption. |
| R012-P1-C024 | Leases: only qualifying debt/credit-sale arrangements satisfy this route; a lease label is insufficient. | S003, § 1602(h); S004, § 1026.2(a)(16)(i)–(ii); S015, p. 18713 n.26. | The Reg Z lease branch requires the specified value-based payment commitment and ownership/nominal-option terms, and excludes leases terminable without penalty at any time. Not all leases qualify. |
| R012-P1-C025 | Cards: the 1977 Commission explanation expressly distinguishes excluded non-seller card lending from seller-issued card financing under the financed-sale route. | S011, p. 19488 n.2. | Commission interpretation. Retailer branding does not identify the legal issuer or financing route. |
| R012-P1-C026 | Historical-contract exception: § 433.3 protects only its specified pre-November 1, 1977 open-end contracts that do not cut off claims/defenses. | S001, § 433.3(a), (b)(2)–(4); S012, p. 46510. | Requires the defined open-end arrangement and absence of negotiability or limiting terms described in (b)(4). Its open-end definition excludes specified negotiated mortgage advances and letters of credit. No general modern exemption. |
| R012-P1-C027 | Transaction size: the Holder Rule contains no maximum transaction-value exemption of the kind asserted in the old staff pamphlet. | S016, pp. 1–3; S007, p. 53527. | Text plus staff correction. Do not import TILA’s separate dollar exemption wholesale. ftc.gov |
| R012-P1-C028 | § 433.2(a): a seller may not take or receive a covered contract lacking the prescribed notice. | S001, § 433.2(a). | Regulation. Direct or indirect seller conduct; antecedent coverage required. |
| R012-P1-C029 | § 433.2(b): a seller may not accept qualifying loan proceeds toward payment unless the associated consumer credit contract contains the prescribed notice. | S001, § 433.2(b). | Regulation. Applies to partial as well as complete payment; not merely to loans later assigned. |
| R012-P1-C030 | Notice form: both regulatory versions require their prescribed provision in bold type of at least ten points. | S001, § 433.2(a)–(b). | Regulation. The versions’ wording differs; see § 4 below. Actual font and contract unknown. |
| R012-P1-C031 | Location: staff permits any location that makes the notice clearly part of the credit contract. | S009, p. 17. | Staff guidance. No actual document-format approval; Part 433 contains no separate notice-signature command. |
| R012-P1-C032 | Multiple instruments: staff permits appropriate incorporation by reference when the documentation clearly subjects the obligation to the notice. | S009, pp. 10, 17–18. | Staff guidance. A detached disclosure or ambiguous reference is not automatically sufficient. |
| R012-P1-C033 | Qualification/waiver: additional language restricting the required notice conflicts with staff’s unqualified-notice explanation and the Commission’s stated anti-cutoff purpose. | S009, p. 6; S015, § C.5, pp. 18714–18715. | Interpretive finding. Does not adjudicate every later settlement, release, arbitration term, or waiver question. |
Claim ID · Precise claim / area · Source and pinpoint · 15 data rows
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions, status, and limits |
|---|---|---|---|
| R012-P1-C034 | Preserved subject matter: legally sufficient seller-related claims/defenses concerning the financed transaction can be asserted against a holder through the notice. | S014, p. 2; S009, pp. 7–8. | Commission/staff interpretation. An unrelated dispute with the seller is not automatically transferred. |
| R012-P1-C035 | Underlying merits: the rule does not create a new substantive seller claim merely because financing exists. | S014, p. 2; S007, p. 53524. | Commission explanation. Applicable substantive law and proof remain necessary. |
| R012-P1-C036 | Defensive use: preserved claims may defeat or reduce an asserted unpaid obligation. | S014, pp. 2–4. | Commission interpretation. Extent depends on the claim; no automatic payment-suspension or cancellation instruction follows. |
| R012-P1-C037 | Affirmative use: the Commission recognizes a claim for return of money already paid under the relevant contract. | S014, pp. 2–5. | Commission interpretation. A valid underlying basis and applicable procedural rules remain required. |
| R012-P1-C038 | Monetary ceiling: notice-derived affirmative recovery is limited by the debtor’s payments under the relevant contract. | S001, § 433.2, final sentence of each notice; S014, p. 5. | Regulation/interpretation. Face amount, remaining balance, and the assignee’s purchase price are not substitutes for that textual measure. |
| R012-P1-C039 | Down payments: staff distinguishes a payment under the installment-sale contract from a separate seller payment outside a direct-loan contract. | S009, p. 7. | Staff guidance. Contract attribution is necessary; no universal inclusion of every cash down payment. |
| R012-P1-C040 | Rescission: the Commission rejects a universal requirement of rescission entitlement or worthless goods before affirmative recovery. | S014, pp. 3–5; S015, § B, p. 18712. | Commission interpretation. This does not create an independent rescission right or establish every court’s treatment. ftc.gov |
| R012-P1-C041 | Independent liability: the notice’s limitation does not erase independently available rights against the holder. | S017, pp. 2–3. | Commission interpretation. A separate cause and its elements must actually apply. |
| R012-P1-C042 | Independent fees/costs: applicable law may authorize an award against the holder because of its own litigation role, outside the notice-derived ceiling. | S017, pp. 2–3. | Commission interpretation. Requires that law’s entitlement, party, success, and other predicates; no universal award. |
| R012-P1-C043 | Seller-only fees/costs: liability available only against the seller and transmitted through the notice remains within the derivative recovery limit; offsets are separately recognized. | S017, p. 3; S015, § C.3, p. 18713. | Commission interpretation. Relabeling derivative liability as fees does not create a fresh uncapped allowance. ftc.gov |
| R012-P1-C044 | Nonmonetary relief: the Commission does not read the monetary sentence as categorically barring other forms of relief. | S015, p. 18713 n.32; S017, p. 4 n.7. | Commission interpretation. Entitlement to any injunction or other remedy remains a separate question. |
| R012-P1-C045 | Omitted notice: required omission is a compliance problem, but absence does not establish that all seller-related claims against a holder are extinguished. | S001, § 433.2; S015, § C.4, p. 18714. | Regulation/Commission explanation. State-law incorporation or other preservation requires separate authority; no universal automatic insertion conclusion. |
| R012-P1-C046 | Notice present: inclusion alone does not establish mandatory rule coverage, a valid underlying claim, or overall legal compliance. | S001; S014, p. 2. | Inference. The effect of voluntarily included wording outside mandatory coverage is a separate contract/state-law question. |
| R012-P1-C047 | Time: Part 433 supplies no universal consumer assertion or filing period. | S001, complete rule; S009, pp. 7–8. | Text-based inference/staff explanation. Applicable limitation, accrual, tolling, recoupment, and procedural law are unresolved; defensive and affirmative uses must be examined separately. |
| R012-P1-C048 | Paid-amount uncertainty: this investigation establishes no actual payment total or treatment of disputed payment components. | S001, notice limitation; C039. | Unknown. Refunds, credits, trade-ins, third-party payments, finance charges, and separate-contract payments require tracing and legal classification. |
Claim ID · Precise claim / area · Source and pinpoint · 16 data rows
| Claim ID | Precise claim / area | Source and pinpoint | Trigger, conditions, exceptions, status, and limits |
|---|---|---|---|
| R012-P1-C049 | Original timing: the rule was promulgated November 14, published November 18, 1975, with May 14, 1976 effectiveness. | S007, p. 53506; S009, pp. 2, 19. | Historical agency dates. No consumer deadline calculated. |
| R012-P1-C050 | Correction: the December 1975 correction repaired wording and citations, including the purchase-money notice’s services reference. | S008, p. 58131. | Historical correction. Use current corrected text. |
| R012-P1-C051 | Staff status: the 1976 pamphlet expressly states it was informal, advisory, and not formally adopted by the Commission. | S009, printed p. 2. | Authority-status finding. It cannot silently override regulation or later Commission action. |
| R012-P1-C052 | 1976 policy gap: detailed Commission enforcement-policy treatment of seller-creditor relationships was not fully recovered. | S010; S017, p. 2 n.3. | Access hold. Search text is not a substitute for the body. |
| R012-P1-C053 | 1977 changes: the April cutoff was subsequently changed; the September action denied the requested broader permanent exemption. | S011, pp. 19487–19490; S012, pp. 46509–46510. | Historical final actions. Current § 433.3, not the earlier cutoff or petition appendix, supplies the displayed operative text. |
| R012-P1-C054 | 1988 gap: the original review notice was not read; its reported disposition appears in the 2019 Commission notice. | S013; S015, p. 18715 n.46. | Agency account plus access hold. No claim of fresh original-1988 verification. |
| R012-P1-C055 | 2019 action: the Commission retained the rule unchanged; the action states May 2 effectiveness and April 23, 2019 applicability. | S015, opening dates, introduction, conclusion. | Final confirmation. Not a newly adopted collection-notice or lender-insertion amendment. |
| R012-P1-C056 | 2012 status: the affirmative-recovery opinion is Commission interpretation, reiterated in 2019. | S014; S015, § B. | It is not a declaration that every contrary judicial application has been overruled. |
| R012-P1-C057 | 2021 status: the dollar-ceiling correction explains the existing rule rather than establishing a new transaction ceiling. | S016, pp. 1–3. | Staff correction. Historical pamphlet language is not current authority for a ceiling. |
| R012-P1-C058 | 2022 status: the fee opinion clarifies independent versus derivative liability without amending Part 433. | S017, pp. 2–4; S001. | Commission advisory interpretation. Fee entitlement remains dependent on separate law. |
| R012-P1-C059 | Judicial hold: no published judicial majority holding or later case history is established by this pass. | S019, retrieval failures. | Unknown. FTC descriptions of cases were not promoted into independently verified holdings. |
| R012-P1-C060 | BNPL hold: no complete BNPL, marketplace, digital-account, or pay-in-four classification is established. | C008–C017, C025. | Inference/scope hold. Actual instruments, payment obligations, charges, issuer roles, and arrangements remain unknown. |
| R012-P1-C061 | Currentness hold: targeted official searches and current publication pages do not prove exhaustive absence of later amendments, withdrawals, stays, or vacatur. | S001–S006, S018. | Research limitation. No such unverified status is assigned. |
| R012-P1-C062 | Unadopted expansion: the 2019 review did not adopt suggested additional consumer communications or broader direct lender notice duties. | S015, § C.1, C.6. | Final-review finding. Other laws may impose duties; those are not resolved here. |
| R012-P1-C063 | Card-source tension: broad card-exclusion shorthand must be qualified by the 1977 Commission’s express seller/non-seller explanation. | S009, p. 10; S011, p. 19488 n.2; S015, p. 18711 n.2. | Source reconciliation. No 2019 textual amendment eliminating the distinction was adopted. Specific products remain held. |
| R012-P1-C064 | Application boundary: none of these generic findings establishes actual liability, standing, recoverable amount, eligibility, or a filing decision. | Scope of this investigation; C035, C045–C048, C059–C061. | Explicit hold. No individual facts were investigated. |
Feature · § 433.2(a) · § 433.2(b) · 7 data rows
| Feature | § 433.2(a) | § 433.2(b) | Audit implication |
|---|---|---|---|
| Seller event | Taking or receiving the covered consumer credit contract. | Accepting qualifying purchase-money proceeds toward the sale or lease. | Identify the actual route and event; C028–C029. |
| First sentence, paraphrased | Makes a holder subject to the debtor’s seller-related claims and defenses for goods/services obtained under the contract or through its proceeds. | Makes a holder subject to the debtor’s seller-related claims and defenses for goods/services obtained through the loan proceeds. | Compare the entire provision with the regulation. |
| Exact distinguishing fragment | Includes “PURSUANT HERETO OR”. | Omits those words. | Do not treat the two forms as textually identical. |
| Exact proceeds fragment | “WITH THE PROCEEDS HEREOF”. | Same fragment. | The relationship to the financed purchase remains material. |
| Final sentence | Same in both versions; quoted below. | Same. | Establish the relevant contract and payments before considering its monetary limitation. |
| Form | Prescribed notice, headed “NOTICE”, in bold type of at least ten points. | Same express type-size/bold requirement. | Neither parsed text nor this chat establishes the font in an actual agreement. |
| Location / multiple documents | C031–C032. | C031–C032. | Staff’s clear-contract-term standard does not approve ambiguous incorporation. |
Generic pattern · Result within this pass · Critical discriminator · 16 data rows
| Generic pattern | Result within this pass | Critical discriminator | Claim / example links |
|---|---|---|---|
| Direct seller installment sale, with qualifying consumer-credit terms and instrument | Covered route established by stipulation | Seller’s legal role and credit-sale predicates | C005–C011, C028; E01 |
| Seller and lender cooperate to provide a finance-charge loan substantially financing that seller’s goods/services | Covered purchase-money route established by stipulation | Complete § 433.1(d) predicates, not merely a checkout financing button | C009, C017, C029; E02 |
| Consumer independently obtains cash credit; no seller referral or qualifying affiliation | Purchase-money route not established | Stipulated absence of the required connection | C020; E03 |
| Occasional recommendation or one-sided steering, cooperation facts unclear | Unresolved edge | S010 body gap and unknown course of dealing | C017–C019, C052; E12 |
| Pure business-purpose equipment purchase | Consumer route fails on stipulated purpose | Commercial purpose, notwithstanding installment payments | C021; E04 |
| Purchase by an organization | Ordinary consumer definition fails | Natural-person requirement | C005, C021; E04 |
| Financing acquisition of an interest in land | Outside the goods/services framework discussed here | Subject of purchase | C022; E05 |
| Consumer home-improvement goods/services financed with a real-estate lien | Potentially covered | The purchase and financing predicates, not collateral alone | C022; E05 |
| Purchase financed through a non-seller credit-card issuer acting in that capacity | Card exclusion relevant | Actual issuer role and transaction structure | C007, C025; E13 |
| Seller’s own card used for a qualifying seller-financed purchase | Potentially covered financed-sale route | Express 1977 distinction | C025, C063; E13 |
| Retailer-branded card with issuer and initial payee unknown | Unknown | Branding does not resolve the two preceding rows | C016, C025, C060 |
| Lease satisfying all borrowed credit-sale conditions | Potentially covered | Full lease conditions and credit-contract predicates | C024; E15 |
| Ordinary lease failing those conditions | This credit-sale route fails | No automatic coverage from the word lease | C024; E15 |
| BNPL/pay-in-four/deferred-payment/marketplace product without its legal structure | Unknown | Charges, instruments, roles, seller connection, card status | C012–C017, C060; E10 |
| Large-dollar consumer purchase otherwise satisfying coverage | No size-only exclusion established | Corrected historical guidance | C027, C057; E14 |
| Notice voluntarily appears in an otherwise uncovered arrangement | Mandatory coverage unproved; contractual effect unresolved | Separate incorporation and governing-law analysis | C046; E06 |
Field · Blank finding · Question / evidence category needed · 33 data rows
| Field | Blank finding | Question / evidence category needed | Related claims |
|---|---|---|---|
| W01 — Applicable jurisdiction | ______ | Which substantive, contract, and procedural laws would govern? | C035, C047 |
| W02 — Relevant legal version | ______ | Which enactment, effective date, and source currency apply to the transaction? | C001–C002, C049–C061 |
| W03 — Purchaser category | ______ | Natural person or organization? | C005, C021 |
| W04 — Purchase purpose | ______ | Personal/family/household, commercial, or mixed? | C005, C021 |
| W05 — Purchased subject | ______ | Goods, services, real-property interest, securities, commodities, or mixed transaction? | C006, C022–C024 |
| W06 — Seller role | ______ | Who performs the legal seller role, and is it ordinary-course activity? | C006 |
| W07 — FTC jurisdiction predicate | ______ | Relevant commerce and actor-jurisdiction questions? | C003–C004 |
| W08 — Initial obligation structure | ______ | Credit sale, loan, qualifying lease, other arrangement, or unresolved? | C008–C016 |
| W09 — Initial payability | ______ | To whom is the debt initially payable under the instrument? | C011, C015–C016 |
| W10 — Qualifying credit terms | ______ | Finance-charge and installment obligations; applicable creditor test? | C011–C014 |
| W11 — Card capacity | ______ | Seller-issued versus non-seller-issued financing; actual transaction capacity? | C007, C025 |
| W12 — Purchase-money use | ______ | Is the advance substantially or wholly applied to the relevant purchase? | C009, C019 |
| W13 — Referral facts | ______ | Nature, repetition, and cooperation involved in referrals? | C017, C052 |
| W14 — Affiliation facts | ______ | Common control, express agreement, informal understanding, or course of dealing? | C017–C018 |
| W15 — Historical exception | ______ | Any genuine § 433.3 issue, including all non-cutoff conditions? | C026 |
| W16 — Complete instrument set | ______ | Which documents embody the obligation and are incorporated? | C008, C032 |
| W17 — Correct notice version | ______ | Is the applicable § 433.2(a) or (b) wording complete? | C028–C030 |
| W18 — Notice typography | ______ | Actual bold type and point size; reliable visual/document evidence? | C030 |
| W19 — Notice placement | ______ | Clearly a contract term, including any cross-reference? | C031–C032 |
| W20 — Contradictory terms | ______ | Any purported restriction of preserved claims or defenses? | C033 |
| W21 — Assent/incorporation | ______ | Applicable contract law and actual presentation/acceptance evidence? | C031–C032, C046 |
| W22 — Holder relationship | ______ | Relevant contract, assignment chain, and capacity in which rights are asserted? | C034, C038 |
| W23 — Underlying seller claim | ______ | Exact cause/defense, elements, breach, causation, injury, and available relief? | C034–C035 |
| W24 — Transaction linkage | ______ | Does the claim concern the financed purchase or a separate dealing? | C034 |
| W25 — Desired legal use | ______ | Defense, setoff, affirmative recovery, nonmonetary relief, or separate liability? | C036–C044 |
| W26 — Payment attribution | ______ | Payments under this contract versus other agreements; no amount assumed? | C038–C039, C048 |
| W27 — Payment components | ______ | Principal, interest, fees, down payment, trade-in, credits, refunds, and third-party payments? | C048 |
| W28 — Independent holder conduct | ______ | Separate legal duty and facts, if any? | C041 |
| W29 — Attorney-fee/cost authority | ______ | Statute/contract/rule; against which party; success and other conditions? | C042–C043 |
| W30 — Time and procedure | ______ | Accrual, limitation, tolling, notice prerequisites, recoupment, forum, and procedural posture? | C047, C059 |
| W31 — Missing-notice consequence | ______ | Applicable incorporation, preservation, or independent-remedy authority? | C045 |
| W32 — Source and court status | ______ | Complete primary text, controlling published opinions, and any later authority still missing? | C052, C054, C059–C061 |
| W33 — Audit disposition | ______ | Which questions are answered, held, or outside this component? | C064 |
Example · Stipulated facts · Rule-specific result versus unknown · 15 data rows
| Example | Stipulated facts | Rule-specific result versus unknown | Evidence needed / adverse misclassification |
|---|---|---|---|
| R012-P1-E01 — Direct seller installment | A retail seller enters a qualifying consumer credit sale for household goods; the obligation is initially payable to the seller and later assigned. | The financed-sale notice route applies on these stipulations. Whether the goods were defective and whether a claim succeeds remain unknown. C010–C011, C016, C028, C035. | Need the instrument, initial-payee structure, and underlying claim law. Failure: assuming assignment removes seller-related defenses, or assuming covered financing proves a breach. |
| R012-P1-E02 — Qualifying arranged purchase-money loan | A seller and lender have a cooperative financing arrangement. A consumer receives a finance-charge advance, substantially applies it to the seller’s goods, and the seller accepts those proceeds. | The stipulated purchase-money predicates are met; the § 433.2(b) notice condition matters. Assignment is not a prerequisite to this route. C009, C017, C029. | Need the loan instrument, arrangement, purchase nexus, and charge characterization. Failure: treating every loan made by a separate lender as outside the rule. |
| R012-P1-E03 — Independent cash loan | A consumer chooses an unaffiliated lender independently. The seller neither refers consumers to it nor has the defined affiliation. | The stipulated transaction fails the seller-connection requirement for the purchase-money route. Other contract or statutory rights remain open. C020. | Need reliable relationship facts. Failure: treating later expenditure of borrowed money at a shop as sufficient coverage. |
| R012-P1-E04 — Business purpose / organizational purchaser | Equipment is purchased exclusively for commercial operations; alternatively, the purchaser is an organization. | The ordinary consumer predicate used in this pass fails. A mixed-purpose transaction would require a different analysis. C005, C021. | Need purpose and legal purchaser category. Failure: equating a natural person’s signature, retail setting, or installment schedule with consumer coverage. |
| R012-P1-E05 — Real estate versus real-estate security | One arrangement finances a land interest. Another finances household improvements and takes a real-estate lien. | The two transactions cannot be classified identically merely because both involve real estate. The second still requires all financing predicates. C022. | Need what was purchased and what merely secures repayment. Failure: excluding all secured home-improvement financing, or including every land-acquisition loan. |
| R012-P1-E06 — Notice present, claim unknown | An instrument contains a Holder notice; no legally sufficient seller claim has been established. | The notice alone establishes neither damages nor cancellation. If mandatory coverage is absent, its voluntary contractual effect is also a separate issue. C035, C046. | Need underlying cause, transaction facts, and incorporation law. Failure: treating the notice as a refund guarantee. |
| R012-P1-E07 — Required notice missing | A transaction satisfies the rule, but the relevant contract omits the prescribed provision. | The seller-command issue is identifiable. Whether another law supplies notice-equivalent rights or another remedy remains unresolved. C028–C029, C045. | Need governing incorporation/preservation law and any controlling opinion. Failure: saying omission always destroys claims—or that federal law always inserts the notice automatically. |
| R012-P1-E08 — Affirmative versus defensive use | A legally sufficient seller claim is stipulated. The consumer has an unpaid obligation and has also made some payments. | Defensive reduction and affirmative recovery are distinct analyses. The monetary ceiling does not automatically determine the defensible balance or guarantee repayment of everything paid. C036–C040. | Need underlying relief, payment attribution, and procedural law. Failure: using one undifferentiated recovery cap for every form of relief. |
| R012-P1-E09 — Independent assignee misconduct | A holder is alleged to have committed a separate violation of a law imposing duties directly on it. | The independent theory must be tested on its own elements; the Holder notice is not a universal shield or automatic source of that liability. C041. | Need the independent duty, actor coverage, conduct, injury, and remedy. Failure: capping all holder misconduct at debtor payments merely because the contract also contains a notice. |
| R012-P1-E10 — BNPL classification unknown | A checkout option is described only as BNPL or pay-in-four; its charges, instruments, creditor roles, and legal card status are unspecified. | Coverage is unknown. Neither route is established by the label. C012–C017, C025, C060. | Need actual legal structure and applicable product authority in a separate authorized pass. Failure: declaring all such products covered, excluded, or credit cards. |
| R012-P1-E11 — Attorney fees depend on separate authority | A consumer succeeds on a preserved claim. One possible fee law addresses the holder’s litigation role; another permits liability only against the seller. | Those are materially different routes under the 2022 interpretation. Neither hypothetical establishes an amount or entitlement without the separate authority’s conditions. C042–C043. | Need exact fee statute/contract/rule and posture. Failure: announcing that fees are always capped, always uncapped, or automatically awarded. |
| R012-P1-E12 — Referral edge | A seller recommends a financing source, but repetition, lender agreement, and cooperative activity are unclear. | The borderline relationship remains unresolved, including the S010 source gap. C017–C019, C052. | Need the complete Commission policy and arrangement facts. Failure: treating one recommendation or a fabricated referral quota as dispositive. |
| R012-P1-E13 — Seller card versus branded non-seller card | One seller extends its own qualifying card credit. A different retail purchase uses a card legally issued by a non-seller acting in that role. | The 1977 explanation requires different treatment of the routes; branding does not decide which arrangement exists. C025, C063. | Need issuer capacity and initial debt structure. Failure: applying the shorthand exclusion to every card bearing a retailer’s name. |
| R012-P1-E14 — Large transaction / payment attribution | A large consumer transaction otherwise meets coverage. Some money was paid under a separate sale arrangement rather than the loan instrument at issue. | Size alone supplies no stated ceiling exemption. The separate payment cannot simply be added to a notice-derived recovery measure without attribution analysis. C027, C039, C048. | Need contract boundaries and payment tracing. Failure: relying on the corrected historical dollar exclusion or treating all money spent as money paid under the relevant contract. |
| R012-P1-E15 — Lease and timing | A document is called a lease; termination and ownership terms are unspecified. A later dispute is also alleged to be untimely. | Lease coverage and timeliness are independently unresolved. Part 433 supplies no universal deadline that resolves either affirmative or defensive use. C024, C047. | Need complete lease terms and governing time/recoupment law. Failure: assuming every lease is covered or that expiration of a claim period necessarily answers every defensive-use question. |
Issue · Materials actually inspected · Resolution for this pass · 9 data rows
| Issue | Materials actually inspected | Resolution for this pass | Remaining limitation |
|---|---|---|---|
| Original rule and correction | S007 selected final-rule/SBP pages; S008 correction; S001 complete current text | Original effective date and corrected notice text distinguished. | Unread historical pages are not represented as read. |
| Historical open-end exception | S011 complete relevant notice; S012 majority modification; current § 433.3 | Earlier August cutoff and petition proposals do not replace the displayed November 1, 1977 cutoff and conditions. | No actual old contract assessed. |
| Credit-card shorthand | S009’s broad staff wording; S011 p. 19488 n.2; S015 n.2 | Preserve the express seller/non-seller distinction. | Actual issuer role and any product-specific later authority remain unknown. |
| Transaction-value exemption | S009 corrected page; S016 complete note; S007 p. 53527 | The old staff dollar-ceiling assertion is not retained. | Separate TILA exemptions and product regulation remain outside this pass. |
| Rescission-only affirmative recovery | S007 pp. 53524, 53527; complete S014; S015 § B | Report the Commission’s rejection of that universal restriction. | No determination of controlling judicial treatment in a particular jurisdiction. |
| Attorney fees/costs | Complete S015 discussion and S017 opinion | Distinguish independent authority against the holder from seller-only derivative liability. | Exact state cause, fee law, posture, and judicial authority remain open. |
| Missing notice | S015 § C.4 and current § 433.2 | No categorical extinguishment or universal automatic-insertion conclusion. | State incorporation and remedies require their own primary-law pass. |
| Direct duties on lenders | S009’s historical proposal discussion; S015 § C.6 and n.46; S001 | Current direct command remains addressed to sellers; the 2019 review did not adopt the proposed expansion. | Original 1988 body not retrieved; other-law lender duties excluded. |
| Later status | S018 publication pages and targeted official-domain searches | No subsequently operative change was established by the retrieved materials. | This is not a finding that no later change, withdrawal, stay, or vacatur exists. |
Coverage ID · Assigned subquestion / major branch · Status and claim/example links · 45 data rows
| Coverage ID | Assigned subquestion / major branch | Status and claim/example links | Exact missing authority or facts | Next bounded permissible investigation |
|---|---|---|---|---|
| R012-P1-H001 | Complete operative Part 433 | Answered: C003–C010, C026, C028–C030 | Post-displayed-currency audit remains incomplete | Check subsequent official amendments only |
| R012-P1-H002 | Person, consumer, seller, creditor definitions | Answered generically: C005–C007 | Actual roles/purpose | No actual inquiry in this pass |
| R012-P1-H003 | Consumer credit contract / instrument | Answered generically: C008 | Actual complete instrument set | Generic document-structure research if separately needed |
| R012-P1-H004 | Financed-sale definition | Answered: C010–C011; E01 | Actual seller-creditor status | Separate product classification |
| R012-P1-H005 | Purchase-money definition and proceeds | Answered: C009, C029; E02 | Finance charge, use, relationship facts | Generic targeted clause interpretation |
| R012-P1-H006 | Referral boundary | Partial: C017–C019, C052; E12 | Complete S010 body; cooperative-course facts | Recover official 1976 policy and any final modification |
| R012-P1-H007 | Common control / contract / arrangement | Answered text; application held: C017–C018 | Actual relationship; S010 edge interpretation | Same bounded policy inquiry |
| R012-P1-H008 | Independent lender loan | Answered conditionally: C020; E03 | Whether independence is true | No actual provider inquiry authorized |
| R012-P1-H009 | Business and organizational purchases | Answered for stipulated pure cases: C021; E04 | Mixed purpose, purchaser category | Narrow mixed-purpose primary-law study |
| R012-P1-H010 | Real-estate purchase exclusion | Answered at generic boundary: C022; E05 | Nature of purchased interest | Product-specific real-property classification remains separate |
| R012-P1-H011 | Real-estate-secured goods/services | Answered conditionally: C022; E05 | Purchase and financing predicates | Narrow home-improvement financing law if assigned |
| R012-P1-H012 | Credit-card purchases | Answered distinction; product held: C025, C063; E13 | Actual issuer and transaction role | Product-specific classification, with 1977 distinction preserved |
| R012-P1-H013 | Seller open-end credit / historical exception | Answered: C026, C053 | Genuine pre-cutoff contract and non-cutoff terms | No modern blanket exemption inferred |
| R012-P1-H014 | Leases and ownership options | Answered conditional test: C024; E15 | Full lease and termination terms | Separate lease/product classification |
| R012-P1-H015 | Large transactions | Answered: C027, C057; E14 | Other coverage predicates | No dollar-threshold model required |
| R012-P1-H016 | Commodities/securities / utility statements | Partial: C023 | Modern sector-specific authority, especially utilities | Narrow sector inquiry; no blanket transplantation of TILA exemptions |
| R012-P1-H017 | Both notice clauses | Answered: C028–C030; § 4 | Actual document | No customer contract sought |
| R012-P1-H018 | Type size and bold form | Answered rule; application held: C030 | Actual typography | Generic form inspection only if later needed |
| R012-P1-H019 | Location / incorporation / multiple documents | Answered staff framework: C031–C032 | Actual incorporation and governing contract law | Targeted generic incorporation authority |
| R012-P1-H020 | Assent / electronic presentation | Unresolved by scope: worksheet W21 | Governing law and actual assent evidence | Separate electronic-contract pass |
| R012-P1-H021 | Seller acceptance / partial proceeds | Answered: C029 | Actual acceptance and loan connection | No factual transaction inquiry |
| R012-P1-H022 | Unlawful-practice command versus private claim | Answered distinction: C003–C004, C034–C035 | Specific cause, enforcement route, standing | Separate remedies/standing inquiry if authorized |
| R012-P1-H023 | Notice present but claim unknown | Answered: C035, C046; E06 | Underlying substantive claim | Jurisdiction/cause-specific public law |
| R012-P1-H024 | Notice missing | Partial: C045; E07 | Applicable incorporation/remedy law and controlling opinion | Single-jurisdiction missing-notice pass |
| R012-P1-H025 | Defensive use | Answered Commission framework: C036; E08 | Underlying claim and defensive procedure | Cause- and jurisdiction-specific defensive-use law |
| R012-P1-H026 | Affirmative recovery | Answered Commission framework: C037–C040; E08 | Claim, payments, procedural entitlement | Narrow published-opinion/underlying-law inquiry |
| R012-P1-H027 | Amount-paid limit | Answered textual measure; facts held: C038–C039, C048 | Payments and their legal attribution | Payment-component authority only; no actual computation |
| R012-P1-H028 | Holder/assignee relationship | Answered generic preservation: C034, C038 | Actual chain and capacity | No assignment-record search authorized |
| R012-P1-H029 | Independent assignee misconduct | Answered distinction: C041; E09 | Separate duty and cause | Separate actor/conduct-specific public-law pass |
| R012-P1-H030 | Attorney fees and costs | Answered federal interpretation; local law held: C042–C043; E11 | Fee source, party coverage, posture, controlling holding | Targeted fee-authority and published-opinion inquiry |
| R012-P1-H031 | Rescission | Answered negative universal prerequisite: C040 | Actual rescission law and entitlement | Separate rescission/remedy pass |
| R012-P1-H032 | Nonmonetary remedies | Partial: C044 | Remedy elements and jurisdiction | Specific remedy authority, not an award prediction |
| R012-P1-H033 | Time limits / accrual / defensive survival | Unresolved beyond distinction: C047; E15 | Applicable statute, accrual, tolling, recoupment law | Separate bounded time-law pass |
| R012-P1-H034 | Published majority opinions | Unresolved: C059; S019 | Successfully retrieved majority body and later-authority treatment | Recover an official published opinion; no docket-status query |
| R012-P1-H035 | 1975/1977 operative history | Answered for used changes: C049–C053 | Other historical pages not relied on | Only if a remaining historical issue requires them |
| R012-P1-H036 | Original 1988 review | Partial: C054 | Original notice body | Public official notice retrieval |
| R012-P1-H037 | 2019 review / proposed versus adopted | Answered: C055, C062 | Exhaustive subsequent amendment history | Official final-rule check |
| R012-P1-H038 | 2021/2022 interpretive changes | Answered within authority status: C057–C058 | Later withdrawal or judicial treatment not exhaustively audited | Targeted publisher-status / published-authority check |
| R012-P1-H039 | CFPB withdrawn-guidance condition | Not triggered by a relied-on circular/bulletin/advisory | No such instrument used; S006 is regulatory commentary | If one is used later, check its withdrawal register and publisher status |
| R012-P1-H040 | BNPL and full Reg Z classification | Excluded/held: C012, C060; E10 | Product structure and full relevant authority | Separate A012 product/BNPL component |
| R012-P1-H041 | Comparison matrix | Delivered: § 5 | All actual product facts remain unknown | No operational classification approved |
| R012-P1-H042 | Blank audit | Delivered: § 6, W01–W33 | All finding fields intentionally blank | No records request or identifier entry |
| R012-P1-H043 | Qualitative failure branches | Delivered: E01–E15 | No individual predicates established | No amount or deadline example necessary |
| R012-P1-H044 | Currentness / litigation status | Partial: C001–C002, C061 | Intervening issue/session-law audit and later published-authority review | Bounded public-primary updates |
| R012-P1-H045 | All other parent dimensions | Excluded as instructed: C064; § 12 | Unaddressed A012 authorities and facts | Separate authorized components |
Log item · Action / source · Result and effect · 14 data rows
| Log item | Action / source | Result and effect |
|---|---|---|
| L01 | S001 complete Part 433 | Successful complete HTML body read. Later separate § 433.1 URL, https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-433/section-433.1, returned an access screen. No challenge interaction; the earlier complete-part read supplied the definition body. |
| L02 | Initial House query-form URLs | These returned 404: https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1602&num=0&edition=prelim and https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1605&num=0&edition=prelim. Alternate title/section query forms also failed. S003’s publication-specific House URLs successfully recovered the necessary bodies. |
| L03 | Complete eCFR Supplement I | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/appendix-Supplement%20I%20to%20Part%201026 exceeded the tool’s content-size limit. S006 supplied the selected official commentary; no complete-appendix read claimed. |
| L04 | Four initial FTC historical-page clicks | Link-resolution errors occurred before the short landing pages were fully displayed. Reading those pages exposed the correct links; S007, S008, S011, and S012 were then successfully opened. These were recovered navigation failures. |
| L05 | S007 original 1975 scan | Parser returned zero text lines. Necessary selected pages were actually read as screenshots. No claim that all 25 pages were read. |
| L06 | S008, S011, S012 historical scans | OCR interleaved columns and unrelated material. Screenshots verified the correction, the seller-card footnote, and the adopted exemption text. Proposed petition text and separate dissent were distinguished from adopted action. |
| L07 | S010 1976 Federal Register issue | Full PDF failed at approximately 50 MB. Citation route unavailable. Alternate public-document attempts also failed: https://www.ftc.gov/system/files/documents/federal_register_notices/1976/08/41_fr_34594.pdf, https://www.govinfo.gov/content/pkg/FR-1976-08-16/html/FR-1976-08-16.htm, and https://www.govinfo.gov/content/pkg/FR-1976-08-16/text/FR-1976-08-16.txt. Material relationship-interpretation gap retained. |
| L08 | S013 1988 Federal Register issue | Full PDF failed at approximately 56 MB; archival slice unavailable; citation route led to access/CAPTCHA page. No interaction with the challenge. Original-body gap retained. |
| L09 | Screenshot attempts for oversized issues | The tool could not render the unsuccessful issue references as PDFs. These attempts supplied no additional body evidence. |
| L10 | S014, S016, S017 | Complete parsed opinions/note read through their final pages and footnotes. No pixel inspection claimed. |
| L11 | S015 2019 confirmation | Complete HTML body/footnotes read; official PDF checked as specified in the source register. Mirrors remain one source group. |
| L12 | S019 court opinion | Three official opinion URLs failed. Search metadata was discovery only. No headnote or search-excerpt holding substituted. |
| L13 | S020 alternative historical compilation | Index/TOC search did not recover S010. No substantive legal conclusion drawn from the absence of keyword matches. |
| L14 | Publication and update searches | Official FTC pages and targeted later-change searches inspected. They did not establish an exhaustive amendment, withdrawal, or later-litigation census. |
Assigned question · Principal answer locations · Claims · 6 data rows
| Assigned question | Principal answer locations | Claims | Sources | Remaining boundary |
|---|---|---|---|---|
| 1. Definitions, seller/consumer/contract coverage, financing patterns and exclusions | Claim register § 3.1–3.2; comparison matrix | C003–C027, C060, C063 | S001–S007, S009–S012, S015–S016 | S010 relationship-edge gap; actual product/purpose/arrangement; mixed-purpose and complete BNPL classification |
| 2. Complete notice clauses, format, placement, seller acceptance, presence/absence | § 4; worksheet W16–W21 and W31 | C028–C033, C045–C046 | S001, S009, S015 | Actual documents, typography, assent, incorporation, and state-law missing-notice consequences |
| 3. Preservation, defensive/affirmative use, amount paid, independent liability, fees, rescission, timing | Claim register § 3.3; E06–E11, E14–E15 | C034–C048, C056, C058–C059 | S001, S007, S009, S014–S017 | Underlying cause, governing law, payment attribution, judicial holdings, limitations and remedies |
| 4. Amendments, review history, current/proposed/historical status and conflicts | §§ 2, 8, 10 | C001–C002, C049–C063 | S001–S020 as individually qualified | Original 1976/1988 bodies, complete later-status audit, court-opinion access |
| 5. Comparison matrix, blank audit, qualitative failure branches, coverage and remaining questions | §§ 5–7, 9, 12 | Entire register; especially C060–C064 | Sources linked through claims | Analytical deliverables only; no individual classification or acceptance |
| Research/owner standards | §§ 1, 2, 10, 12 | C001–C002, C052, C054, C059–C064 | Retrieval record and source-status entries | No independent review, UI provenance verification, operational approval, or publication |
Check · Result · 15 data rows
| Check | Result |
|---|---|
| Complete operative Part 433 read | Yes, through the complete-part retrieval, including both notices and the entire § 433.3 exception. |
| Both financing routes kept separate | Yes. Seller-financed credit sales and qualifying seller-connected purchase-money loans were not collapsed. |
| Borrowed TILA definitions distinguished from wholesale incorporation of TILA exemptions | Yes. The corrected transaction-value issue is explicit. |
| Seller-issued versus non-seller cards preserved | Yes. The 1977 Commission footnote was read in pixels and used to qualify broad shorthand. |
| Staff guidance distinguished from Commission interpretation | Yes. The pamphlet’s express status and its corrected/conflicting statements are identified. |
| Underlying cause distinguished from notice preservation | Yes. No breach, fraud, warranty claim, or entitlement was assumed. |
| Defensive and affirmative uses distinguished | Yes. No automatic cancellation, payment-suspension, or recovery calculation. |
| Independent holder liability and fee authority separated from derivative liability | Yes. No universal cap or universal fee award stated. |
| Missing notice handled conditionally | Yes. Neither automatic extinguishment nor universal automatic incorporation asserted. |
| Proposed, retained, corrected, and historical materials separated | Yes. No proposal or dissent treated as adopted operative text. |
| Published-case body requirement honored | Yes by withholding the unverified holding. The court-source failure remains a substantive gap. |
| PDF text versus pixels distinguished | Yes. Exact visual-read bounds appear in the source register. |
| No legal arithmetic or deadline model | Yes. None necessary. |
| Source completeness / independent corroboration | Limited. Grouped formats are not independent sources; no independent reviewer performed this self-check. |
| Actual-person and operational boundaries | Preserved. No records lookup, decision, filing, contact, or publication. |
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.
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: superseded by accepted bounded P2 replacement with source and limit cells
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: conditional framework reviewed with source application and card dependency holds
Recorded check status: superseded by accepted bounded P2 replacement with source and limit cells
Recorded check status: conditional framework reviewed with source application and card dependency holds
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.
Recorded check status: fresh selected body
Recorded check status: fresh selected partial group
Recorded check status: fresh selected partial group
Recorded check status: fresh selected partial group
Recorded check status: fresh selected partial group
Recorded check status: fresh selected partial group
Recorded check status: fresh failed text representation
Recorded check status: fresh body route failure
Recorded check status: fresh selected partial group
Recorded check status: unreopened failed historical policy
Recorded check status: corrected by P2 S002 and prior actual coordinator scan with explicit read bounds
Recorded check status: fresh selected historical body
Recorded check status: unreopened original history gap
Recorded check status: fresh selected body
Recorded check status: fresh selected body
Recorded check status: fresh selected body
Recorded check status: fresh selected body
Recorded check status: fresh selected partial metadata group
Recorded check status: unreopened published opinion retrieval gap
Recorded check status: unreopened unused navigation history
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.
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
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.
No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.
reviewed with limits
Original saved Markdown SHA-256: 186c7e1effe319c3f71493d16970120706af1f0ceba4e4f3195907c7e3639f0e. Public formatting, private-reference removal and correction annotations are separate from that immutable original.