FIND THE EXPLANATION

Decode an MCA or revenue-based funding offer

Translate the funding offer into cash received, cash remitted, reconciliation rights, and personal exposure.

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DETAILED RESEARCH · EVIDENCE & LIMITS INCLUDED

New York’s published commercial-financing disclosure framework for sales-based financing

R028 · pass-01Captured 2026-10-2819 tables · 107 claim records · 29 source recordsScoped coordinator review completed

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

How to read the research →

SettleADebt R028 PASS-01

New York’s published commercial-financing disclosure framework for sales-based financing

The selected framework is Financial Services Law Article 8, implemented by 23 NYCRR Part 600. It reaches specified offers of sales-based financing, including certain arrangements with fixed payments and reconciliation. Its disclosures describe funding, financing cost, estimated payments and duration, prepayment consequences, and other prescribed matters. Disclosure coverage or compliance does not establish that a transaction is a loan or a sale, that its charges are lawful, that a business is properly licensed, or that an obligation is collectible. The chapter amendment expressly preserves otherwise applicable illegality and licensing rules. See C001, C008, and C010–C027 below. NYSenate.gov+2

Currentness result: I verified the current official statutory pages, the agency’s final-adopted regulatory text, the actual adoption notice, and the agency’s presently served regulatory listing and 2026 rule-review entry. I could not retrieve the state-linked NYCRR compilation because it returned access errors. Consequently, the report establishes the selected published final-adopted framework, with a disclosed gap in independently confirming the entire later-current regulatory compilation and amendment history. It does not certify the absence of later amendments, stays, vacatur, or other judicial developments.

Access date: October 27, 2026, America/Los_Angeles. A clock check during the closing source review returned 17:41:26 PDT on October 27, 2026, corresponding to 00:41:26 UTC on October 28, 2026. That is an access-session marker, not an enactment, amendment, or effective date.

No actual transaction, provider, broker, recipient, contract, account, license, property, or case was investigated. No transaction figures or historical-sales inputs were invented. This answer contains the substantive findings, sources, claims, comparisons, worksheet, branches, coverage crosswalk, and limitations.

1. Source register and exact read bounds

How to read the register

Every source identifier below has the prefix R028-P1-. Later references such as S009, C081, and E013 mean R028-P1-S009, R028-P1-C081, and R028-P1-E013.

For HTML sources, printed-page and PDF-index fields are not applicable, except where the HTML reproduces a bill’s printed page number. For PDFs, indexes are zero-based.

Sources S001–S008 are sections of one statutory instrument, not eight independent corroborating authorities. S009’s two URLs serve the same adopted instrument. S023–S025 belong to the same federal regulation and its official interpretations. Alternate publication formats are grouped and are not counted as independent corroboration.

All access dates in this register are October 27, 2026, America/Los_Angeles.

A. New York Financial Services Law: current official statutory body

The Senate pages for the selected Article 8 sections identify their most recent revision as January 7, 2022. That is publisher revision metadata; the operative statutory date is addressed separately in S016 and C003.

Source ID	Issuer, title, complete HTTPS URL	Exact substantive read extent	Jurisdiction, version, status, limits
R028-P1-S001	New York State Senate, Financial Services Law §801, Definitions. https://www.nysenate.gov/legislation/laws/FIS/801	Entire §801(a)–(k), including all purpose-reliance language and role, product, finance-charge, and offer definitions.	New York; current official statutory page, revision metadata 2022-01-07. Entire selected section read. NYSenate.gov
R028-P1-S002	New York State Senate, §802, Exemptions. https://www.nysenate.gov/legislation/laws/FIS/802	Entire introductory clause and exemptions (a)–(h).	New York; current statutory body, same revision metadata. Every listed exemption read; no actual exempt status established. NYSenate.gov
R028-P1-S003	New York State Senate, §803, Sales-based financing disclosure requirements. https://www.nysenate.gov/legislation/laws/FIS/803	Entire introduction and (a)–(i), including complete (c)(i)–(ii), (f)(i)–(ii), and (h)(i)–(ii).	New York; current statutory body. This is the principal sales-based disclosure statute. NYSenate.gov
R028-P1-S004	New York State Senate, §807, Other forms of financing disclosure requirements. https://www.nysenate.gov/legislation/laws/FIS/807	Entire introduction and (a)–(i).	New York; read to establish the residual-category boundary and regulatory authority. Other-product implementation remains held. NYSenate.gov
R028-P1-S005	New York State Senate, §808, Disclosure requirements for renewal financing. https://www.nysenate.gov/legislation/laws/FIS/808	Entire conditional introduction and (a)–(b), including the fixed-repayment prepayment-charge formula.	New York; current statutory body. No renewal transaction assumed. NYSenate.gov
R028-P1-S006	New York State Senate, §809, Required signature. https://www.nysenate.gov/legislation/laws/FIS/809	Entire section.	New York; current statutory body. Wording is preserved separately from the regulation’s consummation rule. NYSenate.gov
R028-P1-S007	New York State Senate, §810, Additional information. https://www.nysenate.gov/legislation/laws/FIS/810	Entire section, including separation of additional information, restrictions on “rate” and “interest,” and APR statements during an application.	New York; current statutory body. NYSenate.gov
R028-P1-S008	New York State Senate, §811, Rules and regulations; Article 8 index. https://www.nysenate.gov/legislation/laws/FIS/811; https://www.nysenate.gov/legislation/laws/FIS/A8	Entire §811 introduction and (a)–(d); Article 8 section index.	New York. Article 8 includes §§801–812. §§804–806 were not substantively investigated; §812 remedies remain held. NYSenate.gov+1

B. Adopted Part 600, adoption record, agency explanations, and history

Source ID	Issuer, title, complete HTTPS URL	Exact read extent and pages	Version, effectiveness, status, limits
R028-P1-S009	NYDFS, Disclosure Requirements for Certain Providers of Commercial Financing Transactions, final-adopted 23 NYCRR Part 600. https://www.dfs.ny.gov/system/files/documents/2023/01/rf_finservices_23nycrr600_text.pdf. Agency-linked alias: https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_text	Complete selected sections listed in the next table. PDF has 53 pages: numbered text pp. 1–52, followed by unnumbered certification at index 52.	New York; final-adopted text certified January 12, 2023; effective on publication of adoption notice. Final publication/effective date verified through S010. Parsed text read; no successful pixel inspection. Current-compilation gap S027 remains. dfs.ny.gov+1
R028-P1-S010	NY Department of State, New York State Register, February 1, 2023, Vol. XLV, Issue 5, Part 600 Notice of Adoption. https://dos.ny.gov/system/files/documents/2023/02/020123.pdf	Notice identification, filing/effective dates, action, authority, complete section-by-section adoption summary, comparison with prior publication, and beginning of comment assessment. Printed pp. 1–2; PDF indexes 6–7. The separate complete assessment was read through S012.	Historical official adoption publication. Filing January 12, 2023; effective February 1, 2023. The entire 88-page Register was not read. dos.ny.gov+1
R028-P1-S011	NYDFS, Part 600 Notice of Adoption. https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_notice	Items 1–6, printed pp. 1–2, indexes 0–1, including action, publication-based effectiveness, authority, and prior revised-proposal date. Later administrative fields were encountered but not used as a complete filing-form review.	Five-page agency adoption form. “Rev. 1/17” is the administrative form revision, not a merchant disclosure version or effective date. No form filled or submitted. Notice
R028-P1-S012	NYDFS, Assessment of Public Comments for Revised Proposed 23 NYCRR 600. https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_apc	Complete comments and agency responses 1–9, printed pp. 1–6, indexes 0–5.	Agency rulemaking explanation accompanying final adoption. Commenters’ positions are not law; agency responses are explanatory material, not substitutes for the enacted/adopted text. APC
R028-P1-S013	NYDFS, Regulatory Activity—Financial Services Law. https://www.dfs.ny.gov/industry_guidance/regulatory_activity/financial_services	Current preproposal, proposal, emergency, and final-adoption listings, particularly the Part 600 final-adoption row and notice that final postings may be retained only temporarily.	Current agency publication accessed in this session. Sections show different update dates: preproposal/emergency August 26, 2026; proposals July 22, 2026; final-adoption section November 1, 2023. These are publication metadata, not Part 600 operative dates or a complete amendment audit. Department of Financial Services
R028-P1-S014	NYDFS, 2026 Three and Five Year Review of Agency Rules. https://www.dfs.ny.gov/industry_guidance/regulatory_and_legislative_activities/agency_rules_3and5year_review	Part 600 review entry, printed p. 74, index 73.	Current agency review document describing the 2023 adoption. The invitation for comments on the rule is not itself an amendment. Other entries and the entire 75-page document were not substantively reviewed. dfs.ny.gov
R028-P1-S015	New York State Senate, enacted S5470B, Laws of 2020, chapter 369. https://www.nysenate.gov/legislation/bills/2019/S5470	Official action showing signature December 23, 2020; B-version original §802(g) threshold and original act §2, including printed bill p. 9 for the original 180-day effective-date clause.	Historical enacted-bill text and action record. The page also contains earlier bill versions; those were not conflated with B. No complete session-law or all-version comparison claimed. nysenate.gov+2
R028-P1-S016	New York State Senate, enacted S898, Laws of 2021, chapter 61. https://www.nysenate.gov/legislation/bills/2021/S898	Official signed-chapter action; amended §§802–803; complete act §§2–3 concerning saving language and effectiveness. The latter appear on printed bill pp. 6–7 in HTML.	Signed February 16, 2021. Establishes January 1, 2022 underlying statutory effectiveness, immediate rulemaking authorization, and preservation of other illegality/licensing requirements. Not a complete subsequent session-law audit. nysenate.gov+3
R028-P1-S017	NYDFS, February 1, 2023 release announcing adoption of commercial-financing disclosure regulation. https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202302011	Entire substantive release.	Historical agency announcement, used as context only. It does not replace the adoption notice or operative text. Department of Financial Services

S009: exact Part 600 clause and page map

Provision	Complete selected read	Printed pages	PDF indexes
§600.0	(a), (b)(1)–(8), including nested clauses	1–2	0–1
§600.1	All definitions (a)–(ap), including nested definitions	2–9	1–8
§600.2	(a)(1)–(4), (b)–(d)	9–10	8–9
§600.3	(a)–(d)	10	9
§600.4	(a)(1)–(3), (b)–(c)	11	10
§600.5	(a)–(p), all nested formatting and estimate conditions	11–14	10–13
§600.6	Introduction and (a)–(m), all required sales-based rows and conditions	14–18	13–17
§600.7	(a)(1)–(5), (b)(1)–(6)	18–19	17–18
§600.8	(a), (b)(1)–(6), (c)(1)–(3)	19–20	18–19
§600.9	(a)–(k), including all audit exclusions and thresholds	20–22	19–21
§600.10	Introductory routing paragraph only	22	21
§600.15	Introductory routing paragraph only	40	39
§600.17	(a)(1)–(6), (b)(1)–(2) examples, (c)(1)–(4)	47–48	46–47
§600.18	(a)–(c)	48–49	47–48
§600.19	Introduction and (a)–(d), complete threshold conditions	49–50	48–49
§600.20	(a)–(b)	50	49
§600.21	(a)–(g), all nested broker/financer/provider duties	50–51	49–50
§600.22	(a)–(d), all reporting provisions	51–52	50–51
§600.24	(a)–(b)	52	51
§600.25	(a)–(b)	52	51
Certification	Entire certification and proposal-publication dates	Unnumbered	52

Section 600.23 was encountered in full while reading adjacent provisions, but assignment rights and their UCC implementation remain outside this component. Other-product text incidentally returned with adjacent excerpts was not treated as a completed review of §§600.10–600.16.

C. Necessary cross-references and imported calculation rules

Source ID	Issuer, title, complete HTTPS URL	Read extent	Version/status and limits
R028-P1-S018	New York State Senate, UCC §2-A-103. https://www.nysenate.gov/legislation/laws/UCC/2-A-103	Definitions (1)(h), (h-1), and (j), especially the complete lease definition.	Current official page; revision metadata June 5, 2026. No actual lease/security-interest characterization or full UCC §1-203 investigation. NYSenate.gov
R028-P1-S019	New York State Senate, VTL §415 and §137-a. https://www.nysenate.gov/legislation/laws/VAT/415; https://www.nysenate.gov/legislation/laws/VAT/137-A	§415(1)(a)–(j) complete; additional adjacent definitions encountered. §137-a entire definition.	§415 revision metadata April 3, 2026; §137-a September 22, 2014. Definitions only for exemption boundaries; no licensing/registration records or actual dealer determination. NYSenate.gov+1
R028-P1-S020	New York State Senate, GBL §396-z. https://www.nysenate.gov/legislation/laws/GBS/396-Z	Current (1)(b), (c), (k); effectiveness notices; future-version (1)(c) compared.	Page revision metadata July 7, 2023. Current and future bodies are separately displayed: present version until June 30, 2028; future version effective June 30, 2028. Rental-company definition selected here; full rental-protection regime held. NYSenate.gov+1
R028-P1-S021	New York State Senate and ITS, State Technology Law Article 3, ESRA. https://www.nysenate.gov/legislation/laws/STT/A3; https://www.nysenate.gov/legislation/laws/STT/301; https://www.nysenate.gov/legislation/laws/STT/302; https://www.nysenate.gov/legislation/laws/STT/303; https://www.nysenate.gov/legislation/laws/STT/304; https://www.nysenate.gov/legislation/laws/STT/305; https://www.nysenate.gov/legislation/laws/STT/306; https://www.nysenate.gov/legislation/laws/STT/307; https://www.nysenate.gov/legislation/laws/STT/308; https://www.nysenate.gov/legislation/laws/STT/309; parallel ITS publication: https://its.ny.gov/nys-technology-law	Article index and §§301–309 across the official publications; particularly §302 signature definition, §§304–306 validity/records/evidence, all §307 exceptions, §308 confidentiality, and §309 voluntariness.	Current statute, with §307 showing current/future alternatives. Current §307(1) lasts until December 12, 2027; future text is separately labeled effective that date. General metadata for many sections is 2014-09-22; §307 metadata 2026-02-27. No actual electronic-signature implementation approved. NYSenate.gov+5
R028-P1-S022	New York ITS, Electronic Signatures and Records Act Regulation, 9 NYCRR Part 540. https://its.ny.gov/electronic-signatures-and-records-act-esra-regulation	§§540.1–540.6 complete; §540.7 encountered but not analyzed. Relevant private-signature provisions: §540.4(a)–(b), §540.5(a).	Agency-hosted text expressly labeled an unofficial convenience copy. No complete Part 540 amendment/effective-date audit. Government-specific certification and risk-assessment rules were not converted into universal private-business requirements. Office of Information Technology Services+2
R028-P1-S023	OFR/GPO eCFR and CFPB, Regulation Z §1026.4, Finance charge. https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.4; https://www.consumerfinance.gov/rules-policy/regulations/1026/4/	Regulatory body (a)–(f) read in full through eCFR; corresponding CFPB body compared. Interleaved commentary was encountered, but no complete commentary audit is claimed.	Federal rule imported by New York for calculation. eCFR currency displayed through October 26, 2026 on later retrieval; title-level last-amended metadata October 23, 2026 is not a §1026.4 amendment date. eCFR is an authoritative electronic publication but not the official legal edition. Nonselected overdraft-related differences between displays were not used to support an SBF proposition. ecfr.gov+4
R028-P1-S024	OFR/GPO eCFR and CFPB, Regulation Z §1026.22, Determination of annual percentage rate. https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.22; https://www.consumerfinance.gov/rules-policy/regulations/1026/22/	Body (a)–(d); official interpretations 22(a)(1)-1 through -5, 22(a)(2)-1, and 22(a)(3)-1.	Federal imported calculation authority. CFPB labels its page current. Official interpretations are identified as interpretations, not New York statutes or staff correspondence. No CFPB circular, bulletin, or advisory was relied upon. ecfr.gov+1
R028-P1-S025	OFR/GPO eCFR and CFPB, Regulation Z Appendix J. https://www.ecfr.gov/current/title-12/chapter-X/part-1026/appendix-Appendix%20J%20to%20Part%201026; https://www.consumerfinance.gov/rules-policy/regulations/1026/j/	Text of (a)(1)–(3), (b)(1)–(6), and textual iteration instruction (b)(9)(ii).	Imported actuarial framework. Image-based symbols/equations in (b)(7)–(9) were not pixel-inspected; the full example collection was not read. No APR solver or numerical transaction illustration is claimed. Consumer Financial Protection Bureau+3
R028-P1-S026	U.S. House OLRC, 15 USC §1602(g), and GPO 2024 edition of the same statute. https://uscode.house.gov/us/usc/119-121/t15/s1602/; https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partA-sec1602.htm	Complete §1602(g); adjacent definitions encountered.	OLRC states laws in effect through Public Law 119-121, October 9, 2026. GPO 2024 publication is historical corroborating text of the same instrument. Used only for Part 600’s as-if creditor calculation premise; actual federal creditor status held. uscode.house.gov+1

D. Current-compilation and guidance-search limitations

Source ID	Publisher/path and complete HTTPS URL	Retrieval/read result	Consequence
R028-P1-S027	State-linked NYCRR electronic compilation: https://govt.westlaw.com/nycrr/Index?bhcp=1&contextData=%28sc.Default%29&transitionType=Default. Located §600.1 page: https://govt.westlaw.com/nycrr/Document/I8bdf0115366511f085fee08d50b7f070?contextData=%28sc.Default%29&originationContext=documenttoc&transitionType=CategoryPageItem&viewType=FullText	Both returned HTTP 403; no substantive body read there.	Current codification placement is supported by official adoption and agency listings, but the later-current compiled Part 600 body was not independently retrieved.
R028-P1-S028	NYDFS industry-letter catalog. https://www.dfs.ny.gov/industry_guidance/industry_letters	Current catalog and relevant 2021/financing portions checked, together with targeted official-site searches.	No separately published official commercial-financing FAQ, standalone current merchant model package, method-election filing instruction, or opt-in reporting instruction was retrieved. This is a source gap, not a finding that none exists. Department of Financial Services+2
R028-P1-S029	Other unsuccessful public-page paths, listed in the failure log in §9 below.	No substantive reliance on failed pages or private reproductions.	Failures were not converted into absence-of-law conclusions.

2. Atomic claim ledger: substantive findings

All Part 600 propositions below refer to the retrieved final-adopted text, subject to the current-compilation limitation above. The “conditions/limits” column is part of each claim.

A. Codification, adoption, dates, and legal effect

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C001	The statutory framework is Financial Services Law Article 8; Part 600 implements its commercial-financing disclosure provisions.	This component reads §§801–803 and 807–811, not the entire law of commercial finance. Article 8’s other-product and enforcement components remain held.	S001–S008; S009 §600.0.
R028-P1-C002	The original enactment was Laws of 2020, chapter 369, signed December 23, 2020.	Its original 180-day effective-date clause and lower amount threshold are historical; they are not substituted for the amended law.	S015, official action; B-version §802(g), act §2.
R028-P1-C003	Laws of 2021, chapter 61, signed February 16, 2021, amended the framework and set the underlying act’s operative date to January 1, 2022.	The amendment also authorized implementing rulemaking immediately; its own effectiveness provision coordinates the amended statutory sections with the underlying act.	S016, act §§2–3.
R028-P1-C004	January 7, 2022 on the selected Senate pages is revision metadata.	It is not the statutory operative date, final-rule adoption date, or compliance date.	S001–S008 compared with S016.
R028-P1-C005	Part 600 was filed January 12, 2023 and became effective February 1, 2023; its six-month compliance interval yields August 1, 2023.	August 1 is the calendar result of §600.25(b) applied to the verified February 1 publication date. Effectiveness and compliance are different events. No actual transaction deadline is inferred.	S010 notice; S009 §600.25(a)–(b).
R028-P1-C006	The currently served DFS listing and its 2026 rule-review entry continue to identify the February 1, 2023 Part 600 adoption.	Neither publication supplies a complete later-amendment, session-law, or judicial-history audit. The unavailable NYCRR compilation remains a material currentness gap.	S013, S014, S027.
R028-P1-C007	The 2021 proposal and September 14, 2022 revised proposal are historical stages, not the final operative text.	Their dates are verified in the certification/adoption material. Their complete bodies were not read, and no full proposal-to-final redline is claimed.	S009 certification; S010–S012.
R028-P1-C008	The disclosure enactment does not authorize otherwise illegal transactions or dispense with an otherwise required license.	It therefore cannot alone settle loan characterization, usury, licensing, enforceability, or collectibility. Those questions require different authority and facts and remain held.	S016 saving clause; S001 §801(h).
R028-P1-C009	The agency’s comment assessment can explain drafting choices but does not replace statutory or regulatory language.	Its response concerning retention uses narrower terminology than §600.21(d); that difference is preserved below. No staff statement is treated as legislation.	S012 responses 1–9; S009 §600.21(d).

The actual adoption notice, the delayed compliance clause, and the chapter amendment support these distinctions directly. dos.ny.gov+4

B. Scope, roles, nexus, thresholds, and every statutory exemption

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C010	Commercial financing is financing whose proceeds the recipient does not intend to use primarily for personal, family, or household purposes.	The provider may rely on a separate signed statement, a signed/consented application or other document, or an oral statement documented in the application file. Electronic consent is permitted. The statute does not require checking later actual use against that statement.	S001 §801(b).
R028-P1-C011	Sales-based financing includes repayment varying as a percentage of sales/revenue and fixed-payment financing with reconciliation adjusting payment to such a percentage.	A product label alone does not establish the definition. Fixed scheduled debits alone do not exclude the category when the defined reconciliation arrangement exists.	S001 §801(j); S009 §600.1(ah), (ap)(1).
R028-P1-C012	A provider extends a specific offer; unless exempt, the definition also includes a person who solicits and presents specific offers for a third party.	Making an offer or giving disclosures alone does not mean originating, making, funding, or providing the financing. The regulation includes a financer communicating through an agent or broker with an expectation of onward communication.	S001 §801(h); S009 §600.1(ad).
R028-P1-C013	A financer is the person providing or to provide the financing; a broker is a compensated participant in the specified intermediation activities.	Broker activities include negotiation, advice, preparation/gathering/delivery of documents, communications, or obtaining signatures. Financer, recipient, and recipient’s agent are excluded from that broker definition. Mere role labels do not resolve overlapping provider duties.	S009 §600.1(j), (q).
R028-P1-C014	A recipient applies and receives a specific offer; an authorized representative can qualify, but a broker cannot be the recipient.	For one offer, controlled, controlling, or commonly controlled recipients are included together only when the single offer is conveyed simultaneously in the same writing. This is not general aggregation of all affiliates or all transactions.	S001 §801(i); S009 §600.1(ab), (ae).
R028-P1-C015	The disclosure nexus is a recipient business principally directed or managed from New York, or a natural-person recipient legally resident in New York.	A provider may rely on the specified written representation/business address; for a natural person, the specified government-ID address or written legal-address representation. Provider location alone is not the adopted nexus test. No actual address or ID was sought.	S009 §600.24(a)–(b); S012 response 1.
R028-P1-C016	Financial institutions described by §801(f) are exempt. The regulation includes entities majority-owned through voting power by such an institution, directly or indirectly.	The statutory bank, trust, industrial-loan, savings, and credit-union categories contain charter/authorization conditions, including authorization to transact business in New York. Mere affiliation or use of a banking service is not the stated majority-voting-power condition.	S001 §801(f); S002 §802(a); S009 §600.1(r); S012 responses 2–3.
R028-P1-C017	A technology-services provider can be exempt when serving an exempt entity’s financing program.	It must have no interest, and no arrangement or agreement to purchase an interest, in financing extended through that program. The exemption is capacity- and condition-specific.	S002 §802(b).
R028-P1-C018	A lender regulated under the federal Farm Credit Act is exempt.	The statute requires that regulated status; no actual institution’s status was investigated. The entire federal Farm Credit regulatory system was not independently analyzed.	S002 §802(c).
R028-P1-C019	A commercial-financing transaction secured by real property is exempt.	The clause does not say that any collateral, guarantee, or security interest is enough. No actual security or property facts were investigated.	S002 §802(d).
R028-P1-C020	A lease within UCC §2-A-103 is exempt.	That definition concerns transfer of possession/use of goods for a term and consideration, excluding a sale or retention/creation of a security interest. A security-interest “lease financing” is separately defined in Part 600. Actual characterization remains held.	S002 §802(e); S018 §2-A-103(1)(j); S009 §600.1(w).
R028-P1-C021	A person or provider making no more than five commercial-financing transactions in New York in a twelve-month period is exempt.	The unit is not stated as five sales-based transactions, five offers, or five transactions in a calendar year. Section 600.1(am)’s advances definition expressly addresses §801(c), so it cannot silently settle the §802(f) counting issue.	S002 §802(f); S009 §600.1(am).
R028-P1-C022	An individual commercial-financing transaction over $2,500,000 is exempt under the amount clause.	Exactly $2,500,000 is not exempt under this clause alone. The regulation uses the aggregate amount available under the agreement, not a particular advance; ordinary sales-based financing uses “amount financed” under §600.19(d).	S002 §802(g); S009 §600.1(b), §600.19(d).
R028-P1-C023	Other categories have different threshold measures.	Open-end uses approved credit limit. Asset-based/factoring treatment requires the specified general agreement, limit above $2.5 million, and timely written reasonable expectation that more than $2.5 million will be advanced and outstanding; without all conditions the offer is deemed at or below the threshold. Those categories are boundary reads, not completed product studies.	S009 §600.19(a)–(c), all nested clauses.
R028-P1-C024	The dealer/rental-company exemption requires the specified recipient or affiliate status and an agreement or open-end plan of at least $50,000.	It includes loans made pursuant to that transaction. It is not a blanket exemption for financing a vehicle. Dealer and rental-company definitions were read; no actual dealer, affiliate, vehicle, or registration status was inferred.	S002 §802(h); S019 §415(1), §137-a; S020 §396-z(1)(b), (c), (k).
R028-P1-C025	Part 600 excludes a transaction subject to TILA for which a TILA-compliant disclosure is provided.	Both predicates matter. Voluntarily using a TILA-style form for a transaction not subject to TILA does not establish this exclusion.	S009 §600.1(m); S012 response 7.
R028-P1-C026	Sales-based, closed-end, open-end, factoring, and lease definitions must be distinguished before selecting a disclosure format.	Open-end requires the stated repeat-credit/replenishment features; factoring concerns existing legally enforceable payment claims for supplied goods/rendered services. Some sales-based arrangements also meet the closed-end definition; §600.10’s introduction routes such arrangements away from its ordinary closed-end format.	S001 §801(a), (c), (d), (j); S009 §600.1(k); §600.10 introduction.
R028-P1-C027	Section 600.6 expressly excludes asset-based lending that also meets the sales-based definition from its sales-based table.	Asset-based lending has the advance/forwarding-payment conditions in §600.1(e), (s), and its own §600.15 route. This report does not resolve that separate product’s full disclosure method.	S009 §600.1(e), (s); §600.6 introduction; §600.15 introduction.

These are conditional coverage rules. No combination of missing facts has been treated as proof either of coverage or of exemption. NYSenate.gov+5

C. Specific offers, changed terms, signatures, brokers, and funding distinctions

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C028	The statute’s specific offer is recipient-informed financing terms, including price or amount, binding on the provider if accepted, subject to stated specific requirements.	The statute’s wording must be preserved; it does not itself establish that any communication was accepted or all conditions were fulfilled.	S001 §801(k).
R028-P1-C029	The regulation defines a specific offer as a written recipient-informed communication combining a payment/financing amount with a rate, price, or cost.	The communication must be binding if accepted. Name, address, or general interest alone is not the relevant recipient information. This is more detailed than the statute’s “price or amount” wording.	S009 §600.1(ai).
R028-P1-C030	A covered provider supplies the prescribed sales-based disclosures when extending the specific offer.	Ordinary advertisement/inquiry labels are not decisive; the actual statutory and regulatory offer predicates govern. No actual communication was examined.	S003 introduction; S009 §600.1(f)(1), §600.3(a).
R028-P1-C031	Simultaneous offers and customizable menus have a selection rule.	When the recipient selects from multiple qualifying options, disclosure timing is tied to selection; the provider need provide disclosures for the particular offer elected for pursuit. This does not authorize omitting disclosure for the selected offer.	S009 §600.1(f)(1), (4).
R028-P1-C032	A written offer to change an already consummated financing requires disclosure before agreement if the changes increase finance charge or APR.	The express exception is proposed terms resolving the recipient’s default. This clause is not a general exemption for every renewal, workout, or new financing.	S009 §600.1(f)(2).
R028-P1-C033	A changing payoff amount already included in a disclosure does not, by itself, require a new disclosure before consummation.	Section 600.5(n) is limited to that cause. The funding row must give the applicable warning about changing or unknown payoff deductions. Other changed terms must be evaluated separately.	S009 §600.5(n); §600.6(b)(3)(iii)–(iv).
R028-P1-C034	A special draw-by-draw rule exists for certain retailer/supplier open-end financing.	All three conditions are required: draw at purchase, variable rate/price depending on retailer/product, and election to use §600.10 instead of §600.11. This is a boundary exception, not a general sales-based funding rule.	S009 §600.1(f)(3)(i)–(iii).
R028-P1-C035	The application-stage cost-metric restriction and the APR statement trigger are not identical.	Nonannual metrics cannot be presented as a “rate” throughout the defined application process; the adopted rule ties the APR-alongside-rate/amount requirement to quotation of a specific offer and subsequent application communications.	S007 §810; S009 §600.1(f)(1), (n), §600.3(b); S012 response 9.
R028-P1-C036	Section 809 requires the recipient’s signature on required disclosures before authorization to proceed further with the transaction application.	That statutory wording is not rewritten as “only at funding.” Electronic signature is expressly allowed.	S006 entire section.
R028-P1-C037	Section 600.18 requires the signature before consummation and, for a consummated transaction with multiple negotiating disclosures, only on the final corresponding disclosure.	It does not require signatures for transactions that are not consummated. This is the adopted implementation; the difference from §809’s application-stage wording remains visible.	S009 §600.18(a), (c).
R028-P1-C038	An entity recipient’s disclosure may be signed by an authorized natural person who is not a broker.	Authority to sign is a factual predicate. Broker delivery or obtaining a signature does not make the broker the permissible recipient signatory.	S009 §600.18(a); S001 §801(i).
R028-P1-C039	Electronic signatures may be used, including qualifying button/checkbox processes; electronically consummated transactions may use electronic or fax signatures.	The process must satisfy ESRA. Electronic disclosure/signature is allowed regardless of the later agreement’s delivery medium. No actual click, authority, intent, or authentication was established.	S009 §600.5(b), §600.18(a)–(b); S021 §302(3), §304; S022 §540.4(a)–(b).
R028-P1-C040	The prescribed signature legend acknowledges receipt of information.	Its presence or a button labeled “Accept” does not, by itself, prove substantive contract acceptance, contract formation, satisfaction of offer conditions, or funding.	S009 §600.5(b), read with S001 §801(k) and S009 §600.18.
R028-P1-C041	Electronic execution requires an automatic date stamp and a signed copy the recipient can retain indefinitely.	Merely sending a link does not establish fulfillment of these conditions. ESRA also requires the signature’s association with the record and intent to sign; statutory exceptions and voluntariness remain relevant.	S009 §600.5(j); S021 §§302, 307, 309; S022 §540.4(b).
R028-P1-C042	Required disclosures are separate from contracts and other disclosure documents.	They may travel in one package; electronic material may share an attachment/link if separated by page breaks. Additional voluntary financing information cannot simply be inserted into the required disclosure.	S009 §600.5(e); S007 §810.
R028-P1-C043	A required amount-financed itemization is a separate, immediately following document that need not be signed.	Its trigger is amount financed greater than recipient funds. The unsigned exception does not eliminate the main disclosure’s signature requirements.	S009 §600.17(a), (c)(1)–(4).
R028-P1-C044	A broker receiving the financer’s disclosures must transmit them unaltered before communicating the specific offer and return transmission evidence, including time.	Alternatively, the broker may obtain confirmation that the financer supplied the disclosures directly. Delivery obligations remain distinct from signature and contract acceptance.	S009 §600.21(b)–(c).
R028-P1-C045	A financer giving a broker a specific offer must supply compliant disclosures and establish reasonable procedures for timely recipient delivery.	Direct delivery to the recipient is an alternative under §600.21(e). The listed contractual, investigation, and discontinuation procedures are examples of reasonable procedures, not an assertion that every example is invariably mandatory.	S009 §600.21(a), (e).
R028-P1-C046	The adopted text requires retention of specified disclosure and transmission records for at least four years.	Financer transmission-evidence retention runs from presentation to the recipient; §600.21(d) separately requires a provider to retain generated disclosures from presentation to recipient or provision to broker. The APC’s statement that retention applies only to financers is narrower and is not used to erase the adopted wording.	S009 §600.21(a)(2), (d); S012 response 5.
R028-P1-C047	When a broker is involved, the provider must explain in writing how and by whom the broker will be compensated.	The final rule does not prescribe a dedicated broker-compensation row or fixed form for that explanation. That does not eliminate separately applicable finance-charge/itemization treatment.	S009 §600.21(f); S012 response 5.
R028-P1-C048	Section 600.21 does not require a broker to evaluate the financer’s disclosure accuracy or create broker liability for the financer’s noncompliant disclosure.	It does not limit liability arising from the broker’s own representations. No actual liability conclusion is made.	S009 §600.21(g)(1)–(3).
R028-P1-C049	Delivery, receipt, signed acknowledgment, offer acceptance, consummation, and funding are separate analytical events.	The selected texts impose event-specific duties but do not provide evidence that any event occurred. No universal waiting period, actual funding deadline, or actual contract-formation result is established here.	S001 §801(h), (k); S003 introduction; S006; S009 §§600.5, 600.18, 600.21.

The broker sequence and signature exceptions are explicit in the adopted body; they should not be collapsed into a generic “signed at funding” rule. dfs.ny.gov+5

D. Funding, finance charge, APR, and other cost measures

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C050	For sales-based financing, amount financed is funds provided to the recipient or on the recipient’s behalf, less prepaid finance charge.	It is not necessarily cash deposited directly to the recipient. A prepaid finance charge includes qualifying separately paid charges before/at consummation or charges withheld from proceeds.	S009 §600.1(a)(1), (ac).
R028-P1-C051	Recipient funds are the net funds provided directly to the recipient.	They exclude third-party payments, including broker payments, and known payoffs/paydowns. For changing obligations, the provider may use the balance at disclosure. Actual later funding may therefore differ.	S009 §600.1(af).
R028-P1-C052	Finance charge is the dollar cost of financing and imports Regulation Z’s charge rules on an as-if consumer-credit/creditor basis.	A non-factoring receivables-purchase discount is also included. Importing that calculation does not determine that TILA actually applies or that the transaction is legally a loan.	S001 §801(e); S009 §600.2(a)(1)–(2); S023; S026 §1602(g).
R028-P1-C053	Finance-charge treatment depends on the charge’s function and conditions, not its label alone.	Regulation Z generally includes incident-to/condition-of-credit charges, with rules for third-party charges and specified exceptions. Cash-comparable charges, application fees charged to all applicants, and actual unanticipated late/default charges have distinct rules.	S023 §1026.4(a), (b), (c)(1)–(2).
R028-P1-C054	Insurance, debt-cancellation, security-related official fees, and similar exclusions are conditional.	For example, voluntary credit-insurance/debt-cancellation exclusions require the specified disclosures and affirmative request; property-insurance and itemized security-fee exclusions have their own conditions. No particular fee was classified.	S023 §1026.4(d)–(f), with complete surrounding conditions read.
R028-P1-C055	Part 600 prevents double counting and excludes avoidable charges not imposed incident to credit.	“Avoidable” alone is not a universal exclusion. For benchmark-plus-margin charges that cannot be known in advance, the rule uses the benchmark at disclosure plus the margin for unknown future periods.	S009 §600.2(b)–(d); §600.5(l).
R028-P1-C056	APR measures financing cost annually using both the amounts and timing of value received and payments made, including finance charges.	Section 600.3 permits the actuarial or United States Rule method; §803 requires an estimate based on the prescribed sales/payment/term projection. It does not authorize substituting a factor or dollar charge for APR.	S003 §803(c); S009 §600.3(a)–(c); S024 §1026.22(a)(1).
R028-P1-C057	The actuarial and U.S. Rule methods differ in treatment of unpaid accrued finance charges.	The official interpretation explains capitalization under the actuarial method and separate accumulation under the U.S. Rule. These are calculation conventions, not conclusions about lawful interest or permissible contractual capitalization.	S024 official interpretations 22(a)(1)-1 through -3.
R028-P1-C058	Appendix J’s annualization depends on a correctly determined unit period and payment timing.	The text read specifies nominal annualization and unit-period conventions; daily, weekly, monthly, and semimonthly periods have distinct annual units. Its month-fraction convention is not the same as Part 600’s optional 30.4-day monthly-cost conversion. No numerical solver was run.	S025 Appendix J(a), (b)(1)–(6); S009 §600.1(h), (p).
R028-P1-C059	A sales split percentage, a financing factor, an annual interest rate, APR, finance charge, and total payment answer different questions.	Part 600 defines the split percentage for payment/true-up calculations. It does not supply a universal factor formula or denominator. Section 810 restricts presenting nonannual cost metrics as a “rate” and using “interest” for nonannual percentages.	S007; S009 §600.1(u), (ak), §600.3.
R028-P1-C060	Multiple-payment-option disclosures use the minimum contractually permitted payments; demand balances have a prescribed assumed-term rule.	Demand uses one year unless faster repayment is reasonably anticipated; an alternate maturity stated in the legal obligation controls. No such contractual option or demand obligation is assumed to exist.	S009 §600.20(a)–(b).

The federal provisions are used because the New York statute and rule expressly import them. Their use here does not introduce a separate federal consumer-credit coverage or preemption determination. dfs.ny.gov+5

E. Every selected sales-based disclosure item and format condition

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C061	The sales-based format is a prescribed ten-row, three-column table, subject to its express additional-row rule.	It applies to §600.6 transactions; sales-based asset-based lending is excluded from this format. Some cells are merged as prescribed. This report is not a completed disclosure form.	S009 §600.6 introduction, (a)–(m).
R028-P1-C062	The funding row gives amount financed and, when lower, net recipient funds with the required itemization reference.	It also requires applicable explanations of changing known payoffs, unknown mandatory third-party payoffs, and same-provider renewal charges.	S003 §803(a); S009 §600.6(b).
R028-P1-C063	The APR row explains annualized estimated cost and identifies the assumed monthly income through the relevant payment channel/mechanism.	It warns that actual income and effective APR may vary. If no finance-charge component is interest-based, the additional prescribed explanation distinguishes APR from an interest rate.	S009 §600.6(c)(1)–(4).
R028-P1-C064	The finance-charge row states dollar financing cost.	A statement that the charge will not increase with longer repayment is optional only when it will not increase under any circumstance if repayment takes longer than estimated.	S003 §803(b); S009 §600.6(d).
R028-P1-C065	The total-payment row states total estimated contractual payments.	Section 803(d) separately defines total repayment as disbursement plus finance charge. The different amount concepts must not be silently equated without tracing deductions and charges.	S003 §803(d); S009 §600.6(e).
R028-P1-C066	The payment row includes average estimated periodic payment/frequency, irregular payment dates/amounts, and reasonably anticipated true-up dates/amounts.	A short explanation is required when necessary to explain why estimated payments differ from actual obligations.	S003 §803(f); S009 §600.6(f).
R028-P1-C067	The payment-terms row explains daily-payment days, applicable sales-split operation, and true-up mechanics.	If a true-up exists, it must explain the preset-payment derivation, mechanism and available contract reference, and minimum payments. A no-minimum/no-fixed-schedule statement is conditional on the actual terms.	S009 §600.6(g).
R028-P1-C068	The term row gives estimated duration and explains the income assumptions underlying it.	The estimate is the time for projected periodic payments to reach required repayment; it is not necessarily an unconditional maturity or prediction of actual payoff.	S003 §803(e); S009 §600.6(h), §600.1(al)(4).
R028-P1-C069	The first prepayment row states whether finance charges beyond accrued unpaid interest remain payable and the maximum noninterest amount.	The negative statement applies only when the contrary condition does not occur at any time during the term. Statutory percentage disclosure remains separately relevant under C074.	S003 §803(h)(i); S009 §600.1(y)(1), §600.6(i)–(j).
R028-P1-C070	The second prepayment row states additional prepayment fees outside finance charge or gives the prescribed negative answer.	It must address fees applicable at any time during the term, not merely on the offer date.	S003 §803(h)(ii); S009 §600.6(k).
R028-P1-C071	The collateral row describes collateral requirements or security interests, if any.	Disclosure of a security provision does not establish its attachment, validity, perfection, priority, or enforceability.	S003 §803(i); S009 §600.6(l).
R028-P1-C072	Nonmonthly periodic payments require an additional estimated-monthly-cost row immediately after the total-payment row.	If estimated monthly cost varies, the row lists the estimates and applicable periods and explains the calculation. Monthly cost includes projected payments; it is not merely monthly fees.	S009 §600.1(p), §600.6(m).
R028-P1-C073	Section 803(g) requires a description of all other potential fees/charges outside finance charge, including draw, late, and returned-payment fees.	Section 600.6 does not expressly allocate a general other-fees row. That layout gap does not establish permission to omit the statutory disclosure. Placement remains unresolved on the retrieved materials.	S003 §803(g), compared with S009 §600.6(a)–(m).
R028-P1-C074	Section 803(h)(i) requires both the percentage of unpaid finance charge retained on early payoff/refinance and the maximum dollar amount.	Section 600.6(j) expressly supplies a maximum-dollar statement but does not separately spell out the statutory percentage field. This is a preserved statute/layout gap.	S003 §803(h)(i), compared with S009 §600.6(j).
R028-P1-C075	Required same-provider payoff as a condition of renewal triggers §808’s renewal disclosures.	For fixed total repayment, the statute specifies its own prepayment-charge calculation and requires disclosure of actual disbursement reduction. No actual renewal or numerical charge is inferred.	S005 §808 introduction, (a)–(b).
R028-P1-C076	The adopted renewal-row calculation does not use the same stated base as §808(a).	Section 600.6(b)(3)(v) refers to a pro rata fee based on the fraction of original amount financed already repaid; §808(a) uses renewal payoff as a fraction of original total repayment, less forgiveness. These are not silently reconciled or numerically implemented here.	S005 §808(a); S009 §600.6(b)(3)(v).
R028-P1-C077	When amount financed exceeds recipient funds, a separate itemization must be substantially similar to the rule’s example and contain the listed minimum components.	Components include direct funds, applicable credit to the recipient’s existing obligation, third-party disbursements, their sum, prepaid finance charges/purpose, and amount financed. The rule permits generic descriptions for specified payee categories. No account number, payee, or transaction value was entered.	S009 §600.17(a)–(c).
R028-P1-C078	Formatting requirements include a prominent summary heading, prescribed signature legend where applicable, numerical presentation, term units, APR rounding, font/column rules, outlined cells, and short-explanation limits.	Term ≤1 year is in days from the day after consummation through final payment; longer terms use years/months with remaining-day month fractions to two decimals. APR is to two decimals; no fractional-cent dollar display. Fonts, 3:3:7 column safe format, and ≤60-word short explanations have their stated conditions and permitted accessibility/medium deviations.	S009 §600.5(a)–(j), (m), (o)–(p).

The prescribed table and itemization are regulatory requirements with embedded examples. They are not an executed contract, an agency-approved actual transaction, or proof that disclosure occurred. NYSenate.gov+5

F. Complete selected projection, reconciliation, audit, reporting, and tolerance rules

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C079	Section 803 permits historical or opt-in sales projections and requires notice to the superintendent of the method intended across sales-based offerings.	The retrieved statutory text establishes the notice obligation; a separate current public election form, channel, or filing instruction was not retrieved. No filing or actual election is inferred.	S003 §803(c); S028 search bound.
R028-P1-C080	The historical projection averages receipts through the relevant payment channel plus other-channel receipts that the contract would previously have required to be redirected there.	It is not automatically total business revenue, bank deposits, or a hand-selected gross-sales figure. “Average” means arithmetic mean unless otherwise stated.	S009 §600.1(g), (z); §600.8(b)(1).
R028-P1-C081	The ordinary regulatory historical window is fixed at four to twelve months, either preceding the offer or the same number of highest-volume months in the preceding twelve months.	The rule permits fixing the period for all transactions or by recipient industry, financing amount, or both. The statute’s outer wording is one to twelve months; both texts are preserved. Exceptions below prevent treating four observed months as an unconditional minimum dataset.	S003 §803(c)(i); S009 §600.8(b)(2).
R028-P1-C082	For a business operating less than twelve months, the provider may average the months of operation.	No minimum operating history, actual business age, or actual sales data is invented. A zero-data calculation is not supplied.	S009 §600.8(b)(3).
R028-P1-C083	Historical averaging permits specified exclusions.	They are: a below-average month with a provider-determined cause unlikely to recur; a month lacking requested documentation; and oldest beginning months for which documentation is neither required nor received. Declining the nonrecurring-event exclusion carries the stated no-liability provision.	S009 §600.8(b)(4)(i)–(iii).
R028-P1-C084	Additional documented months may be included on an all-or-none basis, excluding nonoperating months.	This is not authority to select only favorable additional documented months. It operates in addition to the fixed-period rules.	S009 §600.8(b)(5).
R028-P1-C085	The fixed-period decision must be recorded with its effective date, versioned when changed, and retained while effective and for four years afterward.	This is a provider’s required internal record, not a record obtained or invented in this investigation. The adopted text’s cross-reference problem is recorded in C103.	S009 §600.8(b)(6).
R028-P1-C086	Additional assumptions under either sales-projection method must use the best reasonably available information, identify estimates, and explain assumptions.	The general §600.5(k) estimate clause expressly excludes sales-based financing; its sales-based counterparts are §600.8(c) and §600.9(k).	S009 §§600.5(k), 600.8(c), 600.9(k).
R028-P1-C087	A true-up can be a payment to the recipient, a charge, or an adjustment of periodic payments.	For sales-based financing, the mechanism involves preset payments and a contract permitting recipient-requested or financer-initiated adjustment so total payment more closely reflects the contractual split percentage. It is not defined solely as a refund.	S009 §600.1(an), (ap)(1).
R028-P1-C088	Reasonably anticipated true-ups require a reasonable basis informed by similar-contract performance and financer policies/procedures.	A printed reconciliation provision alone does not prove that a refund will occur, an adjustment was requested or granted, or reconciliation works effectively in practice.	S009 §600.1(ao).
R028-P1-C089	Estimated payments and anticipated true-ups must account for specified payments, changing split percentages, minimums, contractual shortfall-threshold payments, and reasonably anticipated finance charges.	The threshold-payment item excludes default fees. No payment schedule or provider policy is assumed.	S009 §600.7(a)(1)–(5).
R028-P1-C090	Estimated monthly cost, finance charge, term, and APR use the selected projection and account for those payment features plus reasonably anticipated true-ups.	A preset debit cannot simply be treated as the final actual payment stream if the rule requires anticipated adjustments. The retrieved §600.7 internal-projection cross-reference is defective; see C103.	S009 §600.7(b)(1)–(6).
R028-P1-C091	Opt-in projections use the provider’s internal estimate for the contract’s particular payment channel, based on best reasonably available information.	Opt-in is subject to the audit/reporting process; it is not unrestricted discretion to select an attractive APR.	S003 §803(c)(ii); S009 §600.9(a)–(d).
R028-P1-C092	Every twelve months, an opt-in provider audits sales-based financings paid off in the preceding twelve months using internal estimates, including contractual true-ups.	The cohort excludes transactions with specified court/arbitration action, stopped collection after determined breach, or agreed contract modification. These are generic cohort rules; no case or collection record was queried.	S009 §600.9(e)(1)–(3).
R028-P1-C093	Retrospective APR ordinarily uses the fully repaid contract’s known payment/fee dates and amounts.	For the audit, the provider may disregard an early payoff lump sum and assume continued periodic payments averaging past periodic payments. Consequently, an audit retrospective APR can incorporate this permitted counterfactual rather than literal realized cash flows.	S009 §600.1(ag); §600.9(f).
R028-P1-C094	Audit APR spread is the relative difference between retrospective and disclosed APR; each audit’s measure is the median spread.	The denominator is disclosed APR, not a percentage-point comparison. No zero-denominator convention is supplied by the selected text.	S009 §600.9(g)–(h).
R028-P1-C095	The rule weights annual audited median spreads by transaction count over the last three, five, and seven audits.	Calculations are required only after enough audits exist. Thresholds are greater than 15%, 10%, and 5%, respectively. The clauses direct use of the historical method for 24 months unless the provider determines historical treatment would have yielded a higher weighted average.	S009 §600.9(i)(1)–(3).
R028-P1-C096	Returning to opt-in after that 24-month period requires a good-faith effort to improve the internal projection method’s accuracy.	Passage of time alone does not satisfy the stated reentry condition. No provider history is assumed.	S009 §600.9(j).
R028-P1-C097	The annual opt-in report is due on or before April 30, beginning in 2025, for a provider that used opt-in during the preceding calendar year.	It is subscribed and affirmed under penalties of perjury and covers the preceding calendar year. This establishes a generic recurring rule, not an actual filer or overdue filing.	S009 §600.22(a).
R028-P1-C098	Reporting includes disclosed estimated and completed-transaction retrospective APRs, annual mean differences weighted by financing amount and unweighted, unusual circumstances, and additional prescribed information.	These reporting means and financing-amount weights differ from §600.9’s medians and transaction-count weights. The superintendent may request additional material and special reports. No reporting template or submission was used.	S009 §600.22(b)–(d).
R028-P1-C099	Part 600 supplies alternative APR accuracy tolerances.	Ordinary tolerance is ±0.125 percentage point; qualifying irregular transactions receive ±0.25 percentage point; a separate relative-percentage test uses the rule’s stated formula and 2.5% threshold. These are disclosure tolerances, not maximum lawful charges.	S009 §600.4(a)(1)–(3).
R028-P1-C100	The bona fide disclosure-error provision requires discovery through the provider’s/financer’s procedures, timely notice, and adjustment.	Within 60 days after discovery and before an action for that error, the financer/assignee must notify and adjust so charges do not exceed the lower of disclosed finance charge or the dollar equivalent of disclosed APR. No actual cure or immunity is found.	S009 §600.4(b).
R028-P1-C101	Section 600.4 separately addresses inadvertent overstatement of enumerated disclosure amounts.	It covers the listed finance charge, APR, payments, monthly cost, maximum noninterest charge, and prepayment amounts. It is not a blanket exemption from the disclosure law or other law.	S009 §600.4(c).

The full historical-method exceptions and opt-in audit conditions were read. They are essential to avoid turning a qualified estimate into a guaranteed payment schedule or a generic industry assumption. dfs.ny.gov+5

G. Source defects and explicit research limits

Claim ID	Finding	Consequence and limit	Support
R028-P1-C102	The retrieved adopted §600.5(b) names ESRA but cites State Technology Law §§103–109; current ESRA is Article 3, §§301–309.	The relevant current signature/record provisions were read directly. The erroneous-looking citation is not silently treated as correct, and no actual signature is validated.	S009 §600.5(b); S021; S022.
R028-P1-C103	Other internal references in the retrieved adopted text do not align with their apparent targets.	Examples: §600.7 refers to nonexistent §600.9(a)(3); §600.8(b)(6) points to §600.6 for its decision record; §600.5(f)(3)–(4) points to font provisions under subdivision (g), although fonts are under (f); §600.17(a)(6)’s illustrative item-number subtraction does not track its preceding list. These are parsed-text observations, not pixel-confirmed printing defects or judicial invalidity findings.	S009 §§600.5(f), 600.7, 600.8(b)(6), 600.17(a)(6).
R028-P1-C104	No standalone official FAQ/model/reporting-instruction package was retrieved in the bounded official searches.	No assertion is made that none exists. The mandatory rules and embedded examples were examined directly.	S013, S028; failure log.
R028-P1-C105	No PDF pixel inspection was successfully completed.	Screenshot attempts for Part 600 indexes 17, 18, 46, and 47 returned placeholders without inspectable image content. No claim of seeing scanned signatures, visual form layout, typography, or image-based federal equations is made.	S009, S025; retrieval log.
R028-P1-C106	The full later regulatory/session-law/judicial history is unresolved.	No finding that the law has never been amended, stayed, vacated, or otherwise affected is made. A historical agency transition-letter source was not recovered from an official publisher and was not substituted with a private reproduction.	S013–S016, S027–S029.
R028-P1-C107	No actual compliance, exemption, contractual, funding, collection, or legal-validity result follows from this investigation.	Every parent fact and every unaddressed jurisdiction/product/enforcement dimension remains held. No court opinion or federal-preemption ruling was needed to state the selected published disclosure propositions.	Scope restriction; C008 and the conditional claims above.

3. Provision-specific comparison

This comparison identifies places where reading only one layer would produce an incomplete or misleading result.

Issue	Statutory provision	Adopted rule / agency explanation	Result for this component
Specific offer	§801(k): recipient-informed terms including price or amount; binding if accepted, subject to stated requirements.	§600.1(ai): written communication combining amount/payment information and rate/price/cost, based on quote-relevant recipient information.	Preserve both formulations. Do not replace the statutory text with an informal “personalized quote” shortcut. C028–C030.
New York nexus	Article 8 does not itself specify the adopted recipient-location test.	§600.24 supplies the recipient-management/residence nexus; APC response 1 explains the final narrowing.	Provider location alone does not answer coverage under this rule. C015.
Financial institution	§§801(f), 802(a) identify exempt categories and authorization conditions.	§600.1(r) includes majority-voting-power-owned entities; APC responses 2–3 explain the distinction.	“Affiliate,” “bank partner,” and “regulated somewhere” are not interchangeable predicates. C016.
Amount threshold	§802(g): individual transaction over $2.5 million.	§§600.1(b), 600.19 specify agreement-level and product-specific measuring units.	Do not test a draw or direct cash deposit against the threshold without the correct unit. C022–C023.
Historical window	§803(c)(i): fixed one-to-twelve-month outer range.	§600.8(b)(2): ordinary four-to-twelve-month fixed window, permitted grouping, plus (b)(3)–(5) exceptions.	Do not describe either “one month is always enough” or “four actual months are always required.” C081–C084.
Signature timing	§809: before authorization to proceed further with the application.	§600.18: before consummation; no signature for an unconsummated transaction; final corresponding disclosure suffices during negotiation.	State both. Do not infer that acknowledgment equals contract acceptance or that signature may always wait until funding. C036–C049.
Other potential fees	§803(g) expressly requires them.	§600.6 lacks an express general-fees row.	Statutory content remains required; exact compliant placement is unresolved on retrieved sources. C073.
Prepayment percentage	§803(h)(i) requires percentage and maximum dollar amount.	§600.6(j) expressly specifies a maximum-dollar statement.	Do not drop the percentage requirement by following the table mechanically. C074.
Renewal charges	§808(a) uses original finance charge, renewal payoff/original total repayment, and forgiveness.	§600.6(b)(3)(v) describes a pro rata portion using original amount financed already repaid.	Different stated bases; no silent reconciliation or numerical illustration. C075–C076.
Broker compensation	Provider definition includes qualifying third-party offer activity.	§600.21(f) requires a written compensation explanation; APC response 5 removes a prescribed compensation row.	Written disclosure remains; no fixed final-row model is established. C047.
Retention actor	General provider framework.	§600.21(d) says provider; APC response 5 says retention applies only to financers.	Preserve the adopted text and identify the narrower explanatory statement. C046.
Electronic signature reference	ESRA is State Technology Law Article 3.	§600.5(b) cites §§103–109 while naming ESRA.	Read §§301–309 and applicable Part 540 text directly; actual implementation remains held. C039–C041, C102.
Rule/form/model status	§811 authorizes prescribed disclosure formats.	§§600.5–600.6 prescribe format/content; §600.17 requires substantial similarity to embedded itemization examples.	These are distinct from a signed actual contract and from the administrative adoption form. C061, C077–C078, C105.
Lawfulness	The chapter saving clause preserves other illegality/licensing law.	APR and disclosure calculation requirements do not supply a loan/sale or enforceability adjudication.	All parent legal-validity questions remain held. C008, C052, C107.

4. What each displayed number answers

Displayed concept	Source-defined question	Units / necessary assumptions	What it cannot establish by itself
Amount financed	What funding value is provided to or for the recipient after subtracting prepaid finance charge?	Dollars; §600.1(a)(1), (ac).	Direct cash received, total repayment, or lawful principal.
Recipient funds	What is provided directly to the recipient after specified deductions/payoffs?	Dollars; balances may be assumed as of disclosure under §600.1(af).	Exact later funding when payoff balances change.
Finance charge	What is the dollar cost included under the imported and state-specific charge rules?	Dollars; charge inclusion/exclusion predicates matter.	An annual rate, lawful-interest conclusion, or total payments.
Estimated total payment	What total contractual payments are projected?	Dollars; estimated payment stream and applicable contract features.	Cost alone, actual payoff total, or an unconditional fixed obligation.
Estimated payment	What periodic/irregular payment and true-up amounts are projected?	Dollars per stated period, plus specified dates/amounts for irregular items.	Actual future debits or effective reconciliation.
Estimated monthly cost	What is the projected average monthly payment burden?	Dollars/month; estimated total payments and estimated term. Optional term conversion uses 30.4 days/month.	Monthly finance charges alone or APR.
Split percentage	What percentage is used to determine payments or true-ups?	Percentage of the contractually relevant sales/receipt channel.	Annual borrowing cost.
Factor or other nonannual cost metric	Only the question established by its expressly defined base and operation.	No universal factor formula or base is supplied by the selected texts.	APR, finance charge, or total repayment without further definitions and timing.
Estimated APR	What is the annualized cost of the projected value/payment stream?	Percent per year; prescribed charge treatment, amount/timing, method, and sales projection.	Actual realized cost, statutory maximum interest, loan characterization, or enforceability.
Audit retrospective APR	What does the completed-transaction audit calculation show?	Percent per year; actual known flows, subject to the permitted early-lump-sum adjustment.	Necessarily the unadjusted realized cash-flow APR in every audit.

Support: C050–C059, C063–C072, C087–C094; S003 and S009, with imported S023–S025.

Source-defined equations, without invented transaction inputs

These are symbolic explanations of published rules, not worked transaction examples.

Amount financed — C050

Amount financed [dollars] = Funds provided to recipient or on recipient's behalf [dollars] - Prepaid finance charge [dollars]

This does not make “funds provided on behalf” identical to direct recipient funds.

Statutory total repayment — C065

Total repayment amount [dollars] = Disbursement amount [dollars] + Finance charge [dollars]

The statute’s disbursement concept must be traced; it is not silently replaced with a different amount field.

Estimated monthly cost — C072

Estimated monthly cost [dollars/month] = Estimated total periodic and irregular payments [dollars] / Estimated term [months]

When the permitted conversion is used:

Estimated term [months] = Estimated term [days] / 30.4 [days/month]

This is a monthly-cost convention. It is not a universal APR day-count convention.

Appendix J nominal annualization — C058

APR [percent/year] = Unit-period rate [percent/unit period] * Number of unit periods [unit periods/year]

The applicable unit period must first be established under Appendix J. This is not an effective-annual-yield compounding formula and is not a complete implementation of the image-based general equation.

Opt-in APR spread — C094

APR spread [percent] = ((Retrospective APR [percent/year] - Disclosed APR [percent/year]) / Disclosed APR [percent/year]) * 100

This measures a relative difference. It is not the difference in percentage points. The selected text does not supply a rule for a zero disclosed-APR denominator.

Renewal statutory calculation — C075

Statutory prepayment charge [dollars] = Original finance charge [dollars] * (Renewal amount used to pay existing financing [dollars] / Original total repayment amount [dollars]) - Forgiven portion of total repayment [dollars]

This is displayed only to preserve §808(a)’s stated inputs and operations. Because §600.6(b)(3)(v) describes a different base, no numerical reconciliation or compliance result is supplied.

No numerical illustration is justified here. A worked transaction would require assumptions about sales, dates, charges, contractual minimums, true-ups, and method selection that this task expressly holds.

5. Qualitative branches and material-branch coverage

Status key

A: The selected generic public rule is answered within the stated source bounds.
P: Partially answered because a source, drafting, or implementation gap remains.
X: Actual application is deliberately excluded by the parent holds.

“Adverse inference to avoid” means an unsupported conclusion that must not be drawn from missing evidence. It does not assert a legal adverse-evidence presumption.

Every branch below uses generic roles only.

Branch ID / status	Qualitative branch and rule/claim/source	Conditions and missing evidence	Adverse inference to avoid	Exact next permissible public-law read
R028-P1-E001 — A/X	New York nexus unknown. C015; S009 §600.24.	Whether business direction/management or natural-person legal residence meets the rule is held; no location representation examined.	“Provider is in New York, therefore covered,” or “provider is elsewhere, therefore excluded.”	Current compiled §600.24 and any official amendment or published generic DFS interpretation of that subsection. No address/ID search.
R028-P1-E002 — A/X	Commercial/personal purpose uncertain. C010, C025; S001 §801(b), S009 §600.1(m).	Intended primary purpose and an eligible purpose statement are unknown; TILA coverage/compliant disclosure not established.	Treating a business label as conclusive commercial purpose, or a voluntary TILA form as an exemption.	§801(b), §600.1(m), APC response 7; a federal coverage provision only if a narrower generic proposition becomes necessary.
R028-P1-E003 — A/X	Amount and threshold unit unknown. C022–C023, C050–C051.	Product, agreement-level availability, amount financed, prepaid charges, and direct funds are held.	Comparing a single debit, draw, or net deposit to $2.5 million.	§§600.1(a)–(d), 600.19 in current compilation; no transaction arithmetic.
R028-P1-E004 — A/X	Provider/broker/recipient status uncertain. C012–C014.	Offer conduct, compensation, agency, funding role, and authority are unknown.	Assuming every intermediary is the financer, or that a broker may sign as recipient.	§801(h)–(i); §§600.1(j), (q), (ad)–(ae), 600.18(a), 600.21.
R028-P1-E005 — P/X	Transaction-count exemption unestablished. C021; §802(f).	Number, location, twelve-month interval, and the treatment of renewals/advances are unestablished.	Using five SBF deals only, a calendar year automatically, or importing §600.1(am) beyond its stated target.	Any current official generic interpretation of §802(f)’s transaction count; current §802(f) and §600.1(am). No roster or transaction records.
R028-P1-E006 — A/X	Bank/other exemption conditions uncertain. C016–C020, C024.	Charter/authorization category, voting ownership, technology interest, Farm Credit regulation, real-property security, true lease, or dealer/rental predicates are held.	Exemption merely because of a bank relationship, collateral, software role, or vehicle-related purpose.	Relevant §802 clause and its definitional cross-reference; only a specifically needed generic classification statute, never an entity/license lookup.
R028-P1-E007 — P/X	Sales-based versus closed/open-end, factoring, or lease category uncertain. C011, C026–C027.	Contractual payment and product features are held; asset-based overlap unresolved.	Treating an “MCA” label as controlling or applying §600.6 to every receivables-related product.	§801(a), (c), (d), (j); §600.1(e), (k), (w), (s); §600.6 and §600.15 introductions. Full other-product work remains held.
R028-P1-E008 — A/X	Specific offer versus advertisement/inquiry. C028–C030, C035.	Written terms, quote-relevant recipient information, both regulatory quote elements, and binding character are unknown.	Every advertisement requires the final table, or every communication called an advertisement is exempt.	§801(k); §600.1(f), (n), (ai); §600.3; APC response 9.
R028-P1-E009 — A/X	Offer terms changed. C032–C033, C037.	Whether change preceded or followed consummation, increased cost, addressed default, or merely reflected payoff drift is held.	Every change requires identical treatment; a payoff exception covers an increased APR; a default exception covers a new unrelated financing.	§600.1(f)(2); §600.5(n); §600.6(b)(3); §600.18(c).
R028-P1-E010 — P/X	Delivery versus acknowledgment/acceptance/funding. C036–C043, C049.	Delivery, receipt, signatory authority, intent, final corresponding terms, consummation, and funding evidence are all held.	A sent link proves receipt; acknowledgment proves contract formation; a signature proves funding.	§809; §§600.5(b), (e), (j), 600.18; ESRA §§302, 304–309. Any formation inquiry remains outside this pass.
R028-P1-E011 — A/X	Broker versus provider obligation. C044–C048.	Transmission route, timing, direct-delivery confirmation, generated documents, and compensation arrangements unknown.	Broker involvement transfers every financer obligation or immunizes the broker’s own representations.	§600.21(a)–(g) and APC response 5, preserving the retention-language difference.
R028-P1-E012 — A/X	Estimated versus actual term/payment. C063, C066–C072, C089–C093.	Actual sales, payment timing, contractual minimums, irregular payments, fees, and adjustments are held.	The disclosed estimated term is necessarily the contract maturity or actual payoff date.	§§600.1(ag), (al), 600.6(f)–(m), 600.7, 600.9(f).
R028-P1-E013 — A/X	Historical-sales versus opt-in estimate. C079–C086, C091.	Election, fixed window, channel, documentation, exclusions, internal projection, and method notice are unknown.	Inventing a three-month policy from an illustrative sentence, assuming undocumented sales, or assuming opt-in without audit duties.	§803(c); §§600.8–600.9, plus any official public election instruction if published.
R028-P1-E014 — A/X	Reconciliation disclosed versus effective adjustment. C067, C087–C090.	Contract mechanism, request/initiation, actual adjustment, similar-contract performance, and policy are held.	A reconciliation paragraph proves actual relief, a refund, or true-sale characterization.	§§600.1(an)–(ap), 600.6(g)(2)(iii), 600.7. Actual performance and characterization remain held.
R028-P1-E015 — A/X	Factor versus APR/finance charge/total payment. C050–C059, C065.	Factor definition/base, charges, timing, and projected payment stream unknown.	Calling a factor an annual rate or treating total payment as dollar financing cost.	§810; §§600.1(a), (u), (ak), 600.2–600.3; imported §1026.22/Appendix J only to the necessary calculation proposition.
R028-P1-E016 — P/X	Generic model versus signed actual contract. C061, C077–C078, C105.	No executed disclosure or contract exists in the research record; pixels not inspected.	An embedded example proves the actual form was compliant, delivered, or signed.	Current §§600.5–600.6 and 600.17; inspect official example pixels if a public-view capability supplies them. No filling/submission.
R028-P1-E017 — P/X	Current adopted rule versus proposal/history. C002–C007, C106.	Later-current compilation and complete intervening history remain unverified.	Treating a 2022 proposal, 2026 page update, or rule-review invitation as a new effective rule.	Current compiled Part 600 plus intervening official State Register adoption/amendment notices. No docket/status search.
R028-P1-E018 — A/X	Disclosure compliance versus loan/usury/collection validity. C008, C052, C107.	All substantive characterization, licensing, enforceability, and collection facts/law are held.	“Disclosed APR means lawful charge,” “disclosure means loan,” or “missing disclosure automatically eliminates debt.”	The chapter saving clause and §801(h) suffice here. No broader investigation is necessary for the selected proposition.
R028-P1-E019 — A/X	Multiple offers versus multiple payment options. C031, C060.	Whether there are separate offers, customization, or choices within one contract is unknown.	Applying the selected-offer timing rule as though it were the minimum-payment calculation rule, or vice versa.	§600.1(f)(1), (4), compared with §600.20(a).
R028-P1-E020 — P/X	Renewal payoff and fee overlap. C062, C075–C077.	Required same-provider payoff, original bases, retained fees, forgiveness, and net disbursement are held.	Using one formula as though statute and regulation stated identical inputs.	§808(a)–(b), §600.6(b)(3)(v), §600.17; any official correction or generic explanatory rule. No invented calculation.
R028-P1-E021 — A/X	Opt-in audit versus annual regulatory report. C092–C098.	Cohort, completed financings, number of audits, actual/estimated APRs, and report history are held.	Equating annual median spreads/count weights with reporting means/financing-amount weights, or declaring a filing overdue.	§§600.9(e)–(j), 600.22(a)–(d), and any current public reporting specification.
R028-P1-E022 — A/X	Disclosure tolerance versus guaranteed compliance. C099–C101.	Calculated/disclosed APR, irregularity, error discovery, intent, notice, adjustment, and action timing are held.	Treating 2.5% as 2.5 percentage points, or assuming a cure/tolerance proves lawful pricing or collectibility.	§600.4(a)–(c) and the specifically incorporated APR calculation provisions.

6. Blank audit worksheet

This is a blank research/audit worksheet, not a disclosure form, legal certification, transaction record, or request for private evidence. No identifying fields or fictional entries are supplied.

Worksheet item	Rule/claim reference	Evidence or public-law citation to record	Finding	Open issue / permitted public-law follow-up
Governing version and operative dates	C001–C007	______	______	______
Recipient New York nexus rule	C015	______	______	______
Intended primary purpose	C010	______	______	______
Provider / financer / broker / recipient distinction	C012–C014	______	______	______
Product category and overlap	C011, C026–C027	______	______	______
Amount measure and threshold unit	C022–C023, C050–C051	______	______	______
Twelve-month transaction-count rule	C021	______	______	______
Each potentially applicable §802 exemption	C016–C024	______	______	______
TILA exclusion’s two predicates	C025	______	______	______
Specific-offer predicates	C028–C030	______	______	______
Multiple-offer / customization treatment	C031	______	______	______
Changed terms / default / payoff-drift distinction	C032–C034	______	______	______
Delivery and broker-transmission rule	C044–C045	______	______	______
Signature timing and final corresponding disclosure	C036–C038	______	______	______
Electronic intent, association, timestamp, durable copy	C039–C041	______	______	______
Contract/disclosure/itemization separation	C042–C043	______	______	______
Funding amount, recipient funds, deductions, itemization	C050–C051, C062, C077	______	______	______
Finance-charge inclusion/exclusion treatment	C052–C055	______	______	______
APR method, units, assumptions, rounding	C056–C059, C078	______	______	______
All §803(a)–(i) disclosure subjects	C062–C074	______	______	______
Renewal provisions and formula discrepancy	C075–C076	______	______	______
Historical method and complete exception set	C079–C086	______	______	______
True-up definition and anticipated-adjustment treatment	C087–C090	______	______	______
Opt-in cohort, spread, weighting, thresholds, reentry	C091–C096	______	______	______
Annual reporting rule and distinct statistics	C097–C098	______	______	______
Tolerance/cure conditions	C099–C101	______	______	______
Source defects, pixel bounds, and later-history gaps	C102–C106	______	______	______
Preserved parent holds; no acceptance determination	C107	______	______	______

7. Granular question-to-claim/source crosswalk

The branch matrix above supplies the material-branch coverage. This table separately accounts for each numbered question and its principal subquestions.

Question / subquestion	Coverage	Claims, sources, examples	Missing evidence or limit	Exact permissible next investigation
1(a): Actual statutory codification and selected complete provisions	Answered	C001–C004; S001–S008, S015–S016	Other-product and remedy provisions intentionally held.	Only a necessary amendment/session-law check for these selected sections.
1(b): Adopted Part 600 provisions actually necessary	Answered as adopted; partial as later-current compilation	S009 clause/page map; C005–C007, C106	S027 access failure.	Current compiled §§600.0–600.9, .17–.22, .24–.25 and any intervening official amendments.
1(c): Scope, purpose, roles, nexus	Answered generically; actual application excluded	C010–C015; E001–E004	All actual role, purpose, and nexus facts held.	Specific listed definitions; no identity/location search.
1(d): Amount and unit thresholds	Answered generically	C022–C024; E003	Actual amount/product facts held.	§§600.1(a)–(d), 600.19 and §802(h), if needed for a further generic clarification.
1(e): Transaction count	Partial	C021; E005	No specific official count interpretation retrieved for edge cases.	Official generic interpretation or amendment addressing §802(f).
1(f): Every statutory exemption	Answered at clause level; subordinate actual classification excluded	C016–C025; S018–S020; E006	Full Farm Credit, vehicle licensing, and lease-characterization regimes not investigated.	Only the specific generic definitional cross-reference needed; no status records.
1(g): Disclosure versus substantive validity	Answered boundary	C008, C052, C107; E018	Loan/sale, lawful charge, license, collection questions held.	No further read necessary to preserve the boundary.
2(a): Specific-offer timing	Answered generically	C028–C031, C035; E008, E019	No actual quote/application.	§801(k), §600.1(f), (n), (ai), §600.3.
2(b): Changed terms and exceptions	Answered generically	C032–C034; E009	No actual amendment/default/payoff.	§600.1(f)(2)–(3), §600.5(n), §600.6(b)(3).
2(c): Signature and acknowledgment	Answered with textual distinction preserved	C036–C043; E010	Statute/rule timing wording not collapsed; actual authority/intent held.	Current §809, §600.18, and relevant ESRA text.
2(d): Broker transmission and duties	Answered; retention wording tension identified	C044–C048; E011	No transmission/compensation facts; APC/body tension.	Current §600.21 and any official clarification of retention actor.
2(e): Acceptance, formation, funding	Answered as distinctions; outcomes excluded	C040, C049; E010	No actual event or formation evidence.	No contract-law or factual investigation necessary for this pass.
2(f): Generic forms and pixel bounds	Partial	C061, C077–C078, C104–C105; S009, S011	No standalone model package retrieved; no inspectable pixels.	Official current model instructions, if published; direct public image inspection if available.
3(a): All selected disclosure items	Answered, with placement gaps	C062–C078; S003, S005, S009	General fees and prepayment percentage placement unresolved.	Official clarification/correction of §600.6 against §803(g), (h).
3(b): Estimated versus actual amounts/term	Answered generically	C050–C072, C093; E012, E015	All actual payment/sales/funding facts held.	Selected definitions and estimate rules only.
3(c): Historical method	Answered generically	C079–C086; E013	No elected period, documentation, sales history, or policy.	Current §600.8 and public method-election instructions if available.
3(d): Opt-in method and review	Answered rules; operational instructions partial	C091–C098; E021	No current standalone reporting/election instruction retrieved.	Official public §600.22 reporting specification and §803(c) notice instruction.
3(e): Reconciliation and risk explanation	Answered generically; actual effectiveness excluded	C067, C087–C090; E014	No contract/performance/policy facts.	§§600.1(an)–(ap), 600.6(g), 600.7.
3(f): APR/finance-charge methods and units	Answered at required framework level; numerical implementation not undertaken	C052–C060, C094, C099; S023–S026	Appendix J image equations not pixel-read; no transaction inputs.	Inspect exact Appendix J equations only if a separately authorized numerical calculation becomes necessary.
3(g): Broad pricing/usury/effective-APR modeling	Excluded	C008, C107; E018	Parent hold.	None within this pass.
4(a): Enacted/adopted/effective/compliance dates	Answered	C002–C005; S010, S015–S016	Historical transition guidance remains separately unverified.	Official historical transition letter only if needed to answer a particular 2022 application question.
4(b): FAQs/forms/APC role	Answered hierarchy; source availability partial	C009, C061, C077, C104; S011–S012, S028	No standalone current FAQ/model/reporting package retrieved.	Relevant official generic publication, without filing/contact.
4(c): Proposals and later amendments	Partial	C006–C007, C106; E017	Full proposal texts and complete intervening amendment history not read.	Official current compilation plus exact intervening adoption/amendment notices.
4(d): Future-effective material	Answered for encountered cross-references	S020–S021	Future GBL/ESRA alternatives kept separate; full unrelated future regimes held.	Relevant effective-date note only if it changes a selected proposition.
4(e): Preemption or published opinions	Excluded as unnecessary	C107; E018	No opinion, holding, docket, case record, or later case history researched.	Only a specifically necessary published majority opinion/authority under a later narrowed question; no docket inquiry.
4(f): Withdrawn/stayed/vacated status	Unresolved outside selected publication check	C106	No complete litigation or guidance-withdrawal history. No CFPB circular/advisory used.	Exact official status publication only if needed for a selected proposition; no case-record search.
5(a): Provision-specific comparison	Answered	§3; C028–C029, C073–C076, C102–C103	Identified tensions remain unresolved, not repaired.	Exact official correction/interpretation for each tension.
5(b): Blank worksheet	Answered	§6	Intentionally blank; no actual facts.	None required.
5(c): At least twelve qualitative branches	Answered: 22 branches	E001–E022	Every actual application held.	Public-law-only next reads are specified per branch.
5(d): Optional arithmetic	Omitted; symbolic rules supplied	§4; C050, C058, C072, C075, C094	No justified complete transaction dataset; renewal-text tension; image-equation limit.	No invented numerical example.
5(e): Source/read log, crosswalk, gaps, self-check	Answered	§§1, 7–10	Currentness and pixel gaps expressly remain.	Listed source-specific reads; no acceptance or independent-review claim.

8. Explicit unresolved gaps

Gap	What remains unresolved	Why it matters	Permissible next public-law work
G1 — Later-current Part 600 compilation	State-linked NYCRR pages were unavailable.	The final-adopted text and current agency listing do not alone prove the complete text as amended through the access date.	Retrieve the current compilation through an ordinary permitted public view and compare only the selected sections with S009; read any intervening official adoption notices.
G2 — Complete amendment/session-law history	Selected enacted changes were verified, but not every later session law or amendment history entry.	Publisher revision/update dates cannot certify comprehensive legal currentness.	Exact official statutory amendment histories and chapter texts affecting the selected provisions.
G3 — Historical transition guidance	A December 2021 transition letter was not recovered from an official DFS publication.	January 1, 2022 statutory effectiveness and August 1, 2023 regulatory compliance must not be converted into an unsupported assertion about every intervening obligation or enforcement policy.	The exact official historical letter and any superseding official generic statement, if that historical question becomes necessary.
G4 — Fees and prepayment percentage placement	The sales-based table does not expressly allocate all §803(g) and §803(h)(i) information.	A mechanically copied table could omit a statutory subject.	An official generic clarification or amendment addressing §600.6’s relation to those clauses.
G5 — Renewal calculation discrepancy	Section 808(a) and §600.6(b)(3)(v) use different stated fractions/bases.	A numerical example could silently choose one and conceal the unresolved text.	Official correction or generic interpretive authority limited to these clauses.
G6 — Drafting/cross-reference defects	The retrieved ESRA, historical-record, internal-projection, font, and item-number references do not fully align.	They affect precise implementation and must not be silently renumbered.	Current compiled counterparts and any official correction. Pixel inspection would verify the PDF’s visual text but would not itself resolve legal interpretation.
G7 — Separate public guidance/forms	No standalone current FAQ/model/reporting/election instruction package was retrieved.	Statutory method notice and annual reports have operational details that may be prescribed elsewhere.	Targeted official public instructions for §803(c) and §600.22; no portal entry, submission, contact, or records request.
G8 — Pixel and full numerical-method inspection	PDF screenshots supplied no images; Appendix J image equations were not inspected.	No visual-form validation or complete numerical APR implementation can be claimed.	Public image inspection of the exact pages/equations if needed; numerical modeling remains held.
G9 — Transaction-count edge cases	No definitive generic interpretation was retrieved for all renewal/advance/intermediary counting questions under §802(f).	The expressly limited §600.1(am) definition cannot be extended without authority.	An official generic interpretation or amendment focused on §802(f).
G10 — Actual application and broader law	All actual facts and parent legal dimensions remain uninvestigated.	Conditional public rules do not supply the missing factual predicates or decide substantive validity.	None within this pass.

Status separation: The report distinguishes current official statutory bodies, historical enacted amendments, final adoption, delayed regulatory compliance, historical proposals, encountered future-effective cross-reference text, and unknown later history. It does not label any unverified instrument withdrawn, stayed, or vacated, and it does not certify that none has that status.

9. Source-read and retrieval-failure log

Log item	Action/result	Read or failure bounds	Treatment
L01 — Statutory body	Retrieved selected current official Senate sections.	Full bounds in S001–S008.	Primary foundation; metadata kept separate from operative dates.
L02 — Adopted rule	Retrieved the DFS final-adopted PDF and agency-linked alias.	Full selected read map in §1; same instrument.	Primary regulatory foundation, subject to G1.
L03 — Adoption and agency explanation	Retrieved DOS notice, DFS notice, complete APC, current listing, and 2026 review entry.	S010–S014.	Adoption status and explanatory context; no independent-source inflation.
L04 — Enactment history	Retrieved enacted-bill text and signed-chapter actions for 2020 chapter 369 and 2021 chapter 61.	S015–S016; selected clauses only.	Historical changes verified; no complete session-law audit.
L05 — Necessary cross-references	Retrieved UCC, vehicle/rental definitions, ESRA, ITS rules, federal finance-charge/APR provisions, and creditor definition.	S018–S026.	Used only for the selected definitions/calculation/signature propositions.
L06 — NYCRR failures	State-linked index and located §600.1 page returned 403.	Complete URLs in S027.	No workaround; adopted DFS text used with explicit currentness gap.
L07 — DFS navigation failures	Earlier paths failed: https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services and https://www.dfs.ny.gov/industry_guidance/regulations/proposed_fsl.	No substantive body retrieved at those paths.	Working current regulatory-activity page used; failed paths do not show absence of law.
L08 — Historical bill navigation	A direct amendment path did not resolve: https://www.nysenate.gov/legislation/bills/2019/S5470/amendment/B.	No reliance on failed route.	Base official page supplied the B-version text and action history; versions kept distinct.
L09 — OLRC route failures	Preliminary paths returned 404: https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1602 and https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1602+edition%3Aprelim%29.	No body read there.	The publicly indexed current OLRC page in S026 succeeded; no access-control bypass.
L10 — Literal ESRA citation problem	Following the adopted citation led to unrelated State Technology Law Article 1 material; attempted §§108–109 paths were unavailable: https://www.nysenate.gov/legislation/laws/STT/108, https://www.nysenate.gov/legislation/laws/STT/109.	Unrelated Article 1 text was not used as ESRA authority.	Correctly named ESRA located through the official Article 3 index and read directly.
L11 — Screenshot attempts	Requested Part 600 PDF indexes 17, 18, 46, 47.	Returned image placeholders without inspectable image content.	No pixel inspection claimed. Parsed text only.
L12 — Guidance and historical letter search	Bounded official searches and DFS catalog review did not retrieve the separate FAQ/model/reporting package or official historical transition letter.	Private reproductions surfaced in discovery but were not used as substantive foundation.	G3 and G7 preserved; no claim of nonexistence.
L13 — Federal display bounds	Compared current CFPB and eCFR publications.	Shared selected finance-charge/APR provisions used; image equations and nonselected consumer-overdraft history not resolved.	No broad federal coverage, amendment-history, preemption, or guidance-withdrawal conclusion.
L14 — Overlong retrieval output	One overlong combined retrieval did not supply readable complete output.	No unread remainder was credited as reviewed; necessary selected provisions were retrieved again separately.	Read bounds reflect actually available text, not merely a requested download.
L15 — Courts and actual records	No judicial opinion or case-specific source was necessary for the selected propositions.	No docket, case-record, party, license, entity, account, property, or transaction query.	All litigation and actual-status dimensions remain held.

10. Researcher self-check and preserved parent holds

This is a researcher self-check, not independent review.

The foundation is this session’s public primary-source research. No prior research chat or unreviewed report was used.
Complete selected statutory clauses and adopted regulatory provisions are identified in the source register, with exact PDF page/index bounds.
Every consequential legal finding is assigned a claim ID and provision-specific source.
All eight §802 exemptions are accounted for, including their distinct amount, status, purpose, security, and transaction-count predicates.
Offer delivery, broker transmission, acknowledgment, signature, acceptance, consummation, and funding remain distinct.
The historical method’s complete selected exception set and the opt-in method’s audit/reporting conditions are included.
Estimated payments, actual payments, reasonably anticipated true-ups, and effective actual reconciliation are not equated.
Mandatory format/content, embedded examples, agency explanation, administrative adoption forms, proposals, and signed actual contracts are not conflated.
No source examples were converted into fictional provider policies, sales histories, account entries, or transaction outcomes.
No numerical APR, renewal, or pricing illustration was fabricated.
Currentness, drafting, guidance, and pixel-inspection gaps are visible; retrieval failure is not treated as absence of law.
No subagents, prior-chat research, party investigation, records request, filing, contact, purchase, account creation, publication, or security/CAPTCHA workaround was used.
No verified UI model-selection provenance is asserted.

All parent holds remain: actual parties and roles; New York nexus; purpose; product; amount; offer; disclosure; signature; acceptance; funding; sales; payments; reconciliation; method election; exemption facts; contract facts; loan-versus-sale characterization; broader pricing/usury/effective-APR analysis; enforceability; licensing and registration; security and priority; guarantees; ACH; confession of judgment; collection; settlement; tax; insolvency; remedies; complete litigation and later history; other New York dimensions; every other state, local, tribal, territorial, and national legal system; other alternative-finance products; and all other A028 and parent dimensions.

No component, parent, operations, or publication acceptance is given or inferred.

END R028 PASS-01

Every captured table

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

How to read the research →

Captured table 01

Source ID · Issuer, title, complete HTTPS URL · Exact substantive read extent · 8 data rows

Source ID	Issuer, title, complete HTTPS URL	Exact substantive read extent	Jurisdiction, version, status, limits
R028-P1-S001	New York State Senate, Financial Services Law §801, Definitions. https://www.nysenate.gov/legislation/laws/FIS/801	Entire §801(a)–(k), including all purpose-reliance language and role, product, finance-charge, and offer definitions.	New York; current official statutory page, revision metadata 2022-01-07. Entire selected section read. NYSenate.gov
R028-P1-S002	New York State Senate, §802, Exemptions. https://www.nysenate.gov/legislation/laws/FIS/802	Entire introductory clause and exemptions (a)–(h).	New York; current statutory body, same revision metadata. Every listed exemption read; no actual exempt status established. NYSenate.gov
R028-P1-S003	New York State Senate, §803, Sales-based financing disclosure requirements. https://www.nysenate.gov/legislation/laws/FIS/803	Entire introduction and (a)–(i), including complete (c)(i)–(ii), (f)(i)–(ii), and (h)(i)–(ii).	New York; current statutory body. This is the principal sales-based disclosure statute. NYSenate.gov
R028-P1-S004	New York State Senate, §807, Other forms of financing disclosure requirements. https://www.nysenate.gov/legislation/laws/FIS/807	Entire introduction and (a)–(i).	New York; read to establish the residual-category boundary and regulatory authority. Other-product implementation remains held. NYSenate.gov
R028-P1-S005	New York State Senate, §808, Disclosure requirements for renewal financing. https://www.nysenate.gov/legislation/laws/FIS/808	Entire conditional introduction and (a)–(b), including the fixed-repayment prepayment-charge formula.	New York; current statutory body. No renewal transaction assumed. NYSenate.gov
R028-P1-S006	New York State Senate, §809, Required signature. https://www.nysenate.gov/legislation/laws/FIS/809	Entire section.	New York; current statutory body. Wording is preserved separately from the regulation’s consummation rule. NYSenate.gov
R028-P1-S007	New York State Senate, §810, Additional information. https://www.nysenate.gov/legislation/laws/FIS/810	Entire section, including separation of additional information, restrictions on “rate” and “interest,” and APR statements during an application.	New York; current statutory body. NYSenate.gov
R028-P1-S008	New York State Senate, §811, Rules and regulations; Article 8 index. https://www.nysenate.gov/legislation/laws/FIS/811; https://www.nysenate.gov/legislation/laws/FIS/A8	Entire §811 introduction and (a)–(d); Article 8 section index.	New York. Article 8 includes §§801–812. §§804–806 were not substantively investigated; §812 remedies remain held. NYSenate.gov +1

Source links captured in this table

Captured table 02

Source ID · Issuer, title, complete HTTPS URL · Exact read extent and pages · 9 data rows

Source ID	Issuer, title, complete HTTPS URL	Exact read extent and pages	Version, effectiveness, status, limits
R028-P1-S009	NYDFS, Disclosure Requirements for Certain Providers of Commercial Financing Transactions, final-adopted 23 NYCRR Part 600. https://www.dfs.ny.gov/system/files/documents/2023/01/rf_finservices_23nycrr600_text.pdf. Agency-linked alias: https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_text	Complete selected sections listed in the next table. PDF has 53 pages: numbered text pp. 1–52, followed by unnumbered certification at index 52.	New York; final-adopted text certified January 12, 2023; effective on publication of adoption notice. Final publication/effective date verified through S010. Parsed text read; no successful pixel inspection. Current-compilation gap S027 remains. dfs.ny.gov +1
R028-P1-S010	NY Department of State, New York State Register, February 1, 2023, Vol. XLV, Issue 5, Part 600 Notice of Adoption. https://dos.ny.gov/system/files/documents/2023/02/020123.pdf	Notice identification, filing/effective dates, action, authority, complete section-by-section adoption summary, comparison with prior publication, and beginning of comment assessment. Printed pp. 1–2; PDF indexes 6–7. The separate complete assessment was read through S012.	Historical official adoption publication. Filing January 12, 2023; effective February 1, 2023. The entire 88-page Register was not read. dos.ny.gov +1
R028-P1-S011	NYDFS, Part 600 Notice of Adoption. https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_notice	Items 1–6, printed pp. 1–2, indexes 0–1, including action, publication-based effectiveness, authority, and prior revised-proposal date. Later administrative fields were encountered but not used as a complete filing-form review.	Five-page agency adoption form. “Rev. 1/17” is the administrative form revision, not a merchant disclosure version or effective date. No form filled or submitted. Notice
R028-P1-S012	NYDFS, Assessment of Public Comments for Revised Proposed 23 NYCRR 600. https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_apc	Complete comments and agency responses 1–9, printed pp. 1–6, indexes 0–5.	Agency rulemaking explanation accompanying final adoption. Commenters’ positions are not law; agency responses are explanatory material, not substitutes for the enacted/adopted text. APC
R028-P1-S013	NYDFS, Regulatory Activity—Financial Services Law. https://www.dfs.ny.gov/industry_guidance/regulatory_activity/financial_services	Current preproposal, proposal, emergency, and final-adoption listings, particularly the Part 600 final-adoption row and notice that final postings may be retained only temporarily.	Current agency publication accessed in this session. Sections show different update dates: preproposal/emergency August 26, 2026; proposals July 22, 2026; final-adoption section November 1, 2023. These are publication metadata, not Part 600 operative dates or a complete amendment audit. Department of Financial Services
R028-P1-S014	NYDFS, 2026 Three and Five Year Review of Agency Rules. https://www.dfs.ny.gov/industry_guidance/regulatory_and_legislative_activities/agency_rules_3and5year_review	Part 600 review entry, printed p. 74, index 73.	Current agency review document describing the 2023 adoption. The invitation for comments on the rule is not itself an amendment. Other entries and the entire 75-page document were not substantively reviewed. dfs.ny.gov
R028-P1-S015	New York State Senate, enacted S5470B, Laws of 2020, chapter 369. https://www.nysenate.gov/legislation/bills/2019/S5470	Official action showing signature December 23, 2020; B-version original §802(g) threshold and original act §2, including printed bill p. 9 for the original 180-day effective-date clause.	Historical enacted-bill text and action record. The page also contains earlier bill versions; those were not conflated with B. No complete session-law or all-version comparison claimed. nysenate.gov +2
R028-P1-S016	New York State Senate, enacted S898, Laws of 2021, chapter 61. https://www.nysenate.gov/legislation/bills/2021/S898	Official signed-chapter action; amended §§802–803; complete act §§2–3 concerning saving language and effectiveness. The latter appear on printed bill pp. 6–7 in HTML.	Signed February 16, 2021. Establishes January 1, 2022 underlying statutory effectiveness, immediate rulemaking authorization, and preservation of other illegality/licensing requirements. Not a complete subsequent session-law audit. nysenate.gov +3
R028-P1-S017	NYDFS, February 1, 2023 release announcing adoption of commercial-financing disclosure regulation. https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202302011	Entire substantive release.	Historical agency announcement, used as context only. It does not replace the adoption notice or operative text. Department of Financial Services

Source links captured in this table

Captured table 03

Provision · Complete selected read · Printed pages · 21 data rows

Provision	Complete selected read	Printed pages	PDF indexes
§600.0	(a), (b)(1)–(8), including nested clauses	1–2	0–1
§600.1	All definitions (a)–(ap), including nested definitions	2–9	1–8
§600.2	(a)(1)–(4), (b)–(d)	9–10	8–9
§600.3	(a)–(d)	10	9
§600.4	(a)(1)–(3), (b)–(c)	11	10
§600.5	(a)–(p), all nested formatting and estimate conditions	11–14	10–13
§600.6	Introduction and (a)–(m), all required sales-based rows and conditions	14–18	13–17
§600.7	(a)(1)–(5), (b)(1)–(6)	18–19	17–18
§600.8	(a), (b)(1)–(6), (c)(1)–(3)	19–20	18–19
§600.9	(a)–(k), including all audit exclusions and thresholds	20–22	19–21
§600.10	Introductory routing paragraph only	22	21
§600.15	Introductory routing paragraph only	40	39
§600.17	(a)(1)–(6), (b)(1)–(2) examples, (c)(1)–(4)	47–48	46–47
§600.18	(a)–(c)	48–49	47–48
§600.19	Introduction and (a)–(d), complete threshold conditions	49–50	48–49
§600.20	(a)–(b)	50	49
§600.21	(a)–(g), all nested broker/financer/provider duties	50–51	49–50
§600.22	(a)–(d), all reporting provisions	51–52	50–51
§600.24	(a)–(b)	52	51
§600.25	(a)–(b)	52	51
Certification	Entire certification and proposal-publication dates	Unnumbered	52

Captured table 04

Source ID · Issuer, title, complete HTTPS URL · Read extent · 9 data rows

Source ID	Issuer, title, complete HTTPS URL	Read extent	Version/status and limits
R028-P1-S018	New York State Senate, UCC §2-A-103. https://www.nysenate.gov/legislation/laws/UCC/2-A-103	Definitions (1)(h), (h-1), and (j), especially the complete lease definition.	Current official page; revision metadata June 5, 2026. No actual lease/security-interest characterization or full UCC §1-203 investigation. NYSenate.gov
R028-P1-S019	New York State Senate, VTL §415 and §137-a. https://www.nysenate.gov/legislation/laws/VAT/415; https://www.nysenate.gov/legislation/laws/VAT/137-A	§415(1)(a)–(j) complete; additional adjacent definitions encountered. §137-a entire definition.	§415 revision metadata April 3, 2026; §137-a September 22, 2014. Definitions only for exemption boundaries; no licensing/registration records or actual dealer determination. NYSenate.gov +1
R028-P1-S020	New York State Senate, GBL §396-z. https://www.nysenate.gov/legislation/laws/GBS/396-Z	Current (1)(b), (c), (k); effectiveness notices; future-version (1)(c) compared.	Page revision metadata July 7, 2023. Current and future bodies are separately displayed: present version until June 30, 2028; future version effective June 30, 2028. Rental-company definition selected here; full rental-protection regime held. NYSenate.gov +1
R028-P1-S021	New York State Senate and ITS, State Technology Law Article 3, ESRA. https://www.nysenate.gov/legislation/laws/STT/A3; https://www.nysenate.gov/legislation/laws/STT/301; https://www.nysenate.gov/legislation/laws/STT/302; https://www.nysenate.gov/legislation/laws/STT/303; https://www.nysenate.gov/legislation/laws/STT/304; https://www.nysenate.gov/legislation/laws/STT/305; https://www.nysenate.gov/legislation/laws/STT/306; https://www.nysenate.gov/legislation/laws/STT/307; https://www.nysenate.gov/legislation/laws/STT/308; https://www.nysenate.gov/legislation/laws/STT/309; parallel ITS publication: https://its.ny.gov/nys-technology-law	Article index and §§301–309 across the official publications; particularly §302 signature definition, §§304–306 validity/records/evidence, all §307 exceptions, §308 confidentiality, and §309 voluntariness.	Current statute, with §307 showing current/future alternatives. Current §307(1) lasts until December 12, 2027; future text is separately labeled effective that date. General metadata for many sections is 2014-09-22; §307 metadata 2026-02-27. No actual electronic-signature implementation approved. NYSenate.gov +5
R028-P1-S022	New York ITS, Electronic Signatures and Records Act Regulation, 9 NYCRR Part 540. https://its.ny.gov/electronic-signatures-and-records-act-esra-regulation	§§540.1–540.6 complete; §540.7 encountered but not analyzed. Relevant private-signature provisions: §540.4(a)–(b), §540.5(a).	Agency-hosted text expressly labeled an unofficial convenience copy. No complete Part 540 amendment/effective-date audit. Government-specific certification and risk-assessment rules were not converted into universal private-business requirements. Office of Information Technology Services +2
R028-P1-S023	OFR/GPO eCFR and CFPB, Regulation Z §1026.4, Finance charge. https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.4; https://www.consumerfinance.gov/rules-policy/regulations/1026/4/	Regulatory body (a)–(f) read in full through eCFR; corresponding CFPB body compared. Interleaved commentary was encountered, but no complete commentary audit is claimed.	Federal rule imported by New York for calculation. eCFR currency displayed through October 26, 2026 on later retrieval; title-level last-amended metadata October 23, 2026 is not a §1026.4 amendment date. eCFR is an authoritative electronic publication but not the official legal edition. Nonselected overdraft-related differences between displays were not used to support an SBF proposition. ecfr.gov +4
R028-P1-S024	OFR/GPO eCFR and CFPB, Regulation Z §1026.22, Determination of annual percentage rate. https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.22; https://www.consumerfinance.gov/rules-policy/regulations/1026/22/	Body (a)–(d); official interpretations 22(a)(1)-1 through -5, 22(a)(2)-1, and 22(a)(3)-1.	Federal imported calculation authority. CFPB labels its page current. Official interpretations are identified as interpretations, not New York statutes or staff correspondence. No CFPB circular, bulletin, or advisory was relied upon. ecfr.gov +1
R028-P1-S025	OFR/GPO eCFR and CFPB, Regulation Z Appendix J. https://www.ecfr.gov/current/title-12/chapter-X/part-1026/appendix-Appendix%20J%20to%20Part%201026; https://www.consumerfinance.gov/rules-policy/regulations/1026/j/	Text of (a)(1)–(3), (b)(1)–(6), and textual iteration instruction (b)(9)(ii).	Imported actuarial framework. Image-based symbols/equations in (b)(7)–(9) were not pixel-inspected; the full example collection was not read. No APR solver or numerical transaction illustration is claimed. Consumer Financial Protection Bureau +3
R028-P1-S026	U.S. House OLRC, 15 USC §1602(g), and GPO 2024 edition of the same statute. https://uscode.house.gov/us/usc/119-121/t15/s1602/; https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partA-sec1602.htm	Complete §1602(g); adjacent definitions encountered.	OLRC states laws in effect through Public Law 119-121, October 9, 2026. GPO 2024 publication is historical corroborating text of the same instrument. Used only for Part 600’s as-if creditor calculation premise; actual federal creditor status held. uscode.house.gov +1

Source links captured in this table

Captured table 05

Source ID · Publisher/path and complete HTTPS URL · Retrieval/read result · 3 data rows

Source ID	Publisher/path and complete HTTPS URL	Retrieval/read result	Consequence
R028-P1-S027	State-linked NYCRR electronic compilation: https://govt.westlaw.com/nycrr/Index?bhcp=1&contextData=%28sc.Default%29&transitionType=Default. Located §600.1 page: https://govt.westlaw.com/nycrr/Document/I8bdf0115366511f085fee08d50b7f070?contextData=%28sc.Default%29&originationContext=documenttoc&transitionType=CategoryPageItem&viewType=FullText	Both returned HTTP 403; no substantive body read there.	Current codification placement is supported by official adoption and agency listings, but the later-current compiled Part 600 body was not independently retrieved.
R028-P1-S028	NYDFS industry-letter catalog. https://www.dfs.ny.gov/industry_guidance/industry_letters	Current catalog and relevant 2021/financing portions checked, together with targeted official-site searches.	No separately published official commercial-financing FAQ, standalone current merchant model package, method-election filing instruction, or opt-in reporting instruction was retrieved. This is a source gap, not a finding that none exists. Department of Financial Services +2
R028-P1-S029	Other unsuccessful public-page paths, listed in the failure log in §9 below.	No substantive reliance on failed pages or private reproductions.	Failures were not converted into absence-of-law conclusions.

Source links captured in this table

Captured table 06

Claim ID · Atomic finding · Conditions, exceptions, and limits · 9 data rows

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C001	The statutory framework is Financial Services Law Article 8; Part 600 implements its commercial-financing disclosure provisions.	This component reads §§801–803 and 807–811, not the entire law of commercial finance. Article 8’s other-product and enforcement components remain held.	S001–S008; S009 §600.0.
R028-P1-C002	The original enactment was Laws of 2020, chapter 369, signed December 23, 2020.	Its original 180-day effective-date clause and lower amount threshold are historical; they are not substituted for the amended law.	S015, official action; B-version §802(g), act §2.
R028-P1-C003	Laws of 2021, chapter 61, signed February 16, 2021, amended the framework and set the underlying act’s operative date to January 1, 2022.	The amendment also authorized implementing rulemaking immediately; its own effectiveness provision coordinates the amended statutory sections with the underlying act.	S016, act §§2–3.
R028-P1-C004	January 7, 2022 on the selected Senate pages is revision metadata.	It is not the statutory operative date, final-rule adoption date, or compliance date.	S001–S008 compared with S016.
R028-P1-C005	Part 600 was filed January 12, 2023 and became effective February 1, 2023; its six-month compliance interval yields August 1, 2023.	August 1 is the calendar result of §600.25(b) applied to the verified February 1 publication date. Effectiveness and compliance are different events. No actual transaction deadline is inferred.	S010 notice; S009 §600.25(a)–(b).
R028-P1-C006	The currently served DFS listing and its 2026 rule-review entry continue to identify the February 1, 2023 Part 600 adoption.	Neither publication supplies a complete later-amendment, session-law, or judicial-history audit. The unavailable NYCRR compilation remains a material currentness gap.	S013, S014, S027.
R028-P1-C007	The 2021 proposal and September 14, 2022 revised proposal are historical stages, not the final operative text.	Their dates are verified in the certification/adoption material. Their complete bodies were not read, and no full proposal-to-final redline is claimed.	S009 certification; S010–S012.
R028-P1-C008	The disclosure enactment does not authorize otherwise illegal transactions or dispense with an otherwise required license.	It therefore cannot alone settle loan characterization, usury, licensing, enforceability, or collectibility. Those questions require different authority and facts and remain held.	S016 saving clause; S001 §801(h).
R028-P1-C009	The agency’s comment assessment can explain drafting choices but does not replace statutory or regulatory language.	Its response concerning retention uses narrower terminology than §600.21(d); that difference is preserved below. No staff statement is treated as legislation.	S012 responses 1–9; S009 §600.21(d).

Captured table 07

Claim ID · Atomic finding · Conditions, exceptions, and limits · 18 data rows

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C010	Commercial financing is financing whose proceeds the recipient does not intend to use primarily for personal, family, or household purposes.	The provider may rely on a separate signed statement, a signed/consented application or other document, or an oral statement documented in the application file. Electronic consent is permitted. The statute does not require checking later actual use against that statement.	S001 §801(b).
R028-P1-C011	Sales-based financing includes repayment varying as a percentage of sales/revenue and fixed-payment financing with reconciliation adjusting payment to such a percentage.	A product label alone does not establish the definition. Fixed scheduled debits alone do not exclude the category when the defined reconciliation arrangement exists.	S001 §801(j); S009 §600.1(ah), (ap)(1).
R028-P1-C012	A provider extends a specific offer; unless exempt, the definition also includes a person who solicits and presents specific offers for a third party.	Making an offer or giving disclosures alone does not mean originating, making, funding, or providing the financing. The regulation includes a financer communicating through an agent or broker with an expectation of onward communication.	S001 §801(h); S009 §600.1(ad).
R028-P1-C013	A financer is the person providing or to provide the financing; a broker is a compensated participant in the specified intermediation activities.	Broker activities include negotiation, advice, preparation/gathering/delivery of documents, communications, or obtaining signatures. Financer, recipient, and recipient’s agent are excluded from that broker definition. Mere role labels do not resolve overlapping provider duties.	S009 §600.1(j), (q).
R028-P1-C014	A recipient applies and receives a specific offer; an authorized representative can qualify, but a broker cannot be the recipient.	For one offer, controlled, controlling, or commonly controlled recipients are included together only when the single offer is conveyed simultaneously in the same writing. This is not general aggregation of all affiliates or all transactions.	S001 §801(i); S009 §600.1(ab), (ae).
R028-P1-C015	The disclosure nexus is a recipient business principally directed or managed from New York, or a natural-person recipient legally resident in New York.	A provider may rely on the specified written representation/business address; for a natural person, the specified government-ID address or written legal-address representation. Provider location alone is not the adopted nexus test. No actual address or ID was sought.	S009 §600.24(a)–(b); S012 response 1.
R028-P1-C016	Financial institutions described by §801(f) are exempt. The regulation includes entities majority-owned through voting power by such an institution, directly or indirectly.	The statutory bank, trust, industrial-loan, savings, and credit-union categories contain charter/authorization conditions, including authorization to transact business in New York. Mere affiliation or use of a banking service is not the stated majority-voting-power condition.	S001 §801(f); S002 §802(a); S009 §600.1(r); S012 responses 2–3.
R028-P1-C017	A technology-services provider can be exempt when serving an exempt entity’s financing program.	It must have no interest, and no arrangement or agreement to purchase an interest, in financing extended through that program. The exemption is capacity- and condition-specific.	S002 §802(b).
R028-P1-C018	A lender regulated under the federal Farm Credit Act is exempt.	The statute requires that regulated status; no actual institution’s status was investigated. The entire federal Farm Credit regulatory system was not independently analyzed.	S002 §802(c).
R028-P1-C019	A commercial-financing transaction secured by real property is exempt.	The clause does not say that any collateral, guarantee, or security interest is enough. No actual security or property facts were investigated.	S002 §802(d).
R028-P1-C020	A lease within UCC §2-A-103 is exempt.	That definition concerns transfer of possession/use of goods for a term and consideration, excluding a sale or retention/creation of a security interest. A security-interest “lease financing” is separately defined in Part 600. Actual characterization remains held.	S002 §802(e); S018 §2-A-103(1)(j); S009 §600.1(w).
R028-P1-C021	A person or provider making no more than five commercial-financing transactions in New York in a twelve-month period is exempt.	The unit is not stated as five sales-based transactions, five offers, or five transactions in a calendar year. Section 600.1(am)’s advances definition expressly addresses §801(c), so it cannot silently settle the §802(f) counting issue.	S002 §802(f); S009 §600.1(am).
R028-P1-C022	An individual commercial-financing transaction over $2,500,000 is exempt under the amount clause.	Exactly $2,500,000 is not exempt under this clause alone. The regulation uses the aggregate amount available under the agreement, not a particular advance; ordinary sales-based financing uses “amount financed” under §600.19(d).	S002 §802(g); S009 §600.1(b), §600.19(d).
R028-P1-C023	Other categories have different threshold measures.	Open-end uses approved credit limit. Asset-based/factoring treatment requires the specified general agreement, limit above $2.5 million, and timely written reasonable expectation that more than $2.5 million will be advanced and outstanding; without all conditions the offer is deemed at or below the threshold. Those categories are boundary reads, not completed product studies.	S009 §600.19(a)–(c), all nested clauses.
R028-P1-C024	The dealer/rental-company exemption requires the specified recipient or affiliate status and an agreement or open-end plan of at least $50,000.	It includes loans made pursuant to that transaction. It is not a blanket exemption for financing a vehicle. Dealer and rental-company definitions were read; no actual dealer, affiliate, vehicle, or registration status was inferred.	S002 §802(h); S019 §415(1), §137-a; S020 §396-z(1)(b), (c), (k).
R028-P1-C025	Part 600 excludes a transaction subject to TILA for which a TILA-compliant disclosure is provided.	Both predicates matter. Voluntarily using a TILA-style form for a transaction not subject to TILA does not establish this exclusion.	S009 §600.1(m); S012 response 7.
R028-P1-C026	Sales-based, closed-end, open-end, factoring, and lease definitions must be distinguished before selecting a disclosure format.	Open-end requires the stated repeat-credit/replenishment features; factoring concerns existing legally enforceable payment claims for supplied goods/rendered services. Some sales-based arrangements also meet the closed-end definition; §600.10’s introduction routes such arrangements away from its ordinary closed-end format.	S001 §801(a), (c), (d), (j); S009 §600.1(k); §600.10 introduction.
R028-P1-C027	Section 600.6 expressly excludes asset-based lending that also meets the sales-based definition from its sales-based table.	Asset-based lending has the advance/forwarding-payment conditions in §600.1(e), (s), and its own §600.15 route. This report does not resolve that separate product’s full disclosure method.	S009 §600.1(e), (s); §600.6 introduction; §600.15 introduction.

Captured table 08

Claim ID · Atomic finding · Conditions, exceptions, and limits · 22 data rows

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C028	The statute’s specific offer is recipient-informed financing terms, including price or amount, binding on the provider if accepted, subject to stated specific requirements.	The statute’s wording must be preserved; it does not itself establish that any communication was accepted or all conditions were fulfilled.	S001 §801(k).
R028-P1-C029	The regulation defines a specific offer as a written recipient-informed communication combining a payment/financing amount with a rate, price, or cost.	The communication must be binding if accepted. Name, address, or general interest alone is not the relevant recipient information. This is more detailed than the statute’s “price or amount” wording.	S009 §600.1(ai).
R028-P1-C030	A covered provider supplies the prescribed sales-based disclosures when extending the specific offer.	Ordinary advertisement/inquiry labels are not decisive; the actual statutory and regulatory offer predicates govern. No actual communication was examined.	S003 introduction; S009 §600.1(f)(1), §600.3(a).
R028-P1-C031	Simultaneous offers and customizable menus have a selection rule.	When the recipient selects from multiple qualifying options, disclosure timing is tied to selection; the provider need provide disclosures for the particular offer elected for pursuit. This does not authorize omitting disclosure for the selected offer.	S009 §600.1(f)(1), (4).
R028-P1-C032	A written offer to change an already consummated financing requires disclosure before agreement if the changes increase finance charge or APR.	The express exception is proposed terms resolving the recipient’s default. This clause is not a general exemption for every renewal, workout, or new financing.	S009 §600.1(f)(2).
R028-P1-C033	A changing payoff amount already included in a disclosure does not, by itself, require a new disclosure before consummation.	Section 600.5(n) is limited to that cause. The funding row must give the applicable warning about changing or unknown payoff deductions. Other changed terms must be evaluated separately.	S009 §600.5(n); §600.6(b)(3)(iii)–(iv).
R028-P1-C034	A special draw-by-draw rule exists for certain retailer/supplier open-end financing.	All three conditions are required: draw at purchase, variable rate/price depending on retailer/product, and election to use §600.10 instead of §600.11. This is a boundary exception, not a general sales-based funding rule.	S009 §600.1(f)(3)(i)–(iii).
R028-P1-C035	The application-stage cost-metric restriction and the APR statement trigger are not identical.	Nonannual metrics cannot be presented as a “rate” throughout the defined application process; the adopted rule ties the APR-alongside-rate/amount requirement to quotation of a specific offer and subsequent application communications.	S007 §810; S009 §600.1(f)(1), (n), §600.3(b); S012 response 9.
R028-P1-C036	Section 809 requires the recipient’s signature on required disclosures before authorization to proceed further with the transaction application.	That statutory wording is not rewritten as “only at funding.” Electronic signature is expressly allowed.	S006 entire section.
R028-P1-C037	Section 600.18 requires the signature before consummation and, for a consummated transaction with multiple negotiating disclosures, only on the final corresponding disclosure.	It does not require signatures for transactions that are not consummated. This is the adopted implementation; the difference from §809’s application-stage wording remains visible.	S009 §600.18(a), (c).
R028-P1-C038	An entity recipient’s disclosure may be signed by an authorized natural person who is not a broker.	Authority to sign is a factual predicate. Broker delivery or obtaining a signature does not make the broker the permissible recipient signatory.	S009 §600.18(a); S001 §801(i).
R028-P1-C039	Electronic signatures may be used, including qualifying button/checkbox processes; electronically consummated transactions may use electronic or fax signatures.	The process must satisfy ESRA. Electronic disclosure/signature is allowed regardless of the later agreement’s delivery medium. No actual click, authority, intent, or authentication was established.	S009 §600.5(b), §600.18(a)–(b); S021 §302(3), §304; S022 §540.4(a)–(b).
R028-P1-C040	The prescribed signature legend acknowledges receipt of information.	Its presence or a button labeled “Accept” does not, by itself, prove substantive contract acceptance, contract formation, satisfaction of offer conditions, or funding.	S009 §600.5(b), read with S001 §801(k) and S009 §600.18.
R028-P1-C041	Electronic execution requires an automatic date stamp and a signed copy the recipient can retain indefinitely.	Merely sending a link does not establish fulfillment of these conditions. ESRA also requires the signature’s association with the record and intent to sign; statutory exceptions and voluntariness remain relevant.	S009 §600.5(j); S021 §§302, 307, 309; S022 §540.4(b).
R028-P1-C042	Required disclosures are separate from contracts and other disclosure documents.	They may travel in one package; electronic material may share an attachment/link if separated by page breaks. Additional voluntary financing information cannot simply be inserted into the required disclosure.	S009 §600.5(e); S007 §810.
R028-P1-C043	A required amount-financed itemization is a separate, immediately following document that need not be signed.	Its trigger is amount financed greater than recipient funds. The unsigned exception does not eliminate the main disclosure’s signature requirements.	S009 §600.17(a), (c)(1)–(4).
R028-P1-C044	A broker receiving the financer’s disclosures must transmit them unaltered before communicating the specific offer and return transmission evidence, including time.	Alternatively, the broker may obtain confirmation that the financer supplied the disclosures directly. Delivery obligations remain distinct from signature and contract acceptance.	S009 §600.21(b)–(c).
R028-P1-C045	A financer giving a broker a specific offer must supply compliant disclosures and establish reasonable procedures for timely recipient delivery.	Direct delivery to the recipient is an alternative under §600.21(e). The listed contractual, investigation, and discontinuation procedures are examples of reasonable procedures, not an assertion that every example is invariably mandatory.	S009 §600.21(a), (e).
R028-P1-C046	The adopted text requires retention of specified disclosure and transmission records for at least four years.	Financer transmission-evidence retention runs from presentation to the recipient; §600.21(d) separately requires a provider to retain generated disclosures from presentation to recipient or provision to broker. The APC’s statement that retention applies only to financers is narrower and is not used to erase the adopted wording.	S009 §600.21(a)(2), (d); S012 response 5.
R028-P1-C047	When a broker is involved, the provider must explain in writing how and by whom the broker will be compensated.	The final rule does not prescribe a dedicated broker-compensation row or fixed form for that explanation. That does not eliminate separately applicable finance-charge/itemization treatment.	S009 §600.21(f); S012 response 5.
R028-P1-C048	Section 600.21 does not require a broker to evaluate the financer’s disclosure accuracy or create broker liability for the financer’s noncompliant disclosure.	It does not limit liability arising from the broker’s own representations. No actual liability conclusion is made.	S009 §600.21(g)(1)–(3).
R028-P1-C049	Delivery, receipt, signed acknowledgment, offer acceptance, consummation, and funding are separate analytical events.	The selected texts impose event-specific duties but do not provide evidence that any event occurred. No universal waiting period, actual funding deadline, or actual contract-formation result is established here.	S001 §801(h), (k); S003 introduction; S006; S009 §§600.5, 600.18, 600.21.

Captured table 09

Claim ID · Atomic finding · Conditions, exceptions, and limits · 11 data rows

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C050	For sales-based financing, amount financed is funds provided to the recipient or on the recipient’s behalf, less prepaid finance charge.	It is not necessarily cash deposited directly to the recipient. A prepaid finance charge includes qualifying separately paid charges before/at consummation or charges withheld from proceeds.	S009 §600.1(a)(1), (ac).
R028-P1-C051	Recipient funds are the net funds provided directly to the recipient.	They exclude third-party payments, including broker payments, and known payoffs/paydowns. For changing obligations, the provider may use the balance at disclosure. Actual later funding may therefore differ.	S009 §600.1(af).
R028-P1-C052	Finance charge is the dollar cost of financing and imports Regulation Z’s charge rules on an as-if consumer-credit/creditor basis.	A non-factoring receivables-purchase discount is also included. Importing that calculation does not determine that TILA actually applies or that the transaction is legally a loan.	S001 §801(e); S009 §600.2(a)(1)–(2); S023; S026 §1602(g).
R028-P1-C053	Finance-charge treatment depends on the charge’s function and conditions, not its label alone.	Regulation Z generally includes incident-to/condition-of-credit charges, with rules for third-party charges and specified exceptions. Cash-comparable charges, application fees charged to all applicants, and actual unanticipated late/default charges have distinct rules.	S023 §1026.4(a), (b), (c)(1)–(2).
R028-P1-C054	Insurance, debt-cancellation, security-related official fees, and similar exclusions are conditional.	For example, voluntary credit-insurance/debt-cancellation exclusions require the specified disclosures and affirmative request; property-insurance and itemized security-fee exclusions have their own conditions. No particular fee was classified.	S023 §1026.4(d)–(f), with complete surrounding conditions read.
R028-P1-C055	Part 600 prevents double counting and excludes avoidable charges not imposed incident to credit.	“Avoidable” alone is not a universal exclusion. For benchmark-plus-margin charges that cannot be known in advance, the rule uses the benchmark at disclosure plus the margin for unknown future periods.	S009 §600.2(b)–(d); §600.5(l).
R028-P1-C056	APR measures financing cost annually using both the amounts and timing of value received and payments made, including finance charges.	Section 600.3 permits the actuarial or United States Rule method; §803 requires an estimate based on the prescribed sales/payment/term projection. It does not authorize substituting a factor or dollar charge for APR.	S003 §803(c); S009 §600.3(a)–(c); S024 §1026.22(a)(1).
R028-P1-C057	The actuarial and U.S. Rule methods differ in treatment of unpaid accrued finance charges.	The official interpretation explains capitalization under the actuarial method and separate accumulation under the U.S. Rule. These are calculation conventions, not conclusions about lawful interest or permissible contractual capitalization.	S024 official interpretations 22(a)(1)-1 through -3.
R028-P1-C058	Appendix J’s annualization depends on a correctly determined unit period and payment timing.	The text read specifies nominal annualization and unit-period conventions; daily, weekly, monthly, and semimonthly periods have distinct annual units. Its month-fraction convention is not the same as Part 600’s optional 30.4-day monthly-cost conversion. No numerical solver was run.	S025 Appendix J(a), (b)(1)–(6); S009 §600.1(h), (p).
R028-P1-C059	A sales split percentage, a financing factor, an annual interest rate, APR, finance charge, and total payment answer different questions.	Part 600 defines the split percentage for payment/true-up calculations. It does not supply a universal factor formula or denominator. Section 810 restricts presenting nonannual cost metrics as a “rate” and using “interest” for nonannual percentages.	S007; S009 §600.1(u), (ak), §600.3.
R028-P1-C060	Multiple-payment-option disclosures use the minimum contractually permitted payments; demand balances have a prescribed assumed-term rule.	Demand uses one year unless faster repayment is reasonably anticipated; an alternate maturity stated in the legal obligation controls. No such contractual option or demand obligation is assumed to exist.	S009 §600.20(a)–(b).

Captured table 10

Claim ID · Atomic finding · Conditions, exceptions, and limits · 18 data rows

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C061	The sales-based format is a prescribed ten-row, three-column table, subject to its express additional-row rule.	It applies to §600.6 transactions; sales-based asset-based lending is excluded from this format. Some cells are merged as prescribed. This report is not a completed disclosure form.	S009 §600.6 introduction, (a)–(m).
R028-P1-C062	The funding row gives amount financed and, when lower, net recipient funds with the required itemization reference.	It also requires applicable explanations of changing known payoffs, unknown mandatory third-party payoffs, and same-provider renewal charges.	S003 §803(a); S009 §600.6(b).
R028-P1-C063	The APR row explains annualized estimated cost and identifies the assumed monthly income through the relevant payment channel/mechanism.	It warns that actual income and effective APR may vary. If no finance-charge component is interest-based, the additional prescribed explanation distinguishes APR from an interest rate.	S009 §600.6(c)(1)–(4).
R028-P1-C064	The finance-charge row states dollar financing cost.	A statement that the charge will not increase with longer repayment is optional only when it will not increase under any circumstance if repayment takes longer than estimated.	S003 §803(b); S009 §600.6(d).
R028-P1-C065	The total-payment row states total estimated contractual payments.	Section 803(d) separately defines total repayment as disbursement plus finance charge. The different amount concepts must not be silently equated without tracing deductions and charges.	S003 §803(d); S009 §600.6(e).
R028-P1-C066	The payment row includes average estimated periodic payment/frequency, irregular payment dates/amounts, and reasonably anticipated true-up dates/amounts.	A short explanation is required when necessary to explain why estimated payments differ from actual obligations.	S003 §803(f); S009 §600.6(f).
R028-P1-C067	The payment-terms row explains daily-payment days, applicable sales-split operation, and true-up mechanics.	If a true-up exists, it must explain the preset-payment derivation, mechanism and available contract reference, and minimum payments. A no-minimum/no-fixed-schedule statement is conditional on the actual terms.	S009 §600.6(g).
R028-P1-C068	The term row gives estimated duration and explains the income assumptions underlying it.	The estimate is the time for projected periodic payments to reach required repayment; it is not necessarily an unconditional maturity or prediction of actual payoff.	S003 §803(e); S009 §600.6(h), §600.1(al)(4).
R028-P1-C069	The first prepayment row states whether finance charges beyond accrued unpaid interest remain payable and the maximum noninterest amount.	The negative statement applies only when the contrary condition does not occur at any time during the term. Statutory percentage disclosure remains separately relevant under C074.	S003 §803(h)(i); S009 §600.1(y)(1), §600.6(i)–(j).
R028-P1-C070	The second prepayment row states additional prepayment fees outside finance charge or gives the prescribed negative answer.	It must address fees applicable at any time during the term, not merely on the offer date.	S003 §803(h)(ii); S009 §600.6(k).
R028-P1-C071	The collateral row describes collateral requirements or security interests, if any.	Disclosure of a security provision does not establish its attachment, validity, perfection, priority, or enforceability.	S003 §803(i); S009 §600.6(l).
R028-P1-C072	Nonmonthly periodic payments require an additional estimated-monthly-cost row immediately after the total-payment row.	If estimated monthly cost varies, the row lists the estimates and applicable periods and explains the calculation. Monthly cost includes projected payments; it is not merely monthly fees.	S009 §600.1(p), §600.6(m).
R028-P1-C073	Section 803(g) requires a description of all other potential fees/charges outside finance charge, including draw, late, and returned-payment fees.	Section 600.6 does not expressly allocate a general other-fees row. That layout gap does not establish permission to omit the statutory disclosure. Placement remains unresolved on the retrieved materials.	S003 §803(g), compared with S009 §600.6(a)–(m).
R028-P1-C074	Section 803(h)(i) requires both the percentage of unpaid finance charge retained on early payoff/refinance and the maximum dollar amount.	Section 600.6(j) expressly supplies a maximum-dollar statement but does not separately spell out the statutory percentage field. This is a preserved statute/layout gap.	S003 §803(h)(i), compared with S009 §600.6(j).
R028-P1-C075	Required same-provider payoff as a condition of renewal triggers §808’s renewal disclosures.	For fixed total repayment, the statute specifies its own prepayment-charge calculation and requires disclosure of actual disbursement reduction. No actual renewal or numerical charge is inferred.	S005 §808 introduction, (a)–(b).
R028-P1-C076	The adopted renewal-row calculation does not use the same stated base as §808(a).	Section 600.6(b)(3)(v) refers to a pro rata fee based on the fraction of original amount financed already repaid; §808(a) uses renewal payoff as a fraction of original total repayment, less forgiveness. These are not silently reconciled or numerically implemented here.	S005 §808(a); S009 §600.6(b)(3)(v).
R028-P1-C077	When amount financed exceeds recipient funds, a separate itemization must be substantially similar to the rule’s example and contain the listed minimum components.	Components include direct funds, applicable credit to the recipient’s existing obligation, third-party disbursements, their sum, prepaid finance charges/purpose, and amount financed. The rule permits generic descriptions for specified payee categories. No account number, payee, or transaction value was entered.	S009 §600.17(a)–(c).
R028-P1-C078	Formatting requirements include a prominent summary heading, prescribed signature legend where applicable, numerical presentation, term units, APR rounding, font/column rules, outlined cells, and short-explanation limits.	Term ≤1 year is in days from the day after consummation through final payment; longer terms use years/months with remaining-day month fractions to two decimals. APR is to two decimals; no fractional-cent dollar display. Fonts, 3:3:7 column safe format, and ≤60-word short explanations have their stated conditions and permitted accessibility/medium deviations.	S009 §600.5(a)–(j), (m), (o)–(p).

Captured table 11

Claim ID · Atomic finding · Conditions, exceptions, and limits · 23 data rows

Claim ID	Atomic finding	Conditions, exceptions, and limits	Provision-specific support
R028-P1-C079	Section 803 permits historical or opt-in sales projections and requires notice to the superintendent of the method intended across sales-based offerings.	The retrieved statutory text establishes the notice obligation; a separate current public election form, channel, or filing instruction was not retrieved. No filing or actual election is inferred.	S003 §803(c); S028 search bound.
R028-P1-C080	The historical projection averages receipts through the relevant payment channel plus other-channel receipts that the contract would previously have required to be redirected there.	It is not automatically total business revenue, bank deposits, or a hand-selected gross-sales figure. “Average” means arithmetic mean unless otherwise stated.	S009 §600.1(g), (z); §600.8(b)(1).
R028-P1-C081	The ordinary regulatory historical window is fixed at four to twelve months, either preceding the offer or the same number of highest-volume months in the preceding twelve months.	The rule permits fixing the period for all transactions or by recipient industry, financing amount, or both. The statute’s outer wording is one to twelve months; both texts are preserved. Exceptions below prevent treating four observed months as an unconditional minimum dataset.	S003 §803(c)(i); S009 §600.8(b)(2).
R028-P1-C082	For a business operating less than twelve months, the provider may average the months of operation.	No minimum operating history, actual business age, or actual sales data is invented. A zero-data calculation is not supplied.	S009 §600.8(b)(3).
R028-P1-C083	Historical averaging permits specified exclusions.	They are: a below-average month with a provider-determined cause unlikely to recur; a month lacking requested documentation; and oldest beginning months for which documentation is neither required nor received. Declining the nonrecurring-event exclusion carries the stated no-liability provision.	S009 §600.8(b)(4)(i)–(iii).
R028-P1-C084	Additional documented months may be included on an all-or-none basis, excluding nonoperating months.	This is not authority to select only favorable additional documented months. It operates in addition to the fixed-period rules.	S009 §600.8(b)(5).
R028-P1-C085	The fixed-period decision must be recorded with its effective date, versioned when changed, and retained while effective and for four years afterward.	This is a provider’s required internal record, not a record obtained or invented in this investigation. The adopted text’s cross-reference problem is recorded in C103.	S009 §600.8(b)(6).
R028-P1-C086	Additional assumptions under either sales-projection method must use the best reasonably available information, identify estimates, and explain assumptions.	The general §600.5(k) estimate clause expressly excludes sales-based financing; its sales-based counterparts are §600.8(c) and §600.9(k).	S009 §§600.5(k), 600.8(c), 600.9(k).
R028-P1-C087	A true-up can be a payment to the recipient, a charge, or an adjustment of periodic payments.	For sales-based financing, the mechanism involves preset payments and a contract permitting recipient-requested or financer-initiated adjustment so total payment more closely reflects the contractual split percentage. It is not defined solely as a refund.	S009 §600.1(an), (ap)(1).
R028-P1-C088	Reasonably anticipated true-ups require a reasonable basis informed by similar-contract performance and financer policies/procedures.	A printed reconciliation provision alone does not prove that a refund will occur, an adjustment was requested or granted, or reconciliation works effectively in practice.	S009 §600.1(ao).
R028-P1-C089	Estimated payments and anticipated true-ups must account for specified payments, changing split percentages, minimums, contractual shortfall-threshold payments, and reasonably anticipated finance charges.	The threshold-payment item excludes default fees. No payment schedule or provider policy is assumed.	S009 §600.7(a)(1)–(5).
R028-P1-C090	Estimated monthly cost, finance charge, term, and APR use the selected projection and account for those payment features plus reasonably anticipated true-ups.	A preset debit cannot simply be treated as the final actual payment stream if the rule requires anticipated adjustments. The retrieved §600.7 internal-projection cross-reference is defective; see C103.	S009 §600.7(b)(1)–(6).
R028-P1-C091	Opt-in projections use the provider’s internal estimate for the contract’s particular payment channel, based on best reasonably available information.	Opt-in is subject to the audit/reporting process; it is not unrestricted discretion to select an attractive APR.	S003 §803(c)(ii); S009 §600.9(a)–(d).
R028-P1-C092	Every twelve months, an opt-in provider audits sales-based financings paid off in the preceding twelve months using internal estimates, including contractual true-ups.	The cohort excludes transactions with specified court/arbitration action, stopped collection after determined breach, or agreed contract modification. These are generic cohort rules; no case or collection record was queried.	S009 §600.9(e)(1)–(3).
R028-P1-C093	Retrospective APR ordinarily uses the fully repaid contract’s known payment/fee dates and amounts.	For the audit, the provider may disregard an early payoff lump sum and assume continued periodic payments averaging past periodic payments. Consequently, an audit retrospective APR can incorporate this permitted counterfactual rather than literal realized cash flows.	S009 §600.1(ag); §600.9(f).
R028-P1-C094	Audit APR spread is the relative difference between retrospective and disclosed APR; each audit’s measure is the median spread.	The denominator is disclosed APR, not a percentage-point comparison. No zero-denominator convention is supplied by the selected text.	S009 §600.9(g)–(h).
R028-P1-C095	The rule weights annual audited median spreads by transaction count over the last three, five, and seven audits.	Calculations are required only after enough audits exist. Thresholds are greater than 15%, 10%, and 5%, respectively. The clauses direct use of the historical method for 24 months unless the provider determines historical treatment would have yielded a higher weighted average.	S009 §600.9(i)(1)–(3).
R028-P1-C096	Returning to opt-in after that 24-month period requires a good-faith effort to improve the internal projection method’s accuracy.	Passage of time alone does not satisfy the stated reentry condition. No provider history is assumed.	S009 §600.9(j).
R028-P1-C097	The annual opt-in report is due on or before April 30, beginning in 2025, for a provider that used opt-in during the preceding calendar year.	It is subscribed and affirmed under penalties of perjury and covers the preceding calendar year. This establishes a generic recurring rule, not an actual filer or overdue filing.	S009 §600.22(a).
R028-P1-C098	Reporting includes disclosed estimated and completed-transaction retrospective APRs, annual mean differences weighted by financing amount and unweighted, unusual circumstances, and additional prescribed information.	These reporting means and financing-amount weights differ from §600.9’s medians and transaction-count weights. The superintendent may request additional material and special reports. No reporting template or submission was used.	S009 §600.22(b)–(d).
R028-P1-C099	Part 600 supplies alternative APR accuracy tolerances.	Ordinary tolerance is ±0.125 percentage point; qualifying irregular transactions receive ±0.25 percentage point; a separate relative-percentage test uses the rule’s stated formula and 2.5% threshold. These are disclosure tolerances, not maximum lawful charges.	S009 §600.4(a)(1)–(3).
R028-P1-C100	The bona fide disclosure-error provision requires discovery through the provider’s/financer’s procedures, timely notice, and adjustment.	Within 60 days after discovery and before an action for that error, the financer/assignee must notify and adjust so charges do not exceed the lower of disclosed finance charge or the dollar equivalent of disclosed APR. No actual cure or immunity is found.	S009 §600.4(b).
R028-P1-C101	Section 600.4 separately addresses inadvertent overstatement of enumerated disclosure amounts.	It covers the listed finance charge, APR, payments, monthly cost, maximum noninterest charge, and prepayment amounts. It is not a blanket exemption from the disclosure law or other law.	S009 §600.4(c).

Captured table 12

Claim ID · Finding · Consequence and limit · 6 data rows

Claim ID	Finding	Consequence and limit	Support
R028-P1-C102	The retrieved adopted §600.5(b) names ESRA but cites State Technology Law §§103–109; current ESRA is Article 3, §§301–309.	The relevant current signature/record provisions were read directly. The erroneous-looking citation is not silently treated as correct, and no actual signature is validated.	S009 §600.5(b); S021; S022.
R028-P1-C103	Other internal references in the retrieved adopted text do not align with their apparent targets.	Examples: §600.7 refers to nonexistent §600.9(a)(3); §600.8(b)(6) points to §600.6 for its decision record; §600.5(f)(3)–(4) points to font provisions under subdivision (g), although fonts are under (f); §600.17(a)(6)’s illustrative item-number subtraction does not track its preceding list. These are parsed-text observations, not pixel-confirmed printing defects or judicial invalidity findings.	S009 §§600.5(f), 600.7, 600.8(b)(6), 600.17(a)(6).
R028-P1-C104	No standalone official FAQ/model/reporting-instruction package was retrieved in the bounded official searches.	No assertion is made that none exists. The mandatory rules and embedded examples were examined directly.	S013, S028; failure log.
R028-P1-C105	No PDF pixel inspection was successfully completed.	Screenshot attempts for Part 600 indexes 17, 18, 46, and 47 returned placeholders without inspectable image content. No claim of seeing scanned signatures, visual form layout, typography, or image-based federal equations is made.	S009, S025; retrieval log.
R028-P1-C106	The full later regulatory/session-law/judicial history is unresolved.	No finding that the law has never been amended, stayed, vacated, or otherwise affected is made. A historical agency transition-letter source was not recovered from an official publisher and was not substituted with a private reproduction.	S013–S016, S027–S029.
R028-P1-C107	No actual compliance, exemption, contractual, funding, collection, or legal-validity result follows from this investigation.	Every parent fact and every unaddressed jurisdiction/product/enforcement dimension remains held. No court opinion or federal-preemption ruling was needed to state the selected published disclosure propositions.	Scope restriction; C008 and the conditional claims above.

Captured table 13

Issue · Statutory provision · Adopted rule / agency explanation · 14 data rows

Issue	Statutory provision	Adopted rule / agency explanation	Result for this component
Specific offer	§801(k): recipient-informed terms including price or amount; binding if accepted, subject to stated requirements.	§600.1(ai): written communication combining amount/payment information and rate/price/cost, based on quote-relevant recipient information.	Preserve both formulations. Do not replace the statutory text with an informal “personalized quote” shortcut. C028–C030.
New York nexus	Article 8 does not itself specify the adopted recipient-location test.	§600.24 supplies the recipient-management/residence nexus; APC response 1 explains the final narrowing.	Provider location alone does not answer coverage under this rule. C015.
Financial institution	§§801(f), 802(a) identify exempt categories and authorization conditions.	§600.1(r) includes majority-voting-power-owned entities; APC responses 2–3 explain the distinction.	“Affiliate,” “bank partner,” and “regulated somewhere” are not interchangeable predicates. C016.
Amount threshold	§802(g): individual transaction over $2.5 million.	§§600.1(b), 600.19 specify agreement-level and product-specific measuring units.	Do not test a draw or direct cash deposit against the threshold without the correct unit. C022–C023.
Historical window	§803(c)(i): fixed one-to-twelve-month outer range.	§600.8(b)(2): ordinary four-to-twelve-month fixed window, permitted grouping, plus (b)(3)–(5) exceptions.	Do not describe either “one month is always enough” or “four actual months are always required.” C081–C084.
Signature timing	§809: before authorization to proceed further with the application.	§600.18: before consummation; no signature for an unconsummated transaction; final corresponding disclosure suffices during negotiation.	State both. Do not infer that acknowledgment equals contract acceptance or that signature may always wait until funding. C036–C049.
Other potential fees	§803(g) expressly requires them.	§600.6 lacks an express general-fees row.	Statutory content remains required; exact compliant placement is unresolved on retrieved sources. C073.
Prepayment percentage	§803(h)(i) requires percentage and maximum dollar amount.	§600.6(j) expressly specifies a maximum-dollar statement.	Do not drop the percentage requirement by following the table mechanically. C074.
Renewal charges	§808(a) uses original finance charge, renewal payoff/original total repayment, and forgiveness.	§600.6(b)(3)(v) describes a pro rata portion using original amount financed already repaid.	Different stated bases; no silent reconciliation or numerical illustration. C075–C076.
Broker compensation	Provider definition includes qualifying third-party offer activity.	§600.21(f) requires a written compensation explanation; APC response 5 removes a prescribed compensation row.	Written disclosure remains; no fixed final-row model is established. C047.
Retention actor	General provider framework.	§600.21(d) says provider; APC response 5 says retention applies only to financers.	Preserve the adopted text and identify the narrower explanatory statement. C046.
Electronic signature reference	ESRA is State Technology Law Article 3.	§600.5(b) cites §§103–109 while naming ESRA.	Read §§301–309 and applicable Part 540 text directly; actual implementation remains held. C039–C041, C102.
Rule/form/model status	§811 authorizes prescribed disclosure formats.	§§600.5–600.6 prescribe format/content; §600.17 requires substantial similarity to embedded itemization examples.	These are distinct from a signed actual contract and from the administrative adoption form. C061, C077–C078, C105.
Lawfulness	The chapter saving clause preserves other illegality/licensing law.	APR and disclosure calculation requirements do not supply a loan/sale or enforceability adjudication.	All parent legal-validity questions remain held. C008, C052, C107.

Captured table 14

Displayed concept · Source-defined question · Units / necessary assumptions · 10 data rows

Displayed concept	Source-defined question	Units / necessary assumptions	What it cannot establish by itself
Amount financed	What funding value is provided to or for the recipient after subtracting prepaid finance charge?	Dollars; §600.1(a)(1), (ac).	Direct cash received, total repayment, or lawful principal.
Recipient funds	What is provided directly to the recipient after specified deductions/payoffs?	Dollars; balances may be assumed as of disclosure under §600.1(af).	Exact later funding when payoff balances change.
Finance charge	What is the dollar cost included under the imported and state-specific charge rules?	Dollars; charge inclusion/exclusion predicates matter.	An annual rate, lawful-interest conclusion, or total payments.
Estimated total payment	What total contractual payments are projected?	Dollars; estimated payment stream and applicable contract features.	Cost alone, actual payoff total, or an unconditional fixed obligation.
Estimated payment	What periodic/irregular payment and true-up amounts are projected?	Dollars per stated period, plus specified dates/amounts for irregular items.	Actual future debits or effective reconciliation.
Estimated monthly cost	What is the projected average monthly payment burden?	Dollars/month; estimated total payments and estimated term. Optional term conversion uses 30.4 days/month.	Monthly finance charges alone or APR.
Split percentage	What percentage is used to determine payments or true-ups?	Percentage of the contractually relevant sales/receipt channel.	Annual borrowing cost.
Factor or other nonannual cost metric	Only the question established by its expressly defined base and operation.	No universal factor formula or base is supplied by the selected texts.	APR, finance charge, or total repayment without further definitions and timing.
Estimated APR	What is the annualized cost of the projected value/payment stream?	Percent per year; prescribed charge treatment, amount/timing, method, and sales projection.	Actual realized cost, statutory maximum interest, loan characterization, or enforceability.
Audit retrospective APR	What does the completed-transaction audit calculation show?	Percent per year; actual known flows, subject to the permitted early-lump-sum adjustment.	Necessarily the unadjusted realized cash-flow APR in every audit.

Captured table 15

Branch ID / status · Qualitative branch and rule/claim/source · Conditions and missing evidence · 22 data rows

Branch ID / status	Qualitative branch and rule/claim/source	Conditions and missing evidence	Adverse inference to avoid	Exact next permissible public-law read
R028-P1-E001 — A/X	New York nexus unknown. C015; S009 §600.24.	Whether business direction/management or natural-person legal residence meets the rule is held; no location representation examined.	“Provider is in New York, therefore covered,” or “provider is elsewhere, therefore excluded.”	Current compiled §600.24 and any official amendment or published generic DFS interpretation of that subsection. No address/ID search.
R028-P1-E002 — A/X	Commercial/personal purpose uncertain. C010, C025; S001 §801(b), S009 §600.1(m).	Intended primary purpose and an eligible purpose statement are unknown; TILA coverage/compliant disclosure not established.	Treating a business label as conclusive commercial purpose, or a voluntary TILA form as an exemption.	§801(b), §600.1(m), APC response 7; a federal coverage provision only if a narrower generic proposition becomes necessary.
R028-P1-E003 — A/X	Amount and threshold unit unknown. C022–C023, C050–C051.	Product, agreement-level availability, amount financed, prepaid charges, and direct funds are held.	Comparing a single debit, draw, or net deposit to $2.5 million.	§§600.1(a)–(d), 600.19 in current compilation; no transaction arithmetic.
R028-P1-E004 — A/X	Provider/broker/recipient status uncertain. C012–C014.	Offer conduct, compensation, agency, funding role, and authority are unknown.	Assuming every intermediary is the financer, or that a broker may sign as recipient.	§801(h)–(i); §§600.1(j), (q), (ad)–(ae), 600.18(a), 600.21.
R028-P1-E005 — P/X	Transaction-count exemption unestablished. C021; §802(f).	Number, location, twelve-month interval, and the treatment of renewals/advances are unestablished.	Using five SBF deals only, a calendar year automatically, or importing §600.1(am) beyond its stated target.	Any current official generic interpretation of §802(f)’s transaction count; current §802(f) and §600.1(am). No roster or transaction records.
R028-P1-E006 — A/X	Bank/other exemption conditions uncertain. C016–C020, C024.	Charter/authorization category, voting ownership, technology interest, Farm Credit regulation, real-property security, true lease, or dealer/rental predicates are held.	Exemption merely because of a bank relationship, collateral, software role, or vehicle-related purpose.	Relevant §802 clause and its definitional cross-reference; only a specifically needed generic classification statute, never an entity/license lookup.
R028-P1-E007 — P/X	Sales-based versus closed/open-end, factoring, or lease category uncertain. C011, C026–C027.	Contractual payment and product features are held; asset-based overlap unresolved.	Treating an “MCA” label as controlling or applying §600.6 to every receivables-related product.	§801(a), (c), (d), (j); §600.1(e), (k), (w), (s); §600.6 and §600.15 introductions. Full other-product work remains held.
R028-P1-E008 — A/X	Specific offer versus advertisement/inquiry. C028–C030, C035.	Written terms, quote-relevant recipient information, both regulatory quote elements, and binding character are unknown.	Every advertisement requires the final table, or every communication called an advertisement is exempt.	§801(k); §600.1(f), (n), (ai); §600.3; APC response 9.
R028-P1-E009 — A/X	Offer terms changed. C032–C033, C037.	Whether change preceded or followed consummation, increased cost, addressed default, or merely reflected payoff drift is held.	Every change requires identical treatment; a payoff exception covers an increased APR; a default exception covers a new unrelated financing.	§600.1(f)(2); §600.5(n); §600.6(b)(3); §600.18(c).
R028-P1-E010 — P/X	Delivery versus acknowledgment/acceptance/funding. C036–C043, C049.	Delivery, receipt, signatory authority, intent, final corresponding terms, consummation, and funding evidence are all held.	A sent link proves receipt; acknowledgment proves contract formation; a signature proves funding.	§809; §§600.5(b), (e), (j), 600.18; ESRA §§302, 304–309. Any formation inquiry remains outside this pass.
R028-P1-E011 — A/X	Broker versus provider obligation. C044–C048.	Transmission route, timing, direct-delivery confirmation, generated documents, and compensation arrangements unknown.	Broker involvement transfers every financer obligation or immunizes the broker’s own representations.	§600.21(a)–(g) and APC response 5, preserving the retention-language difference.
R028-P1-E012 — A/X	Estimated versus actual term/payment. C063, C066–C072, C089–C093.	Actual sales, payment timing, contractual minimums, irregular payments, fees, and adjustments are held.	The disclosed estimated term is necessarily the contract maturity or actual payoff date.	§§600.1(ag), (al), 600.6(f)–(m), 600.7, 600.9(f).
R028-P1-E013 — A/X	Historical-sales versus opt-in estimate. C079–C086, C091.	Election, fixed window, channel, documentation, exclusions, internal projection, and method notice are unknown.	Inventing a three-month policy from an illustrative sentence, assuming undocumented sales, or assuming opt-in without audit duties.	§803(c); §§600.8–600.9, plus any official public election instruction if published.
R028-P1-E014 — A/X	Reconciliation disclosed versus effective adjustment. C067, C087–C090.	Contract mechanism, request/initiation, actual adjustment, similar-contract performance, and policy are held.	A reconciliation paragraph proves actual relief, a refund, or true-sale characterization.	§§600.1(an)–(ap), 600.6(g)(2)(iii), 600.7. Actual performance and characterization remain held.
R028-P1-E015 — A/X	Factor versus APR/finance charge/total payment. C050–C059, C065.	Factor definition/base, charges, timing, and projected payment stream unknown.	Calling a factor an annual rate or treating total payment as dollar financing cost.	§810; §§600.1(a), (u), (ak), 600.2–600.3; imported §1026.22/Appendix J only to the necessary calculation proposition.
R028-P1-E016 — P/X	Generic model versus signed actual contract. C061, C077–C078, C105.	No executed disclosure or contract exists in the research record; pixels not inspected.	An embedded example proves the actual form was compliant, delivered, or signed.	Current §§600.5–600.6 and 600.17; inspect official example pixels if a public-view capability supplies them. No filling/submission.
R028-P1-E017 — P/X	Current adopted rule versus proposal/history. C002–C007, C106.	Later-current compilation and complete intervening history remain unverified.	Treating a 2022 proposal, 2026 page update, or rule-review invitation as a new effective rule.	Current compiled Part 600 plus intervening official State Register adoption/amendment notices. No docket/status search.
R028-P1-E018 — A/X	Disclosure compliance versus loan/usury/collection validity. C008, C052, C107.	All substantive characterization, licensing, enforceability, and collection facts/law are held.	“Disclosed APR means lawful charge,” “disclosure means loan,” or “missing disclosure automatically eliminates debt.”	The chapter saving clause and §801(h) suffice here. No broader investigation is necessary for the selected proposition.
R028-P1-E019 — A/X	Multiple offers versus multiple payment options. C031, C060.	Whether there are separate offers, customization, or choices within one contract is unknown.	Applying the selected-offer timing rule as though it were the minimum-payment calculation rule, or vice versa.	§600.1(f)(1), (4), compared with §600.20(a).
R028-P1-E020 — P/X	Renewal payoff and fee overlap. C062, C075–C077.	Required same-provider payoff, original bases, retained fees, forgiveness, and net disbursement are held.	Using one formula as though statute and regulation stated identical inputs.	§808(a)–(b), §600.6(b)(3)(v), §600.17; any official correction or generic explanatory rule. No invented calculation.
R028-P1-E021 — A/X	Opt-in audit versus annual regulatory report. C092–C098.	Cohort, completed financings, number of audits, actual/estimated APRs, and report history are held.	Equating annual median spreads/count weights with reporting means/financing-amount weights, or declaring a filing overdue.	§§600.9(e)–(j), 600.22(a)–(d), and any current public reporting specification.
R028-P1-E022 — A/X	Disclosure tolerance versus guaranteed compliance. C099–C101.	Calculated/disclosed APR, irregularity, error discovery, intent, notice, adjustment, and action timing are held.	Treating 2.5% as 2.5 percentage points, or assuming a cure/tolerance proves lawful pricing or collectibility.	§600.4(a)–(c) and the specifically incorporated APR calculation provisions.

Captured table 16

Worksheet item · Rule/claim reference · Evidence or public-law citation to record · 28 data rows

Worksheet item	Rule/claim reference	Evidence or public-law citation to record	Finding	Open issue / permitted public-law follow-up
Governing version and operative dates	C001–C007	______	______	______
Recipient New York nexus rule	C015	______	______	______
Intended primary purpose	C010	______	______	______
Provider / financer / broker / recipient distinction	C012–C014	______	______	______
Product category and overlap	C011, C026–C027	______	______	______
Amount measure and threshold unit	C022–C023, C050–C051	______	______	______
Twelve-month transaction-count rule	C021	______	______	______
Each potentially applicable §802 exemption	C016–C024	______	______	______
TILA exclusion’s two predicates	C025	______	______	______
Specific-offer predicates	C028–C030	______	______	______
Multiple-offer / customization treatment	C031	______	______	______
Changed terms / default / payoff-drift distinction	C032–C034	______	______	______
Delivery and broker-transmission rule	C044–C045	______	______	______
Signature timing and final corresponding disclosure	C036–C038	______	______	______
Electronic intent, association, timestamp, durable copy	C039–C041	______	______	______
Contract/disclosure/itemization separation	C042–C043	______	______	______
Funding amount, recipient funds, deductions, itemization	C050–C051, C062, C077	______	______	______
Finance-charge inclusion/exclusion treatment	C052–C055	______	______	______
APR method, units, assumptions, rounding	C056–C059, C078	______	______	______
All §803(a)–(i) disclosure subjects	C062–C074	______	______	______
Renewal provisions and formula discrepancy	C075–C076	______	______	______
Historical method and complete exception set	C079–C086	______	______	______
True-up definition and anticipated-adjustment treatment	C087–C090	______	______	______
Opt-in cohort, spread, weighting, thresholds, reentry	C091–C096	______	______	______
Annual reporting rule and distinct statistics	C097–C098	______	______	______
Tolerance/cure conditions	C099–C101	______	______	______
Source defects, pixel bounds, and later-history gaps	C102–C106	______	______	______
Preserved parent holds; no acceptance determination	C107	______	______	______

Captured table 17

Question / subquestion · Coverage · Claims, sources, examples · 31 data rows

Question / subquestion	Coverage	Claims, sources, examples	Missing evidence or limit	Exact permissible next investigation
1(a): Actual statutory codification and selected complete provisions	Answered	C001–C004; S001–S008, S015–S016	Other-product and remedy provisions intentionally held.	Only a necessary amendment/session-law check for these selected sections.
1(b): Adopted Part 600 provisions actually necessary	Answered as adopted; partial as later-current compilation	S009 clause/page map; C005–C007, C106	S027 access failure.	Current compiled §§600.0–600.9, .17–.22, .24–.25 and any intervening official amendments.
1(c): Scope, purpose, roles, nexus	Answered generically; actual application excluded	C010–C015; E001–E004	All actual role, purpose, and nexus facts held.	Specific listed definitions; no identity/location search.
1(d): Amount and unit thresholds	Answered generically	C022–C024; E003	Actual amount/product facts held.	§§600.1(a)–(d), 600.19 and §802(h), if needed for a further generic clarification.
1(e): Transaction count	Partial	C021; E005	No specific official count interpretation retrieved for edge cases.	Official generic interpretation or amendment addressing §802(f).
1(f): Every statutory exemption	Answered at clause level; subordinate actual classification excluded	C016–C025; S018–S020; E006	Full Farm Credit, vehicle licensing, and lease-characterization regimes not investigated.	Only the specific generic definitional cross-reference needed; no status records.
1(g): Disclosure versus substantive validity	Answered boundary	C008, C052, C107; E018	Loan/sale, lawful charge, license, collection questions held.	No further read necessary to preserve the boundary.
2(a): Specific-offer timing	Answered generically	C028–C031, C035; E008, E019	No actual quote/application.	§801(k), §600.1(f), (n), (ai), §600.3.
2(b): Changed terms and exceptions	Answered generically	C032–C034; E009	No actual amendment/default/payoff.	§600.1(f)(2)–(3), §600.5(n), §600.6(b)(3).
2(c): Signature and acknowledgment	Answered with textual distinction preserved	C036–C043; E010	Statute/rule timing wording not collapsed; actual authority/intent held.	Current §809, §600.18, and relevant ESRA text.
2(d): Broker transmission and duties	Answered; retention wording tension identified	C044–C048; E011	No transmission/compensation facts; APC/body tension.	Current §600.21 and any official clarification of retention actor.
2(e): Acceptance, formation, funding	Answered as distinctions; outcomes excluded	C040, C049; E010	No actual event or formation evidence.	No contract-law or factual investigation necessary for this pass.
2(f): Generic forms and pixel bounds	Partial	C061, C077–C078, C104–C105; S009, S011	No standalone model package retrieved; no inspectable pixels.	Official current model instructions, if published; direct public image inspection if available.
3(a): All selected disclosure items	Answered, with placement gaps	C062–C078; S003, S005, S009	General fees and prepayment percentage placement unresolved.	Official clarification/correction of §600.6 against §803(g), (h).
3(b): Estimated versus actual amounts/term	Answered generically	C050–C072, C093; E012, E015	All actual payment/sales/funding facts held.	Selected definitions and estimate rules only.
3(c): Historical method	Answered generically	C079–C086; E013	No elected period, documentation, sales history, or policy.	Current §600.8 and public method-election instructions if available.
3(d): Opt-in method and review	Answered rules; operational instructions partial	C091–C098; E021	No current standalone reporting/election instruction retrieved.	Official public §600.22 reporting specification and §803(c) notice instruction.
3(e): Reconciliation and risk explanation	Answered generically; actual effectiveness excluded	C067, C087–C090; E014	No contract/performance/policy facts.	§§600.1(an)–(ap), 600.6(g), 600.7.
3(f): APR/finance-charge methods and units	Answered at required framework level; numerical implementation not undertaken	C052–C060, C094, C099; S023–S026	Appendix J image equations not pixel-read; no transaction inputs.	Inspect exact Appendix J equations only if a separately authorized numerical calculation becomes necessary.
3(g): Broad pricing/usury/effective-APR modeling	Excluded	C008, C107; E018	Parent hold.	None within this pass.
4(a): Enacted/adopted/effective/compliance dates	Answered	C002–C005; S010, S015–S016	Historical transition guidance remains separately unverified.	Official historical transition letter only if needed to answer a particular 2022 application question.
4(b): FAQs/forms/APC role	Answered hierarchy; source availability partial	C009, C061, C077, C104; S011–S012, S028	No standalone current FAQ/model/reporting package retrieved.	Relevant official generic publication, without filing/contact.
4(c): Proposals and later amendments	Partial	C006–C007, C106; E017	Full proposal texts and complete intervening amendment history not read.	Official current compilation plus exact intervening adoption/amendment notices.
4(d): Future-effective material	Answered for encountered cross-references	S020–S021	Future GBL/ESRA alternatives kept separate; full unrelated future regimes held.	Relevant effective-date note only if it changes a selected proposition.
4(e): Preemption or published opinions	Excluded as unnecessary	C107; E018	No opinion, holding, docket, case record, or later case history researched.	Only a specifically necessary published majority opinion/authority under a later narrowed question; no docket inquiry.
4(f): Withdrawn/stayed/vacated status	Unresolved outside selected publication check	C106	No complete litigation or guidance-withdrawal history. No CFPB circular/advisory used.	Exact official status publication only if needed for a selected proposition; no case-record search.
5(a): Provision-specific comparison	Answered	§3; C028–C029, C073–C076, C102–C103	Identified tensions remain unresolved, not repaired.	Exact official correction/interpretation for each tension.
5(b): Blank worksheet	Answered	§6	Intentionally blank; no actual facts.	None required.
5(c): At least twelve qualitative branches	Answered: 22 branches	E001–E022	Every actual application held.	Public-law-only next reads are specified per branch.
5(d): Optional arithmetic	Omitted; symbolic rules supplied	§4; C050, C058, C072, C075, C094	No justified complete transaction dataset; renewal-text tension; image-equation limit.	No invented numerical example.
5(e): Source/read log, crosswalk, gaps, self-check	Answered	§§1, 7–10	Currentness and pixel gaps expressly remain.	Listed source-specific reads; no acceptance or independent-review claim.

Captured table 18

Gap · What remains unresolved · Why it matters · 10 data rows

Gap	What remains unresolved	Why it matters	Permissible next public-law work
G1 — Later-current Part 600 compilation	State-linked NYCRR pages were unavailable.	The final-adopted text and current agency listing do not alone prove the complete text as amended through the access date.	Retrieve the current compilation through an ordinary permitted public view and compare only the selected sections with S009; read any intervening official adoption notices.
G2 — Complete amendment/session-law history	Selected enacted changes were verified, but not every later session law or amendment history entry.	Publisher revision/update dates cannot certify comprehensive legal currentness.	Exact official statutory amendment histories and chapter texts affecting the selected provisions.
G3 — Historical transition guidance	A December 2021 transition letter was not recovered from an official DFS publication.	January 1, 2022 statutory effectiveness and August 1, 2023 regulatory compliance must not be converted into an unsupported assertion about every intervening obligation or enforcement policy.	The exact official historical letter and any superseding official generic statement, if that historical question becomes necessary.
G4 — Fees and prepayment percentage placement	The sales-based table does not expressly allocate all §803(g) and §803(h)(i) information.	A mechanically copied table could omit a statutory subject.	An official generic clarification or amendment addressing §600.6’s relation to those clauses.
G5 — Renewal calculation discrepancy	Section 808(a) and §600.6(b)(3)(v) use different stated fractions/bases.	A numerical example could silently choose one and conceal the unresolved text.	Official correction or generic interpretive authority limited to these clauses.
G6 — Drafting/cross-reference defects	The retrieved ESRA, historical-record, internal-projection, font, and item-number references do not fully align.	They affect precise implementation and must not be silently renumbered.	Current compiled counterparts and any official correction. Pixel inspection would verify the PDF’s visual text but would not itself resolve legal interpretation.
G7 — Separate public guidance/forms	No standalone current FAQ/model/reporting/election instruction package was retrieved.	Statutory method notice and annual reports have operational details that may be prescribed elsewhere.	Targeted official public instructions for §803(c) and §600.22; no portal entry, submission, contact, or records request.
G8 — Pixel and full numerical-method inspection	PDF screenshots supplied no images; Appendix J image equations were not inspected.	No visual-form validation or complete numerical APR implementation can be claimed.	Public image inspection of the exact pages/equations if needed; numerical modeling remains held.
G9 — Transaction-count edge cases	No definitive generic interpretation was retrieved for all renewal/advance/intermediary counting questions under §802(f).	The expressly limited §600.1(am) definition cannot be extended without authority.	An official generic interpretation or amendment focused on §802(f).
G10 — Actual application and broader law	All actual facts and parent legal dimensions remain uninvestigated.	Conditional public rules do not supply the missing factual predicates or decide substantive validity.	None within this pass.

Captured table 19

Log item · Action/result · Read or failure bounds · 15 data rows

Log item	Action/result	Read or failure bounds	Treatment
L01 — Statutory body	Retrieved selected current official Senate sections.	Full bounds in S001–S008.	Primary foundation; metadata kept separate from operative dates.
L02 — Adopted rule	Retrieved the DFS final-adopted PDF and agency-linked alias.	Full selected read map in §1; same instrument.	Primary regulatory foundation, subject to G1.
L03 — Adoption and agency explanation	Retrieved DOS notice, DFS notice, complete APC, current listing, and 2026 review entry.	S010–S014.	Adoption status and explanatory context; no independent-source inflation.
L04 — Enactment history	Retrieved enacted-bill text and signed-chapter actions for 2020 chapter 369 and 2021 chapter 61.	S015–S016; selected clauses only.	Historical changes verified; no complete session-law audit.
L05 — Necessary cross-references	Retrieved UCC, vehicle/rental definitions, ESRA, ITS rules, federal finance-charge/APR provisions, and creditor definition.	S018–S026.	Used only for the selected definitions/calculation/signature propositions.
L06 — NYCRR failures	State-linked index and located §600.1 page returned 403.	Complete URLs in S027.	No workaround; adopted DFS text used with explicit currentness gap.
L07 — DFS navigation failures	Earlier paths failed: https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services and https://www.dfs.ny.gov/industry_guidance/regulations/proposed_fsl.	No substantive body retrieved at those paths.	Working current regulatory-activity page used; failed paths do not show absence of law.
L08 — Historical bill navigation	A direct amendment path did not resolve: https://www.nysenate.gov/legislation/bills/2019/S5470/amendment/B.	No reliance on failed route.	Base official page supplied the B-version text and action history; versions kept distinct.
L09 — OLRC route failures	Preliminary paths returned 404: https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1602 and https://uscode.house.gov/view.xhtml?req=%28title%3A15+section%3A1602+edition%3Aprelim%29.	No body read there.	The publicly indexed current OLRC page in S026 succeeded; no access-control bypass.
L10 — Literal ESRA citation problem	Following the adopted citation led to unrelated State Technology Law Article 1 material; attempted §§108–109 paths were unavailable: https://www.nysenate.gov/legislation/laws/STT/108, https://www.nysenate.gov/legislation/laws/STT/109.	Unrelated Article 1 text was not used as ESRA authority.	Correctly named ESRA located through the official Article 3 index and read directly.
L11 — Screenshot attempts	Requested Part 600 PDF indexes 17, 18, 46, 47.	Returned image placeholders without inspectable image content.	No pixel inspection claimed. Parsed text only.
L12 — Guidance and historical letter search	Bounded official searches and DFS catalog review did not retrieve the separate FAQ/model/reporting package or official historical transition letter.	Private reproductions surfaced in discovery but were not used as substantive foundation.	G3 and G7 preserved; no claim of nonexistence.
L13 — Federal display bounds	Compared current CFPB and eCFR publications.	Shared selected finance-charge/APR provisions used; image equations and nonselected consumer-overdraft history not resolved.	No broad federal coverage, amendment-history, preemption, or guidance-withdrawal conclusion.
L14 — Overlong retrieval output	One overlong combined retrieval did not supply readable complete output.	No unread remainder was credited as reviewed; necessary selected provisions were retrieved again separately.	Read bounds reflect actually available text, not merely a requested download.
L15 — Courts and actual records	No judicial opinion or case-specific source was necessary for the selected propositions.	No docket, case-record, party, license, entity, account, property, or transaction query.	All litigation and actual-status dimensions remain held.

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R028-P1-C001 Saved research record

The statutory framework is Financial Services Law Article 8; Part 600 implements its commercial-financing disclosure provisions.

Recorded check status: fresh selected definitions and adopted scope checked other statutes history held

Conditions, exceptions, and limits: This component reads §§801–803 and 807–811, not the entire law of commercial finance. Article 8’s other-product and enforcement components remain held.
Provision-specific support: S001–S008; S009 §600.0.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_definitions_and_adopted_scope_checked_other_statutes_history_held", "scope": "Selected801/600.0 and metadata checked; other statutory sections/historical updates not all reopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C002 Saved research record

The original enactment was Laws of 2020, chapter 369, signed December 23, 2020.

Recorded check status: historical or separate authority original attribution unreopened

Conditions, exceptions, and limits: Its original 180-day effective-date clause and lower amount threshold are historical; they are not substituted for the amended law.
Provision-specific support: S015, official action; B-version §802(g), act §2.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "historical_or_separate_authority_original_attribution_unreopened", "scope": "Complete history/saving clause/current listing/review/form-status premises remain original attribution; fresh statutory definitions or certification do not close them.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C003 Saved research record

Laws of 2021, chapter 61, signed February 16, 2021, amended the framework and set the underlying act’s operative date to January 1, 2022.

Recorded check status: historical or separate authority original attribution unreopened

Conditions, exceptions, and limits: The amendment also authorized implementing rulemaking immediately; its own effectiveness provision coordinates the amended statutory sections with the underlying act.
Provision-specific support: S016, act §§2–3.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "historical_or_separate_authority_original_attribution_unreopened", "scope": "Complete history/saving clause/current listing/review/form-status premises remain original attribution; fresh statutory definitions or certification do not close them.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C004 Saved research record

January 7, 2022 on the selected Senate pages is revision metadata.

Recorded check status: fresh selected definitions and adopted scope checked other statutes history held

Conditions, exceptions, and limits: It is not the statutory operative date, final-rule adoption date, or compliance date.
Provision-specific support: S001–S008 compared with S016.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_definitions_and_adopted_scope_checked_other_statutes_history_held", "scope": "Selected801/600.0 and metadata checked; other statutory sections/historical updates not all reopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C005 Saved research record

Part 600 was filed January 12, 2023 and became effective February 1, 2023; its six-month compliance interval yields August 1, 2023.

Recorded check status: fresh adoption and six calendar month interval checked

Conditions, exceptions, and limits: August 1 is the calendar result of §600.25(b) applied to the verified February 1 publication date. Effectiveness and compliance are different events. No actual transaction deadline is inferred.
Provision-specific support: S010 notice; S009 §600.25(a)–(b).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_adoption_and_six_calendar_month_interval_checked", "scope": "Notice date and600.25 separate effectiveness/compliance; February1 plus6 calendar months is August1,2023. No transaction deadline.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C006 Saved research record

The currently served DFS listing and its 2026 rule-review entry continue to identify the February 1, 2023 Part 600 adoption.

Recorded check status: historical or separate authority original attribution unreopened

Conditions, exceptions, and limits: Neither publication supplies a complete later-amendment, session-law, or judicial-history audit. The unavailable NYCRR compilation remains a material currentness gap.
Provision-specific support: S013, S014, S027.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "historical_or_separate_authority_original_attribution_unreopened", "scope": "Complete history/saving clause/current listing/review/form-status premises remain original attribution; fresh statutory definitions or certification do not close them.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C007 Saved research record

The 2021 proposal and September 14, 2022 revised proposal are historical stages, not the final operative text.

Recorded check status: historical or separate authority original attribution unreopened

Conditions, exceptions, and limits: Their dates are verified in the certification/adoption material. Their complete bodies were not read, and no full proposal-to-final redline is claimed.
Provision-specific support: S009 certification; S010–S012.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "historical_or_separate_authority_original_attribution_unreopened", "scope": "Complete history/saving clause/current listing/review/form-status premises remain original attribution; fresh statutory definitions or certification do not close them.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C008 Saved research record

The disclosure enactment does not authorize otherwise illegal transactions or dispense with an otherwise required license.

Recorded check status: historical or separate authority original attribution unreopened

Conditions, exceptions, and limits: It therefore cannot alone settle loan characterization, usury, licensing, enforceability, or collectibility. Those questions require different authority and facts and remain held.
Provision-specific support: S016 saving clause; S001 §801(h).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "historical_or_separate_authority_original_attribution_unreopened", "scope": "Complete history/saving clause/current listing/review/form-status premises remain original attribution; fresh statutory definitions or certification do not close them.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C009 Saved research record

The agency’s comment assessment can explain drafting choices but does not replace statutory or regulatory language.

Recorded check status: fresh operative and APC wording distinguished

Conditions, exceptions, and limits: Its response concerning retention uses narrower terminology than §600.21(d); that difference is preserved below. No staff statement is treated as legislation.
Provision-specific support: S012 responses 1–9; S009 §600.21(d).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_operative_and_APC_wording_distinguished", "scope": "Entire agency explanation compared with600.21; provider/financer retention tension and general compensation writing preserved; no operative rewrite.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C010 Saved research record

Commercial financing is financing whose proceeds the recipient does not intend to use primarily for personal, family, or household purposes.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: The provider may rely on a separate signed statement, a signed/consented application or other document, or an oral statement documented in the application file. Electronic consent is permitted. The statute does not require checking later actual use against that statement.
Provision-specific support: S001 §801(b).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C011 Saved research record

Sales-based financing includes repayment varying as a percentage of sales/revenue and fixed-payment financing with reconciliation adjusting payment to such a percentage.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: A product label alone does not establish the definition. Fixed scheduled debits alone do not exclude the category when the defined reconciliation arrangement exists.
Provision-specific support: S001 §801(j); S009 §600.1(ah), (ap)(1).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C012 Saved research record

A provider extends a specific offer; unless exempt, the definition also includes a person who solicits and presents specific offers for a third party.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: Making an offer or giving disclosures alone does not mean originating, making, funding, or providing the financing. The regulation includes a financer communicating through an agent or broker with an expectation of onward communication.
Provision-specific support: S001 §801(h); S009 §600.1(ad).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C013 Saved research record

A financer is the person providing or to provide the financing; a broker is a compensated participant in the specified intermediation activities.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: Broker activities include negotiation, advice, preparation/gathering/delivery of documents, communications, or obtaining signatures. Financer, recipient, and recipient’s agent are excluded from that broker definition. Mere role labels do not resolve overlapping provider duties.
Provision-specific support: S009 §600.1(j), (q).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C014 Saved research record

A recipient applies and receives a specific offer; an authorized representative can qualify, but a broker cannot be the recipient.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: For one offer, controlled, controlling, or commonly controlled recipients are included together only when the single offer is conveyed simultaneously in the same writing. This is not general aggregation of all affiliates or all transactions.
Provision-specific support: S001 §801(i); S009 §600.1(ab), (ae).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C015 Saved research record

The disclosure nexus is a recipient business principally directed or managed from New York, or a natural-person recipient legally resident in New York.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: A provider may rely on the specified written representation/business address; for a natural person, the specified government-ID address or written legal-address representation. Provider location alone is not the adopted nexus test. No actual address or ID was sought.
Provision-specific support: S009 §600.24(a)–(b); S012 response 1.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C016 Saved research record

Financial institutions described by §801(f) are exempt. The regulation includes entities majority-owned through voting power by such an institution, directly or indirectly.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: The statutory bank, trust, industrial-loan, savings, and credit-union categories contain charter/authorization conditions, including authorization to transact business in New York. Mere affiliation or use of a banking service is not the stated majority-voting-power condition.
Provision-specific support: S001 §801(f); S002 §802(a); S009 §600.1(r); S012 responses 2–3.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C017 Saved research record

A technology-services provider can be exempt when serving an exempt entity’s financing program.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: It must have no interest, and no arrangement or agreement to purchase an interest, in financing extended through that program. The exemption is capacity- and condition-specific.
Provision-specific support: S002 §802(b).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C018 Saved research record

A lender regulated under the federal Farm Credit Act is exempt.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: The statute requires that regulated status; no actual institution’s status was investigated. The entire federal Farm Credit regulatory system was not independently analyzed.
Provision-specific support: S002 §802(c).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C019 Saved research record

A commercial-financing transaction secured by real property is exempt.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: The clause does not say that any collateral, guarantee, or security interest is enough. No actual security or property facts were investigated.
Provision-specific support: S002 §802(d).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C020 Saved research record

A lease within UCC §2-A-103 is exempt.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: That definition concerns transfer of possession/use of goods for a term and consideration, excluding a sale or retention/creation of a security interest. A security-interest “lease financing” is separately defined in Part 600. Actual characterization remains held.
Provision-specific support: S002 §802(e); S018 §2-A-103(1)(j); S009 §600.1(w).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C021 Saved research record

A person or provider making no more than five commercial-financing transactions in New York in a twelve-month period is exempt.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: The unit is not stated as five sales-based transactions, five offers, or five transactions in a calendar year. Section 600.1(am)’s advances definition expressly addresses §801(c), so it cannot silently settle the §802(f) counting issue.
Provision-specific support: S002 §802(f); S009 §600.1(am).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C022 Saved research record

An individual commercial-financing transaction over $2,500,000 is exempt under the amount clause.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: Exactly $2,500,000 is not exempt under this clause alone. The regulation uses the aggregate amount available under the agreement, not a particular advance; ordinary sales-based financing uses “amount financed” under §600.19(d).
Provision-specific support: S002 §802(g); S009 §600.1(b), §600.19(d).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C023 Saved research record

Other categories have different threshold measures.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: Open-end uses approved credit limit. Asset-based/factoring treatment requires the specified general agreement, limit above $2.5 million, and timely written reasonable expectation that more than $2.5 million will be advanced and outstanding; without all conditions the offer is deemed at or below the threshold. Those categories are boundary reads, not completed product studies.
Provision-specific support: S009 §600.19(a)–(c), all nested clauses.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C024 Saved research record

The dealer/rental-company exemption requires the specified recipient or affiliate status and an agreement or open-end plan of at least $50,000.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: It includes loans made pursuant to that transaction. It is not a blanket exemption for financing a vehicle. Dealer and rental-company definitions were read; no actual dealer, affiliate, vehicle, or registration status was inferred.
Provision-specific support: S002 §802(h); S019 §415(1), §137-a; S020 §396-z(1)(b), (c), (k).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C025 Saved research record

Part 600 excludes a transaction subject to TILA for which a TILA-compliant disclosure is provided.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: Both predicates matter. Voluntarily using a TILA-style form for a transaction not subject to TILA does not establish this exclusion.
Provision-specific support: S009 §600.1(m); S012 response 7.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C026 Saved research record

Sales-based, closed-end, open-end, factoring, and lease definitions must be distinguished before selecting a disclosure format.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: Open-end requires the stated repeat-credit/replenishment features; factoring concerns existing legally enforceable payment claims for supplied goods/rendered services. Some sales-based arrangements also meet the closed-end definition; §600.10’s introduction routes such arrangements away from its ordinary closed-end format.
Provision-specific support: S001 §801(a), (c), (d), (j); S009 §600.1(k); §600.10 introduction.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C027 Saved research record

Section 600.6 expressly excludes asset-based lending that also meets the sales-based definition from its sales-based table.

Recorded check status: fresh selected adopted scope definitions checked statutory exemption and nested crossrefs held

Conditions, exceptions, and limits: Asset-based lending has the advance/forwarding-payment conditions in §600.1(e), (s), and its own §600.15 route. This report does not resolve that separate product’s full disclosure method.
Provision-specific support: S009 §600.1(e), (s); §600.6 introduction; §600.15 introduction.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_selected_adopted_scope_definitions_checked_statutory_exemption_and_nested_crossrefs_held", "scope": "600.0/600.1 and selected801/803 fresh;802 timeout, ancillary vehicle/rental/UCC/TILA/creditor and all later/exact-application predicates remain unverified here.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C028 Saved research record

The statute’s specific offer is recipient-informed financing terms, including price or amount, binding on the provider if accepted, subject to stated specific requirements.

Recorded check status: fresh specific offer and change rules checked actual events held

Conditions, exceptions, and limits: The statute’s wording must be preserved; it does not itself establish that any communication was accepted or all conditions were fulfilled.
Provision-specific support: S001 §801(k).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_specific_offer_and_change_rules_checked_actual_events_held", "scope": "801/803 and complete600.1 offer/change/menu/default-specific exceptions checked; actual communication, price, acceptance and performance not established.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C029 Saved research record

The regulation defines a specific offer as a written recipient-informed communication combining a payment/financing amount with a rate, price, or cost.

Recorded check status: fresh specific offer and change rules checked actual events held

Conditions, exceptions, and limits: The communication must be binding if accepted. Name, address, or general interest alone is not the relevant recipient information. This is more detailed than the statute’s “price or amount” wording.
Provision-specific support: S009 §600.1(ai).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_specific_offer_and_change_rules_checked_actual_events_held", "scope": "801/803 and complete600.1 offer/change/menu/default-specific exceptions checked; actual communication, price, acceptance and performance not established.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C030 Saved research record

A covered provider supplies the prescribed sales-based disclosures when extending the specific offer.

Recorded check status: fresh specific offer and change rules checked actual events held

Conditions, exceptions, and limits: Ordinary advertisement/inquiry labels are not decisive; the actual statutory and regulatory offer predicates govern. No actual communication was examined.
Provision-specific support: S003 introduction; S009 §600.1(f)(1), §600.3(a).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_specific_offer_and_change_rules_checked_actual_events_held", "scope": "801/803 and complete600.1 offer/change/menu/default-specific exceptions checked; actual communication, price, acceptance and performance not established.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C031 Saved research record

Simultaneous offers and customizable menus have a selection rule.

Recorded check status: fresh specific offer and change rules checked actual events held

Conditions, exceptions, and limits: When the recipient selects from multiple qualifying options, disclosure timing is tied to selection; the provider need provide disclosures for the particular offer elected for pursuit. This does not authorize omitting disclosure for the selected offer.
Provision-specific support: S009 §600.1(f)(1), (4).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_specific_offer_and_change_rules_checked_actual_events_held", "scope": "801/803 and complete600.1 offer/change/menu/default-specific exceptions checked; actual communication, price, acceptance and performance not established.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C032 Saved research record

A written offer to change an already consummated financing requires disclosure before agreement if the changes increase finance charge or APR.

Recorded check status: fresh specific offer and change rules checked actual events held

Conditions, exceptions, and limits: The express exception is proposed terms resolving the recipient’s default. This clause is not a general exemption for every renewal, workout, or new financing.
Provision-specific support: S009 §600.1(f)(2).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_specific_offer_and_change_rules_checked_actual_events_held", "scope": "801/803 and complete600.1 offer/change/menu/default-specific exceptions checked; actual communication, price, acceptance and performance not established.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C033 Saved research record

A changing payoff amount already included in a disclosure does not, by itself, require a new disclosure before consummation.

Recorded check status: fresh specific offer and change rules checked actual events held

Conditions, exceptions, and limits: Section 600.5(n) is limited to that cause. The funding row must give the applicable warning about changing or unknown payoff deductions. Other changed terms must be evaluated separately.
Provision-specific support: S009 §600.5(n); §600.6(b)(3)(iii)–(iv).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_specific_offer_and_change_rules_checked_actual_events_held", "scope": "801/803 and complete600.1 offer/change/menu/default-specific exceptions checked; actual communication, price, acceptance and performance not established.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C034 Saved research record

A special draw-by-draw rule exists for certain retailer/supplier open-end financing.

Recorded check status: fresh specific offer and change rules checked actual events held

Conditions, exceptions, and limits: All three conditions are required: draw at purchase, variable rate/price depending on retailer/product, and election to use §600.10 instead of §600.11. This is a boundary exception, not a general sales-based funding rule.
Provision-specific support: S009 §600.1(f)(3)(i)–(iii).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_specific_offer_and_change_rules_checked_actual_events_held", "scope": "801/803 and complete600.1 offer/change/menu/default-specific exceptions checked; actual communication, price, acceptance and performance not established.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C035 Saved research record

The application-stage cost-metric restriction and the APR statement trigger are not identical.

Recorded check status: fresh rule APC context checked 810 statute failed unreopened

Conditions, exceptions, and limits: Nonannual metrics cannot be presented as a “rate” throughout the defined application process; the adopted rule ties the APR-alongside-rate/amount requirement to quotation of a specific offer and subsequent application communications.
Provision-specific support: S007 §810; S009 §600.1(f)(1), (n), §600.3(b); S012 response 9.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_rule_APC_context_checked_810_statute_failed_unreopened", "scope": "Application-stage and post-specific-offer APR triggers and separate document rules checked;810 statutory body failed once, no whole claim acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C036 Saved research record

Section 809 requires the recipient’s signature on required disclosures before authorization to proceed further with the transaction application.

Recorded check status: 809 statutory body failed unreopened adopted signature distinct

Conditions, exceptions, and limits: That statutory wording is not rewritten as “only at funding.” Electronic signature is expressly allowed.
Provision-specific support: S006 entire section.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "809_statutory_body_failed_unreopened_adopted_signature_distinct", "scope": "809 application-stage wording remains original attribution after timeout; fresh600.18 before-consummation implementation does not erase it.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C037 Saved research record

Section 600.18 requires the signature before consummation and, for a consummated transaction with multiple negotiating disclosures, only on the final corresponding disclosure.

Recorded check status: fresh signature acknowledgment delivery broker rules checked actual application held

Conditions, exceptions, and limits: It does not require signatures for transactions that are not consummated. This is the adopted implementation; the difference from §809’s application-stage wording remains visible.
Provision-specific support: S009 §600.18(a), (c).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_signature_acknowledgment_delivery_broker_rules_checked_actual_application_held", "scope": "Complete selected600.5/17/18/21 and801/803 checked; acknowledgment, contract acceptance, consummation, funding and role/authority remain separate.809 statutory body and broader contract law not fresh.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C038 Saved research record

An entity recipient’s disclosure may be signed by an authorized natural person who is not a broker.

Recorded check status: fresh signature acknowledgment delivery broker rules checked actual application held

Conditions, exceptions, and limits: Authority to sign is a factual predicate. Broker delivery or obtaining a signature does not make the broker the permissible recipient signatory.
Provision-specific support: S009 §600.18(a); S001 §801(i).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_signature_acknowledgment_delivery_broker_rules_checked_actual_application_held", "scope": "Complete selected600.5/17/18/21 and801/803 checked; acknowledgment, contract acceptance, consummation, funding and role/authority remain separate.809 statutory body and broader contract law not fresh.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C039 Saved research record

Electronic signatures may be used, including qualifying button/checkbox processes; electronically consummated transactions may use electronic or fax signatures.

Recorded check status: fresh electronic rule text checked ESRA conditions unreopened

Conditions, exceptions, and limits: The process must satisfy ESRA. Electronic disclosure/signature is allowed regardless of the later agreement’s delivery medium. No actual click, authority, intent, or authentication was established.
Provision-specific support: S009 §600.5(b), §600.18(a)–(b); S021 §302(3), §304; S022 §540.4(a)–(b).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_electronic_rule_text_checked_ESRA_conditions_unreopened", "scope": "600.5 and600.18 parsed signature/date stamp/retainable copy checked; current ESRA/ITS conditions, later exceptions and actual intent/authority remain original/unverified.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C040 Saved research record

The prescribed signature legend acknowledges receipt of information.

Recorded check status: fresh signature acknowledgment delivery broker rules checked actual application held

Conditions, exceptions, and limits: Its presence or a button labeled “Accept” does not, by itself, prove substantive contract acceptance, contract formation, satisfaction of offer conditions, or funding.
Provision-specific support: S009 §600.5(b), read with S001 §801(k) and S009 §600.18.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_signature_acknowledgment_delivery_broker_rules_checked_actual_application_held", "scope": "Complete selected600.5/17/18/21 and801/803 checked; acknowledgment, contract acceptance, consummation, funding and role/authority remain separate.809 statutory body and broader contract law not fresh.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C041 Saved research record

Electronic execution requires an automatic date stamp and a signed copy the recipient can retain indefinitely.

Recorded check status: fresh electronic rule text checked ESRA conditions unreopened

Conditions, exceptions, and limits: Merely sending a link does not establish fulfillment of these conditions. ESRA also requires the signature’s association with the record and intent to sign; statutory exceptions and voluntariness remain relevant.
Provision-specific support: S009 §600.5(j); S021 §§302, 307, 309; S022 §540.4(b).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_electronic_rule_text_checked_ESRA_conditions_unreopened", "scope": "600.5 and600.18 parsed signature/date stamp/retainable copy checked; current ESRA/ITS conditions, later exceptions and actual intent/authority remain original/unverified.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C042 Saved research record

Required disclosures are separate from contracts and other disclosure documents.

Recorded check status: fresh rule APC context checked 810 statute failed unreopened

Conditions, exceptions, and limits: They may travel in one package; electronic material may share an attachment/link if separated by page breaks. Additional voluntary financing information cannot simply be inserted into the required disclosure.
Provision-specific support: S009 §600.5(e); S007 §810.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_rule_APC_context_checked_810_statute_failed_unreopened", "scope": "Application-stage and post-specific-offer APR triggers and separate document rules checked;810 statutory body failed once, no whole claim acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C043 Saved research record

A required amount-financed itemization is a separate, immediately following document that need not be signed.

Recorded check status: fresh signature acknowledgment delivery broker rules checked actual application held

Conditions, exceptions, and limits: Its trigger is amount financed greater than recipient funds. The unsigned exception does not eliminate the main disclosure’s signature requirements.
Provision-specific support: S009 §600.17(a), (c)(1)–(4).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_signature_acknowledgment_delivery_broker_rules_checked_actual_application_held", "scope": "Complete selected600.5/17/18/21 and801/803 checked; acknowledgment, contract acceptance, consummation, funding and role/authority remain separate.809 statutory body and broader contract law not fresh.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C044 Saved research record

A broker receiving the financer’s disclosures must transmit them unaltered before communicating the specific offer and return transmission evidence, including time.

Recorded check status: fresh signature acknowledgment delivery broker rules checked actual application held

Conditions, exceptions, and limits: Alternatively, the broker may obtain confirmation that the financer supplied the disclosures directly. Delivery obligations remain distinct from signature and contract acceptance.
Provision-specific support: S009 §600.21(b)–(c).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_signature_acknowledgment_delivery_broker_rules_checked_actual_application_held", "scope": "Complete selected600.5/17/18/21 and801/803 checked; acknowledgment, contract acceptance, consummation, funding and role/authority remain separate.809 statutory body and broader contract law not fresh.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C045 Saved research record

A financer giving a broker a specific offer must supply compliant disclosures and establish reasonable procedures for timely recipient delivery.

Recorded check status: fresh signature acknowledgment delivery broker rules checked actual application held

Conditions, exceptions, and limits: Direct delivery to the recipient is an alternative under §600.21(e). The listed contractual, investigation, and discontinuation procedures are examples of reasonable procedures, not an assertion that every example is invariably mandatory.
Provision-specific support: S009 §600.21(a), (e).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_signature_acknowledgment_delivery_broker_rules_checked_actual_application_held", "scope": "Complete selected600.5/17/18/21 and801/803 checked; acknowledgment, contract acceptance, consummation, funding and role/authority remain separate.809 statutory body and broader contract law not fresh.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C046 Saved research record

The adopted text requires retention of specified disclosure and transmission records for at least four years.

Recorded check status: fresh operative and APC wording distinguished

Conditions, exceptions, and limits: Financer transmission-evidence retention runs from presentation to the recipient; §600.21(d) separately requires a provider to retain generated disclosures from presentation to recipient or provision to broker. The APC’s statement that retention applies only to financers is narrower and is not used to erase the adopted wording.
Provision-specific support: S009 §600.21(a)(2), (d); S012 response 5.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_operative_and_APC_wording_distinguished", "scope": "Entire agency explanation compared with600.21; provider/financer retention tension and general compensation writing preserved; no operative rewrite.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C047 Saved research record

When a broker is involved, the provider must explain in writing how and by whom the broker will be compensated.

Recorded check status: fresh operative and APC wording distinguished

Conditions, exceptions, and limits: The final rule does not prescribe a dedicated broker-compensation row or fixed form for that explanation. That does not eliminate separately applicable finance-charge/itemization treatment.
Provision-specific support: S009 §600.21(f); S012 response 5.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_operative_and_APC_wording_distinguished", "scope": "Entire agency explanation compared with600.21; provider/financer retention tension and general compensation writing preserved; no operative rewrite.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C048 Saved research record

Section 600.21 does not require a broker to evaluate the financer’s disclosure accuracy or create broker liability for the financer’s noncompliant disclosure.

Recorded check status: fresh signature acknowledgment delivery broker rules checked actual application held

Conditions, exceptions, and limits: It does not limit liability arising from the broker’s own representations. No actual liability conclusion is made.
Provision-specific support: S009 §600.21(g)(1)–(3).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_signature_acknowledgment_delivery_broker_rules_checked_actual_application_held", "scope": "Complete selected600.5/17/18/21 and801/803 checked; acknowledgment, contract acceptance, consummation, funding and role/authority remain separate.809 statutory body and broader contract law not fresh.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C049 Saved research record

Delivery, receipt, signed acknowledgment, offer acceptance, consummation, and funding are separate analytical events.

Recorded check status: fresh signature acknowledgment delivery broker rules checked actual application held

Conditions, exceptions, and limits: The selected texts impose event-specific duties but do not provide evidence that any event occurred. No universal waiting period, actual funding deadline, or actual contract-formation result is established here.
Provision-specific support: S001 §801(h), (k); S003 introduction; S006; S009 §§600.5, 600.18, 600.21.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_signature_acknowledgment_delivery_broker_rules_checked_actual_application_held", "scope": "Complete selected600.5/17/18/21 and801/803 checked; acknowledgment, contract acceptance, consummation, funding and role/authority remain separate.809 statutory body and broader contract law not fresh.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C050 Saved research record

For sales-based financing, amount financed is funds provided to the recipient or on the recipient’s behalf, less prepaid finance charge.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: It is not necessarily cash deposited directly to the recipient. A prepaid finance charge includes qualifying separately paid charges before/at consummation or charges withheld from proceeds.
Provision-specific support: S009 §600.1(a)(1), (ac).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C051 Saved research record

Recipient funds are the net funds provided directly to the recipient.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: They exclude third-party payments, including broker payments, and known payoffs/paydowns. For changing obligations, the provider may use the balance at disclosure. Actual later funding may therefore differ.
Provision-specific support: S009 §600.1(af).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C052 Saved research record

Finance charge is the dollar cost of financing and imports Regulation Z’s charge rules on an as-if consumer-credit/creditor basis.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: A non-factoring receivables-purchase discount is also included. Importing that calculation does not determine that TILA actually applies or that the transaction is legally a loan.
Provision-specific support: S001 §801(e); S009 §600.2(a)(1)–(2); S023; S026 §1602(g).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C053 Saved research record

Finance-charge treatment depends on the charge’s function and conditions, not its label alone.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: Regulation Z generally includes incident-to/condition-of-credit charges, with rules for third-party charges and specified exceptions. Cash-comparable charges, application fees charged to all applicants, and actual unanticipated late/default charges have distinct rules.
Provision-specific support: S023 §1026.4(a), (b), (c)(1)–(2).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C054 Saved research record

Insurance, debt-cancellation, security-related official fees, and similar exclusions are conditional.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: For example, voluntary credit-insurance/debt-cancellation exclusions require the specified disclosures and affirmative request; property-insurance and itemized security-fee exclusions have their own conditions. No particular fee was classified.
Provision-specific support: S023 §1026.4(d)–(f), with complete surrounding conditions read.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C055 Saved research record

Part 600 prevents double counting and excludes avoidable charges not imposed incident to credit.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: “Avoidable” alone is not a universal exclusion. For benchmark-plus-margin charges that cannot be known in advance, the rule uses the benchmark at disclosure plus the margin for unknown future periods.
Provision-specific support: S009 §600.2(b)–(d); §600.5(l).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C056 Saved research record

APR measures financing cost annually using both the amounts and timing of value received and payments made, including finance charges.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: Section 600.3 permits the actuarial or United States Rule method; §803 requires an estimate based on the prescribed sales/payment/term projection. It does not authorize substituting a factor or dollar charge for APR.
Provision-specific support: S003 §803(c); S009 §600.3(a)–(c); S024 §1026.22(a)(1).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C057 Saved research record

The actuarial and U.S. Rule methods differ in treatment of unpaid accrued finance charges.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: The official interpretation explains capitalization under the actuarial method and separate accumulation under the U.S. Rule. These are calculation conventions, not conclusions about lawful interest or permissible contractual capitalization.
Provision-specific support: S024 official interpretations 22(a)(1)-1 through -3.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C058 Saved research record

Appendix J’s annualization depends on a correctly determined unit period and payment timing.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: The text read specifies nominal annualization and unit-period conventions; daily, weekly, monthly, and semimonthly periods have distinct annual units. Its month-fraction convention is not the same as Part 600’s optional 30.4-day monthly-cost conversion. No numerical solver was run.
Provision-specific support: S025 Appendix J(a), (b)(1)–(6); S009 §600.1(h), (p).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C059 Saved research record

A sales split percentage, a financing factor, an annual interest rate, APR, finance charge, and total payment answer different questions.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: Part 600 defines the split percentage for payment/true-up calculations. It does not supply a universal factor formula or denominator. Section 810 restricts presenting nonannual cost metrics as a “rate” and using “interest” for nonannual percentages.
Provision-specific support: S007; S009 §600.1(u), (ak), §600.3.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C060 Saved research record

Multiple-payment-option disclosures use the minimum contractually permitted payments; demand balances have a prescribed assumed-term rule.

Recorded check status: fresh state cost definitions checked imported federal method and images held

Conditions, exceptions, and limits: Demand uses one year unless faster repayment is reasonably anticipated; an alternate maturity stated in the legal obligation controls. No such contractual option or demand obligation is assumed to exist.
Provision-specific support: S009 §600.20(a)–(b).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_state_cost_definitions_checked_imported_federal_method_and_images_held", "scope": "Complete selected state definitions/finance-charge/APR text checked, with distinct amount, cash and monthly cost units; incorporated TILA bodies/comments/AppendixJ solver and pixels unreopened.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C061 Saved research record

The sales-based format is a prescribed ten-row, three-column table, subject to its express additional-row rule.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: It applies to §600.6 transactions; sales-based asset-based lending is excluded from this format. Some cells are merged as prescribed. This report is not a completed disclosure form.
Provision-specific support: S009 §600.6 introduction, (a)–(m).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C062 Saved research record

The funding row gives amount financed and, when lower, net recipient funds with the required itemization reference.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: It also requires applicable explanations of changing known payoffs, unknown mandatory third-party payoffs, and same-provider renewal charges.
Provision-specific support: S003 §803(a); S009 §600.6(b).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C063 Saved research record

The APR row explains annualized estimated cost and identifies the assumed monthly income through the relevant payment channel/mechanism.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: It warns that actual income and effective APR may vary. If no finance-charge component is interest-based, the additional prescribed explanation distinguishes APR from an interest rate.
Provision-specific support: S009 §600.6(c)(1)–(4).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C064 Saved research record

The finance-charge row states dollar financing cost.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: A statement that the charge will not increase with longer repayment is optional only when it will not increase under any circumstance if repayment takes longer than estimated.
Provision-specific support: S003 §803(b); S009 §600.6(d).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C065 Saved research record

The total-payment row states total estimated contractual payments.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: Section 803(d) separately defines total repayment as disbursement plus finance charge. The different amount concepts must not be silently equated without tracing deductions and charges.
Provision-specific support: S003 §803(d); S009 §600.6(e).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C066 Saved research record

The payment row includes average estimated periodic payment/frequency, irregular payment dates/amounts, and reasonably anticipated true-up dates/amounts.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: A short explanation is required when necessary to explain why estimated payments differ from actual obligations.
Provision-specific support: S003 §803(f); S009 §600.6(f).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C067 Saved research record

The payment-terms row explains daily-payment days, applicable sales-split operation, and true-up mechanics.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: If a true-up exists, it must explain the preset-payment derivation, mechanism and available contract reference, and minimum payments. A no-minimum/no-fixed-schedule statement is conditional on the actual terms.
Provision-specific support: S009 §600.6(g).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C068 Saved research record

The term row gives estimated duration and explains the income assumptions underlying it.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: The estimate is the time for projected periodic payments to reach required repayment; it is not necessarily an unconditional maturity or prediction of actual payoff.
Provision-specific support: S003 §803(e); S009 §600.6(h), §600.1(al)(4).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C069 Saved research record

The first prepayment row states whether finance charges beyond accrued unpaid interest remain payable and the maximum noninterest amount.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: The negative statement applies only when the contrary condition does not occur at any time during the term. Statutory percentage disclosure remains separately relevant under C074.
Provision-specific support: S003 §803(h)(i); S009 §600.1(y)(1), §600.6(i)–(j).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C070 Saved research record

The second prepayment row states additional prepayment fees outside finance charge or gives the prescribed negative answer.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: It must address fees applicable at any time during the term, not merely on the offer date.
Provision-specific support: S003 §803(h)(ii); S009 §600.6(k).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C071 Saved research record

The collateral row describes collateral requirements or security interests, if any.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: Disclosure of a security provision does not establish its attachment, validity, perfection, priority, or enforceability.
Provision-specific support: S003 §803(i); S009 §600.6(l).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C072 Saved research record

Nonmonthly periodic payments require an additional estimated-monthly-cost row immediately after the total-payment row.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: If estimated monthly cost varies, the row lists the estimates and applicable periods and explains the calculation. Monthly cost includes projected payments; it is not merely monthly fees.
Provision-specific support: S009 §600.1(p), §600.6(m).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C073 Saved research record

Section 803(g) requires a description of all other potential fees/charges outside finance charge, including draw, late, and returned-payment fees.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: Section 600.6 does not expressly allocate a general other-fees row. That layout gap does not establish permission to omit the statutory disclosure. Placement remains unresolved on the retrieved materials.
Provision-specific support: S003 §803(g), compared with S009 §600.6(a)–(m).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C074 Saved research record

Section 803(h)(i) requires both the percentage of unpaid finance charge retained on early payoff/refinance and the maximum dollar amount.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: Section 600.6(j) expressly supplies a maximum-dollar statement but does not separately spell out the statutory percentage field. This is a preserved statute/layout gap.
Provision-specific support: S003 §803(h)(i), compared with S009 §600.6(j).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C075 Saved research record

Required same-provider payoff as a condition of renewal triggers §808’s renewal disclosures.

Recorded check status: fresh renewal trigger and distinct formula bases checked not resolved

Conditions, exceptions, and limits: For fixed total repayment, the statute specifies its own prepayment-charge calculation and requires disclosure of actual disbursement reduction. No actual renewal or numerical charge is inferred.
Provision-specific support: S005 §808 introduction, (a)–(b).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_renewal_trigger_and_distinct_formula_bases_checked_not_resolved", "scope": "808 payoff/total repayment/forgiveness formula and600.6 original-amount-financed/already-repaid fraction differ as reported; no numerical reconciliation or actual charge.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C076 Saved research record

The adopted renewal-row calculation does not use the same stated base as §808(a).

Recorded check status: fresh renewal trigger and distinct formula bases checked not resolved

Conditions, exceptions, and limits: Section 600.6(b)(3)(v) refers to a pro rata fee based on the fraction of original amount financed already repaid; §808(a) uses renewal payoff as a fraction of original total repayment, less forgiveness. These are not silently reconciled or numerically implemented here.
Provision-specific support: S005 §808(a); S009 §600.6(b)(3)(v).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_renewal_trigger_and_distinct_formula_bases_checked_not_resolved", "scope": "808 payoff/total repayment/forgiveness formula and600.6 original-amount-financed/already-repaid fraction differ as reported; no numerical reconciliation or actual charge.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C077 Saved research record

When amount financed exceeds recipient funds, a separate itemization must be substantially similar to the rule’s example and contain the listed minimum components.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: Components include direct funds, applicable credit to the recipient’s existing obligation, third-party disbursements, their sum, prepaid finance charges/purpose, and amount financed. The rule permits generic descriptions for specified payee categories. No account number, payee, or transaction value was entered.
Provision-specific support: S009 §600.17(a)–(c).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C078 Saved research record

Formatting requirements include a prominent summary heading, prescribed signature legend where applicable, numerical presentation, term units, APR rounding, font/column rules, outlined cells, and short-explanation limits.

Recorded check status: fresh complete selected sales based rows format and 803 checked placement holds

Conditions, exceptions, and limits: Term ≤1 year is in days from the day after consummation through final payment; longer terms use years/months with remaining-day month fractions to two decimals. APR is to two decimals; no fractional-cent dollar display. Fonts, 3:3:7 column safe format, and ≤60-word short explanations have their stated conditions and permitted accessibility/medium deviations.
Provision-specific support: S009 §600.5(a)–(j), (m), (o)–(p).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_selected_sales_based_rows_format_and_803_checked_placement_holds", "scope": "Full600.5/600.6,803 and600.17 parsed conditions checked; statutory other-fee and prepayment percentage placement gaps remain unresolved. No model-form or pixel/actual compliance acceptance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C079 Saved research record

Section 803 permits historical or opt-in sales projections and requires notice to the superintendent of the method intended across sales-based offerings.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: The retrieved statutory text establishes the notice obligation; a separate current public election form, channel, or filing instruction was not retrieved. No filing or actual election is inferred.
Provision-specific support: S003 §803(c); S028 search bound.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C080 Saved research record

The historical projection averages receipts through the relevant payment channel plus other-channel receipts that the contract would previously have required to be redirected there.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: It is not automatically total business revenue, bank deposits, or a hand-selected gross-sales figure. “Average” means arithmetic mean unless otherwise stated.
Provision-specific support: S009 §600.1(g), (z); §600.8(b)(1).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C081 Saved research record

The ordinary regulatory historical window is fixed at four to twelve months, either preceding the offer or the same number of highest-volume months in the preceding twelve months.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: The rule permits fixing the period for all transactions or by recipient industry, financing amount, or both. The statute’s outer wording is one to twelve months; both texts are preserved. Exceptions below prevent treating four observed months as an unconditional minimum dataset.
Provision-specific support: S003 §803(c)(i); S009 §600.8(b)(2).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C082 Saved research record

For a business operating less than twelve months, the provider may average the months of operation.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: No minimum operating history, actual business age, or actual sales data is invented. A zero-data calculation is not supplied.
Provision-specific support: S009 §600.8(b)(3).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C083 Saved research record

Historical averaging permits specified exclusions.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: They are: a below-average month with a provider-determined cause unlikely to recur; a month lacking requested documentation; and oldest beginning months for which documentation is neither required nor received. Declining the nonrecurring-event exclusion carries the stated no-liability provision.
Provision-specific support: S009 §600.8(b)(4)(i)–(iii).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C084 Saved research record

Additional documented months may be included on an all-or-none basis, excluding nonoperating months.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: This is not authority to select only favorable additional documented months. It operates in addition to the fixed-period rules.
Provision-specific support: S009 §600.8(b)(5).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C085 Saved research record

The fixed-period decision must be recorded with its effective date, versioned when changed, and retained while effective and for four years afterward.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: This is a provider’s required internal record, not a record obtained or invented in this investigation. The adopted text’s cross-reference problem is recorded in C103.
Provision-specific support: S009 §600.8(b)(6).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C086 Saved research record

Additional assumptions under either sales-projection method must use the best reasonably available information, identify estimates, and explain assumptions.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: The general §600.5(k) estimate clause expressly excludes sales-based financing; its sales-based counterparts are §600.8(c) and §600.9(k).
Provision-specific support: S009 §§600.5(k), 600.8(c), 600.9(k).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C087 Saved research record

A true-up can be a payment to the recipient, a charge, or an adjustment of periodic payments.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: For sales-based financing, the mechanism involves preset payments and a contract permitting recipient-requested or financer-initiated adjustment so total payment more closely reflects the contractual split percentage. It is not defined solely as a refund.
Provision-specific support: S009 §600.1(an), (ap)(1).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C088 Saved research record

Reasonably anticipated true-ups require a reasonable basis informed by similar-contract performance and financer policies/procedures.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: A printed reconciliation provision alone does not prove that a refund will occur, an adjustment was requested or granted, or reconciliation works effectively in practice.
Provision-specific support: S009 §600.1(ao).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C089 Saved research record

Estimated payments and anticipated true-ups must account for specified payments, changing split percentages, minimums, contractual shortfall-threshold payments, and reasonably anticipated finance charges.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: The threshold-payment item excludes default fees. No payment schedule or provider policy is assumed.
Provision-specific support: S009 §600.7(a)(1)–(5).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C090 Saved research record

Estimated monthly cost, finance charge, term, and APR use the selected projection and account for those payment features plus reasonably anticipated true-ups.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: A preset debit cannot simply be treated as the final actual payment stream if the rule requires anticipated adjustments. The retrieved §600.7 internal-projection cross-reference is defective; see C103.
Provision-specific support: S009 §600.7(b)(1)–(6).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C091 Saved research record

Opt-in projections use the provider’s internal estimate for the contract’s particular payment channel, based on best reasonably available information.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: Opt-in is subject to the audit/reporting process; it is not unrestricted discretion to select an attractive APR.
Provision-specific support: S003 §803(c)(ii); S009 §600.9(a)–(d).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C092 Saved research record

Every twelve months, an opt-in provider audits sales-based financings paid off in the preceding twelve months using internal estimates, including contractual true-ups.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: The cohort excludes transactions with specified court/arbitration action, stopped collection after determined breach, or agreed contract modification. These are generic cohort rules; no case or collection record was queried.
Provision-specific support: S009 §600.9(e)(1)–(3).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C093 Saved research record

Retrospective APR ordinarily uses the fully repaid contract’s known payment/fee dates and amounts.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: For the audit, the provider may disregard an early payoff lump sum and assume continued periodic payments averaging past periodic payments. Consequently, an audit retrospective APR can incorporate this permitted counterfactual rather than literal realized cash flows.
Provision-specific support: S009 §600.1(ag); §600.9(f).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C094 Saved research record

Audit APR spread is the relative difference between retrospective and disclosed APR; each audit’s measure is the median spread.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: The denominator is disclosed APR, not a percentage-point comparison. No zero-denominator convention is supplied by the selected text.
Provision-specific support: S009 §600.9(g)–(h).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C095 Saved research record

The rule weights annual audited median spreads by transaction count over the last three, five, and seven audits.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: Calculations are required only after enough audits exist. Thresholds are greater than 15%, 10%, and 5%, respectively. The clauses direct use of the historical method for 24 months unless the provider determines historical treatment would have yielded a higher weighted average.
Provision-specific support: S009 §600.9(i)(1)–(3).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C096 Saved research record

Returning to opt-in after that 24-month period requires a good-faith effort to improve the internal projection method’s accuracy.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: Passage of time alone does not satisfy the stated reentry condition. No provider history is assumed.
Provision-specific support: S009 §600.9(j).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C097 Saved research record

The annual opt-in report is due on or before April 30, beginning in 2025, for a provider that used opt-in during the preceding calendar year.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: It is subscribed and affirmed under penalties of perjury and covers the preceding calendar year. This establishes a generic recurring rule, not an actual filer or overdue filing.
Provision-specific support: S009 §600.22(a).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C098 Saved research record

Reporting includes disclosed estimated and completed-transaction retrospective APRs, annual mean differences weighted by financing amount and unweighted, unusual circumstances, and additional prescribed information.

Recorded check status: fresh complete projection history audit reporting checked actual method and cost held

Conditions, exceptions, and limits: These reporting means and financing-amount weights differ from §600.9’s medians and transaction-count weights. The superintendent may request additional material and special reports. No reporting template or submission was used.
Provision-specific support: S009 §600.22(b)–(d).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_projection_history_audit_reporting_checked_actual_method_and_cost_held", "scope": "Complete600.7–9/22 and803 checked: exclusions, historic windows, optional adjustments, relative spread, medians/count weights versus annual means/amount weights, strict thresholds and reports; no actual compliance.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C099 Saved research record

Part 600 supplies alternative APR accuracy tolerances.

Recorded check status: fresh complete tolerance cure overstatement rules checked all conditions held

Conditions, exceptions, and limits: Ordinary tolerance is ±0.125 percentage point; qualifying irregular transactions receive ±0.25 percentage point; a separate relative-percentage test uses the rule’s stated formula and 2.5% threshold. These are disclosure tolerances, not maximum lawful charges.
Provision-specific support: S009 §600.4(a)(1)–(3).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_tolerance_cure_overstatement_rules_checked_all_conditions_held", "scope": "600.4 complete alternatives, relative formula,60-day discovery/pre-action notice-adjustment and listed inadvertent-overstatement treatment checked; no pricing cap or actual immunity.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C100 Saved research record

The bona fide disclosure-error provision requires discovery through the provider’s/financer’s procedures, timely notice, and adjustment.

Recorded check status: fresh complete tolerance cure overstatement rules checked all conditions held

Conditions, exceptions, and limits: Within 60 days after discovery and before an action for that error, the financer/assignee must notify and adjust so charges do not exceed the lower of disclosed finance charge or the dollar equivalent of disclosed APR. No actual cure or immunity is found.
Provision-specific support: S009 §600.4(b).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_tolerance_cure_overstatement_rules_checked_all_conditions_held", "scope": "600.4 complete alternatives, relative formula,60-day discovery/pre-action notice-adjustment and listed inadvertent-overstatement treatment checked; no pricing cap or actual immunity.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C101 Saved research record

Section 600.4 separately addresses inadvertent overstatement of enumerated disclosure amounts.

Recorded check status: fresh complete tolerance cure overstatement rules checked all conditions held

Conditions, exceptions, and limits: It covers the listed finance charge, APR, payments, monthly cost, maximum noninterest charge, and prepayment amounts. It is not a blanket exemption from the disclosure law or other law.
Provision-specific support: S009 §600.4(c).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_complete_tolerance_cure_overstatement_rules_checked_all_conditions_held", "scope": "600.4 complete alternatives, relative formula,60-day discovery/pre-action notice-adjustment and listed inadvertent-overstatement treatment checked; no pricing cap or actual immunity.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C102 Saved research record

The retrieved adopted §600.5(b) names ESRA but cites State Technology Law §§103–109; current ESRA is Article 3, §§301–309.

Recorded check status: fresh literal ESRA citation mismatch confirmed actual current crossrefs held

Consequence and limit: The relevant current signature/record provisions were read directly. The erroneous-looking citation is not silently treated as correct, and no actual signature is validated.
Support: S009 §600.5(b); S021; S022.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_literal_ESRA_citation_mismatch_confirmed_actual_current_crossrefs_held", "scope": "Adopted text cites103–109 while naming ESRA; current Article3/ITS source bodies not reopened here; no signature validity or official correction finding.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C103 Saved research record

Other internal references in the retrieved adopted text do not align with their apparent targets.

Recorded check status: fresh parsed internal reference mismatches checked pixels and legal effect held

Consequence and limit: Examples: §600.7 refers to nonexistent §600.9(a)(3); §600.8(b)(6) points to §600.6 for its decision record; §600.5(f)(3)–(4) points to font provisions under subdivision (g), although fonts are under (f); §600.17(a)(6)’s illustrative item-number subtraction does not track its preceding list. These are parsed-text observations, not pixel-confirmed printing defects or judicial invalidity findings.
Support: S009 §§600.5(f), 600.7, 600.8(b)(6), 600.17(a)(6).

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "fresh_parsed_internal_reference_mismatches_checked_pixels_and_legal_effect_held", "scope": "Complete selected projection/history/font/itemization text preserves the reported mismatched references; not pixel-confirmed printing defects or judicial invalidity.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C104 Saved research record

No standalone official FAQ/model/reporting-instruction package was retrieved in the bounded official searches.

Recorded check status: guidance search original attribution nonexistence not inferred

Consequence and limit: No assertion is made that none exists. The mandatory rules and embedded examples were examined directly.
Support: S013, S028; failure log.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "guidance_search_original_attribution_nonexistence_not_inferred", "scope": "No fresh FAQ/model/election/reporting instructions search; original bounded retrieval absence not nonexistence.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C105 Saved research record

No PDF pixel inspection was successfully completed.

Recorded check status: pixel and full numerical method holds retained

Consequence and limit: Screenshot attempts for Part 600 indexes 17, 18, 46, and 47 returned placeholders without inspectable image content. No claim of seeing scanned signatures, visual form layout, typography, or image-based federal equations is made.
Support: S009, S025; retrieval log.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "pixel_and_full_numerical_method_holds_retained", "scope": "Only parsed text; original screenshots failed and no pixels or AppendixJ images/solver inspected.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C106 Saved research record

The full later regulatory/session-law/judicial history is unresolved.

Recorded check status: later currentness history holds retained

Consequence and limit: No finding that the law has never been amended, stayed, vacated, or otherwise affected is made. A historical agency transition-letter source was not recovered from an official publisher and was not substituted with a private reproduction.
Support: S013–S016, S027–S029.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "later_currentness_history_holds_retained", "scope": "Readable adopted2023PDF and dated statutory page headers do not establish complete later legal history/current compiled text.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

R028-P1-C107 Saved research record

No actual compliance, exemption, contractual, funding, collection, or legal-validity result follows from this investigation.

Recorded check status: all actual application and parent holds retained

Consequence and limit: Every parent fact and every unaddressed jurisdiction/product/enforcement dimension remains held. No court opinion or federal-preemption ruling was needed to state the selected published disclosure propositions.
Support: Scope restriction; C008 and the conditional claims above.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "atomic_reconciliation": "[internal evidence reference]", "disposition": "all_actual_application_and_parent_holds_retained", "scope": "No actual compliance/exemption/contract/funding/collection/validity finding or parent acceptance; all jurisdictions/products/remedies held.", "all_original_limits_retained": true, "entire_claim_currentness_or_actual_application_accepted": false}

Sources, pinpoints and access limits

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

Search this report’s sources

R028-P1-S001 Saved research record

New York State Senate, Financial Services Law §801, Definitions. https://www.nysenate.gov/legislation/laws/FIS/801

Recorded check status: fresh complete 801 definitions checked

Exact substantive read extent: Entire §801(a)–(k), including all purpose-reliance language and role, product, finance-charge, and offer definitions.
Jurisdiction, version, status, limits: New York; current official statutory page, revision metadata 2022-01-07. Entire selected section read. NYSenate.gov
Direct source URLs: https://www.nysenate.gov/legislation/laws/FIS/801
https://www.nysenate.gov/legislation/laws/FIS/801?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_801_definitions_checked", "scope": "Entire selected801(a)–(k) operative wording and page metadata; no actual purpose, roles or license classification.", "selected_evidence_keys": ["801_complete_definitions"], "all_original_limits_retained": true}

R028-P1-S002 Saved research record

New York State Senate, §802, Exemptions. https://www.nysenate.gov/legislation/laws/FIS/802

Recorded check status: fresh literal timeout original 802 unreopened

Exact substantive read extent: Entire introductory clause and exemptions (a)–(h).
Jurisdiction, version, status, limits: New York; current statutory body, same revision metadata. Every listed exemption read; no actual exempt status established. NYSenate.gov
Direct source URLs: https://www.nysenate.gov/legislation/laws/FIS/802
https://www.nysenate.gov/legislation/laws/FIS/802?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_literal_timeout_original_802_unreopened", "scope": "Original eight exemption statutory bodies remain attributed; final-adopted600.0 text separately checked, no statutory recovery. ", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S003 Saved research record

New York State Senate, §803, Sales-based financing disclosure requirements. https://www.nysenate.gov/legislation/laws/FIS/803

Recorded check status: fresh complete 803 sales based disclosure checked

Exact substantive read extent: Entire introduction and (a)–(i), including complete (c)(i)–(ii), (f)(i)–(ii), and (h)(i)–(ii).
Jurisdiction, version, status, limits: New York; current statutory body. This is the principal sales-based disclosure statute. NYSenate.gov
Direct source URLs: https://www.nysenate.gov/legislation/laws/FIS/803
https://www.nysenate.gov/legislation/laws/FIS/803?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_803_sales_based_disclosure_checked", "scope": "Entire803 disclosure items, method predicates and fee/prepayment requirements; no actual offer, projection, method election or complete later history.", "selected_evidence_keys": ["803_complete_sales_based_disclosure_statute"], "all_original_limits_retained": true}

R028-P1-S004 Saved research record

New York State Senate, §807, Other forms of financing disclosure requirements. https://www.nysenate.gov/legislation/laws/FIS/807

Recorded check status: original attribution unreopened all limits retained

Exact substantive read extent: Entire introduction and (a)–(i).
Jurisdiction, version, status, limits: New York; read to establish the residual-category boundary and regulatory authority. Other-product implementation remains held. NYSenate.gov
Direct source URLs: https://www.nysenate.gov/legislation/laws/FIS/807
https://www.nysenate.gov/legislation/laws/FIS/807?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S005 Saved research record

New York State Senate, §808, Disclosure requirements for renewal financing. https://www.nysenate.gov/legislation/laws/FIS/808

Recorded check status: fresh complete 808 renewal checked

Exact substantive read extent: Entire conditional introduction and (a)–(b), including the fixed-repayment prepayment-charge formula.
Jurisdiction, version, status, limits: New York; current statutory body. No renewal transaction assumed. NYSenate.gov
Direct source URLs: https://www.nysenate.gov/legislation/laws/FIS/808
https://www.nysenate.gov/legislation/laws/FIS/808?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_808_renewal_checked", "scope": "Complete statute renewal trigger and its stated fraction/forgiveness/disbursement inputs; regulation differs, no resolution.", "selected_evidence_keys": ["808_complete_renewal_statute"], "all_original_limits_retained": true}

R028-P1-S006 Saved research record

New York State Senate, §809, Required signature. https://www.nysenate.gov/legislation/laws/FIS/809

Recorded check status: fresh literal timeout original 809 unreopened

Exact substantive read extent: Entire section.
Jurisdiction, version, status, limits: New York; current statutory body. Wording is preserved separately from the regulation’s consummation rule. NYSenate.gov
Direct source URLs: https://www.nysenate.gov/legislation/laws/FIS/809
https://www.nysenate.gov/legislation/laws/FIS/809?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_literal_timeout_original_809_unreopened", "scope": "Original application-stage statutory signature wording remains attributed; adopted600.18 is separately fresh, not a current statutory substitute.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S007 Saved research record

New York State Senate, §810, Additional information. https://www.nysenate.gov/legislation/laws/FIS/810

Recorded check status: fresh literal timeout original 810 unreopened

Exact substantive read extent: Entire section, including separation of additional information, restrictions on “rate” and “interest,” and APR statements during an application.
Jurisdiction, version, status, limits: New York; current statutory body. NYSenate.gov
Direct source URLs: https://www.nysenate.gov/legislation/laws/FIS/810
https://www.nysenate.gov/legislation/laws/FIS/810?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_literal_timeout_original_810_unreopened", "scope": "Original metric/separate-information statutory wording attributed; rule/APC selected context fresh, no complete statute recovery.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S008 Saved research record

New York State Senate, §811, Rules and regulations; Article 8 index. https://www.nysenate.gov/legislation/laws/FIS/811; https://www.nysenate.gov/legislation/laws/FIS/A8

Recorded check status: original attribution unreopened all limits retained

Exact substantive read extent: Entire §811 introduction and (a)–(d); Article 8 section index.
Jurisdiction, version, status, limits: New York. Article 8 includes §§801–812. §§804–806 were not substantively investigated; §812 remedies remain held. NYSenate.gov +1
Direct source URLs: https://www.nysenate.gov/legislation/laws/FIS/811
https://www.nysenate.gov/legislation/laws/FIS/A8
https://www.nysenate.gov/legislation/laws/FIS/811?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/FIS/A8?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S009 Saved research record

NYDFS, Disclosure Requirements for Certain Providers of Commercial Financing Transactions, final-adopted 23 NYCRR Part 600. https://www.dfs.ny.gov/system/files/documents/2023/01/rf_finservices_23nycrr600_text.pdf. Agency-linked alias: https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_text

Recorded check status: fresh complete selected final adopted sections parsed currentness pixels held

Exact read extent and pages: Complete selected sections listed in the next table. PDF has 53 pages: numbered text pp. 1–52, followed by unnumbered certification at index 52.
Version, effectiveness, status, limits: New York; final-adopted text certified January 12, 2023; effective on publication of adoption notice. Final publication/effective date verified through S010. Parsed text read; no successful pixel inspection. Current-compilation gap S027 remains. dfs.ny.gov +1
Direct source URLs: https://www.dfs.ny.gov/system/files/documents/2023/01/rf_finservices_23nycrr600_text.pdf
https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_text
https://www.dfs.ny.gov/system/files/documents/2023/01/rf_finservices_23nycrr600_text.pdf?utm_source=chatgpt.com
https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_text?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_selected_final_adopted_sections_parsed_currentness_pixels_held", "scope": "Selected600.0–9 and600.17–25 complete parsed line unions; not current compiled Part600, other-product rules or pixels.", "selected_evidence_keys": ["Part600_0_1_2_and_start3", "Part600_3_4_complete", "format_signature_legend_start", "format_signature_term_rounding_fonts", "format_columns_words_electronic_copy_estimates_rounding", "6006_scope_and_funding_renewal_APR_rows", "6006_APR_financecharge_payment_terms", "6006_prepayment_collateral_monthly_cost", "6007_start", "6007_complete_tail_6008_history_start", "6008_history_tail_6009_header", "6009_projection_audit_spread_median_count_weights", "6009_threshold_tail", "6009_reentry_assumptions", "60017_itemization_start", "60017_examples_text_and_60018_signature_60019_thresholds", "60020_minimum_payment_60021_complete_broker_duties", "60022_reporting_start", "60022_tail_60023_assignment_60024_nexus_60025_dates_certification"], "all_original_limits_retained": true}

R028-P1-S010 Saved research record

NY Department of State, New York State Register, February 1, 2023, Vol. XLV, Issue 5, Part 600 Notice of Adoption. https://dos.ny.gov/system/files/documents/2023/02/020123.pdf

Recorded check status: fresh selected adoption notice checked

Exact read extent and pages: Notice identification, filing/effective dates, action, authority, complete section-by-section adoption summary, comparison with prior publication, and beginning of comment assessment. Printed pp. 1–2; PDF indexes 6–7. The separate complete assessment was read through S012.
Version, effectiveness, status, limits: Historical official adoption publication. Filing January 12, 2023; effective February 1, 2023. The entire 88-page Register was not read. dos.ny.gov +1
Direct source URLs: https://dos.ny.gov/system/files/documents/2023/02/020123.pdf
https://dos.ny.gov/system/files/documents/2023/02/020123.pdf?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_selected_adoption_notice_checked", "scope": "Notice identification, filing/effective date, selected summary/nexus/compliance only; not whole88-page Register.", "selected_evidence_keys": ["adoption_notice_date_and_summary", "adoption_notice_nexus_compliance_tail"], "all_original_limits_retained": true}

R028-P1-S011 Saved research record

NYDFS, Part 600 Notice of Adoption. https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_notice

Recorded check status: original attribution unreopened all limits retained

Exact read extent and pages: Items 1–6, printed pp. 1–2, indexes 0–1, including action, publication-based effectiveness, authority, and prior revised-proposal date. Later administrative fields were encountered but not used as a complete filing-form review.
Version, effectiveness, status, limits: Five-page agency adoption form. “Rev. 1/17” is the administrative form revision, not a merchant disclosure version or effective date. No form filled or submitted. Notice
Direct source URLs: https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_notice
https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_notice?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S012 Saved research record

NYDFS, Assessment of Public Comments for Revised Proposed 23 NYCRR 600. https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_apc

Recorded check status: fresh complete APC parsed checked explanation only

Exact read extent and pages: Complete comments and agency responses 1–9, printed pp. 1–6, indexes 0–5.
Version, effectiveness, status, limits: Agency rulemaking explanation accompanying final adoption. Commenters’ positions are not law; agency responses are explanatory material, not substitutes for the enacted/adopted text. APC
Direct source URLs: https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_apc
https://www.dfs.ny.gov/industry_guidance/regulations/final_financial_services/rf_finservices_23nycrr600_apc?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "fresh_complete_APC_parsed_checked_explanation_only", "scope": "Entire6-page parsed comment assessment; not operative text, pixels or judicial interpretation.", "selected_evidence_keys": ["APC_complete_explanation_not_operating_rule"], "all_original_limits_retained": true}

R028-P1-S013 Saved research record

NYDFS, Regulatory Activity—Financial Services Law. https://www.dfs.ny.gov/industry_guidance/regulatory_activity/financial_services

Recorded check status: original attribution unreopened all limits retained

Exact read extent and pages: Current preproposal, proposal, emergency, and final-adoption listings, particularly the Part 600 final-adoption row and notice that final postings may be retained only temporarily.
Version, effectiveness, status, limits: Current agency publication accessed in this session. Sections show different update dates: preproposal/emergency August 26, 2026; proposals July 22, 2026; final-adoption section November 1, 2023. These are publication metadata, not Part 600 operative dates or a complete amendment audit. Department of Financial Services
Direct source URLs: https://www.dfs.ny.gov/industry_guidance/regulatory_activity/financial_services
https://www.dfs.ny.gov/industry_guidance/regulatory_activity/financial_services?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S014 Saved research record

NYDFS, 2026 Three and Five Year Review of Agency Rules. https://www.dfs.ny.gov/industry_guidance/regulatory_and_legislative_activities/agency_rules_3and5year_review

Recorded check status: original attribution unreopened all limits retained

Exact read extent and pages: Part 600 review entry, printed p. 74, index 73.
Version, effectiveness, status, limits: Current agency review document describing the 2023 adoption. The invitation for comments on the rule is not itself an amendment. Other entries and the entire 75-page document were not substantively reviewed. dfs.ny.gov
Direct source URLs: https://www.dfs.ny.gov/industry_guidance/regulatory_and_legislative_activities/agency_rules_3and5year_review
https://www.dfs.ny.gov/industry_guidance/regulatory_and_legislative_activities/agency_rules_3and5year_review?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S015 Saved research record

New York State Senate, enacted S5470B, Laws of 2020, chapter 369. https://www.nysenate.gov/legislation/bills/2019/S5470

Recorded check status: original attribution unreopened all limits retained

Exact read extent and pages: Official action showing signature December 23, 2020; B-version original §802(g) threshold and original act §2, including printed bill p. 9 for the original 180-day effective-date clause.
Version, effectiveness, status, limits: Historical enacted-bill text and action record. The page also contains earlier bill versions; those were not conflated with B. No complete session-law or all-version comparison claimed. nysenate.gov +2
Direct source URLs: https://www.nysenate.gov/legislation/bills/2019/S5470
https://www.nysenate.gov/legislation/bills/2019/S5470?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S016 Saved research record

New York State Senate, enacted S898, Laws of 2021, chapter 61. https://www.nysenate.gov/legislation/bills/2021/S898

Recorded check status: original attribution unreopened all limits retained

Exact read extent and pages: Official signed-chapter action; amended §§802–803; complete act §§2–3 concerning saving language and effectiveness. The latter appear on printed bill pp. 6–7 in HTML.
Version, effectiveness, status, limits: Signed February 16, 2021. Establishes January 1, 2022 underlying statutory effectiveness, immediate rulemaking authorization, and preservation of other illegality/licensing requirements. Not a complete subsequent session-law audit. nysenate.gov +3
Direct source URLs: https://www.nysenate.gov/legislation/bills/2021/S898
https://www.nysenate.gov/legislation/bills/2021/S898?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S017 Saved research record

NYDFS, February 1, 2023 release announcing adoption of commercial-financing disclosure regulation. https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202302011

Recorded check status: original attribution unreopened all limits retained

Exact read extent and pages: Entire substantive release.
Version, effectiveness, status, limits: Historical agency announcement, used as context only. It does not replace the adoption notice or operative text. Department of Financial Services
Direct source URLs: https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202302011
https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202302011?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S018 Saved research record

New York State Senate, UCC §2-A-103. https://www.nysenate.gov/legislation/laws/UCC/2-A-103

Recorded check status: original attribution unreopened all limits retained

Read extent: Definitions (1)(h), (h-1), and (j), especially the complete lease definition.
Version/status and limits: Current official page; revision metadata June 5, 2026. No actual lease/security-interest characterization or full UCC §1-203 investigation. NYSenate.gov
Direct source URLs: https://www.nysenate.gov/legislation/laws/UCC/2-A-103
https://www.nysenate.gov/legislation/laws/UCC/2-A-103?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S019 Saved research record

New York State Senate, VTL §415 and §137-a. https://www.nysenate.gov/legislation/laws/VAT/415; https://www.nysenate.gov/legislation/laws/VAT/137-A

Recorded check status: original attribution unreopened all limits retained

Read extent: §415(1)(a)–(j) complete; additional adjacent definitions encountered. §137-a entire definition.
Version/status and limits: §415 revision metadata April 3, 2026; §137-a September 22, 2014. Definitions only for exemption boundaries; no licensing/registration records or actual dealer determination. NYSenate.gov +1
Direct source URLs: https://www.nysenate.gov/legislation/laws/VAT/415
https://www.nysenate.gov/legislation/laws/VAT/137-A
https://www.nysenate.gov/legislation/laws/VAT/415?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/VAT/137-A?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S020 Saved research record

New York State Senate, GBL §396-z. https://www.nysenate.gov/legislation/laws/GBS/396-Z

Recorded check status: original attribution unreopened all limits retained

Read extent: Current (1)(b), (c), (k); effectiveness notices; future-version (1)(c) compared.
Version/status and limits: Page revision metadata July 7, 2023. Current and future bodies are separately displayed: present version until June 30, 2028; future version effective June 30, 2028. Rental-company definition selected here; full rental-protection regime held. NYSenate.gov +1
Direct source URLs: https://www.nysenate.gov/legislation/laws/GBS/396-Z
https://www.nysenate.gov/legislation/laws/GBS/396-Z?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S021 Saved research record

New York State Senate and ITS, State Technology Law Article 3, ESRA. https://www.nysenate.gov/legislation/laws/STT/A3; https://www.nysenate.gov/legislation/laws/STT/301; https://www.nysenate.gov/legislation/laws/STT/302; https://www.nysenate.gov/legislation/laws/STT/303; https://www.nysenate.gov/legislation/laws/STT/304; https://www.nysenate.gov/legislation/laws/STT/305; https://www.nysenate.gov/legislation/laws/STT/306; https://www.nysenate.gov/legislation/laws/STT/307; https://www.nysenate.gov/legislation/laws/STT/308; https://www.nysenate.gov/legislation/laws/STT/309; parallel ITS publication: https://its.ny.gov/nys-technology-law

Recorded check status: original attribution unreopened all limits retained

Read extent: Article index and §§301–309 across the official publications; particularly §302 signature definition, §§304–306 validity/records/evidence, all §307 exceptions, §308 confidentiality, and §309 voluntariness.
Version/status and limits: Current statute, with §307 showing current/future alternatives. Current §307(1) lasts until December 12, 2027; future text is separately labeled effective that date. General metadata for many sections is 2014-09-22; §307 metadata 2026-02-27. No actual electronic-signature implementation approved. NYSenate.gov +5
Direct source URLs: https://www.nysenate.gov/legislation/laws/STT/A3
https://www.nysenate.gov/legislation/laws/STT/301
https://www.nysenate.gov/legislation/laws/STT/302
https://www.nysenate.gov/legislation/laws/STT/303
https://www.nysenate.gov/legislation/laws/STT/304
https://www.nysenate.gov/legislation/laws/STT/305
https://www.nysenate.gov/legislation/laws/STT/306
https://www.nysenate.gov/legislation/laws/STT/307
https://www.nysenate.gov/legislation/laws/STT/308
https://www.nysenate.gov/legislation/laws/STT/309
https://its.ny.gov/nys-technology-law
https://www.nysenate.gov/legislation/laws/STT/A3?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/STT/301?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/STT/302?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/STT/303?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/STT/304?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/STT/305?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/STT/306?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/STT/307?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/STT/308?utm_source=chatgpt.com
https://www.nysenate.gov/legislation/laws/STT/309?utm_source=chatgpt.com
https://its.ny.gov/nys-technology-law?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S022 Saved research record

New York ITS, Electronic Signatures and Records Act Regulation, 9 NYCRR Part 540. https://its.ny.gov/electronic-signatures-and-records-act-esra-regulation

Recorded check status: original attribution unreopened all limits retained

Read extent: §§540.1–540.6 complete; §540.7 encountered but not analyzed. Relevant private-signature provisions: §540.4(a)–(b), §540.5(a).
Version/status and limits: Agency-hosted text expressly labeled an unofficial convenience copy. No complete Part 540 amendment/effective-date audit. Government-specific certification and risk-assessment rules were not converted into universal private-business requirements. Office of Information Technology Services +2
Direct source URLs: https://its.ny.gov/electronic-signatures-and-records-act-esra-regulation
https://its.ny.gov/electronic-signatures-and-records-act-esra-regulation?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S023 Saved research record

OFR/GPO eCFR and CFPB, Regulation Z §1026.4, Finance charge. https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.4; https://www.consumerfinance.gov/rules-policy/regulations/1026/4/

Recorded check status: original attribution unreopened all limits retained

Read extent: Regulatory body (a)–(f) read in full through eCFR; corresponding CFPB body compared. Interleaved commentary was encountered, but no complete commentary audit is claimed.
Version/status and limits: Federal rule imported by New York for calculation. eCFR currency displayed through October 26, 2026 on later retrieval; title-level last-amended metadata October 23, 2026 is not a §1026.4 amendment date. eCFR is an authoritative electronic publication but not the official legal edition. Nonselected overdraft-related differences between displays were not used to support an SBF proposition. ecfr.gov +4
Direct source URLs: https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.4
https://www.consumerfinance.gov/rules-policy/regulations/1026/4/
https://www.consumerfinance.gov/rules-policy/regulations/1026/4/?utm_source=chatgpt.com
https://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.4?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S024 Saved research record

OFR/GPO eCFR and CFPB, Regulation Z §1026.22, Determination of annual percentage rate. https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.22; https://www.consumerfinance.gov/rules-policy/regulations/1026/22/

Recorded check status: original attribution unreopened all limits retained

Read extent: Body (a)–(d); official interpretations 22(a)(1)-1 through -5, 22(a)(2)-1, and 22(a)(3)-1.
Version/status and limits: Federal imported calculation authority. CFPB labels its page current. Official interpretations are identified as interpretations, not New York statutes or staff correspondence. No CFPB circular, bulletin, or advisory was relied upon. ecfr.gov +1
Direct source URLs: https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.22
https://www.consumerfinance.gov/rules-policy/regulations/1026/22/
https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.22?utm_source=chatgpt.com
https://www.consumerfinance.gov/rules-policy/regulations/1026/22/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S025 Saved research record

OFR/GPO eCFR and CFPB, Regulation Z Appendix J. https://www.ecfr.gov/current/title-12/chapter-X/part-1026/appendix-Appendix%20J%20to%20Part%201026; https://www.consumerfinance.gov/rules-policy/regulations/1026/j/

Recorded check status: original attribution unreopened all limits retained

Read extent: Text of (a)(1)–(3), (b)(1)–(6), and textual iteration instruction (b)(9)(ii).
Version/status and limits: Imported actuarial framework. Image-based symbols/equations in (b)(7)–(9) were not pixel-inspected; the full example collection was not read. No APR solver or numerical transaction illustration is claimed. Consumer Financial Protection Bureau +3
Direct source URLs: https://www.ecfr.gov/current/title-12/chapter-X/part-1026/appendix-Appendix%20J%20to%20Part%201026
https://www.consumerfinance.gov/rules-policy/regulations/1026/j/
https://www.ecfr.gov/current/title-12/chapter-X/part-1026/appendix-Appendix%20J%20to%20Part%201026?utm_source=chatgpt.com
https://www.consumerfinance.gov/rules-policy/regulations/1026/J/?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S026 Saved research record

U.S. House OLRC, 15 USC §1602(g), and GPO 2024 edition of the same statute. https://uscode.house.gov/us/usc/119-121/t15/s1602/; https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partA-sec1602.htm

Recorded check status: original attribution unreopened all limits retained

Read extent: Complete §1602(g); adjacent definitions encountered.
Version/status and limits: OLRC states laws in effect through Public Law 119-121, October 9, 2026. GPO 2024 publication is historical corroborating text of the same instrument. Used only for Part 600’s as-if creditor calculation premise; actual federal creditor status held. uscode.house.gov +1
Direct source URLs: https://uscode.house.gov/us/usc/119-121/t15/s1602/
https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partA-sec1602.htm
https://uscode.house.gov/us/usc/119-121/t15/s1602/?utm_source=chatgpt.com
https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partA-sec1602.htm?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S027 Saved research record

State-linked NYCRR electronic compilation: https://govt.westlaw.com/nycrr/Index?bhcp=1&contextData=%28sc.Default%29&transitionType=Default. Located §600.1 page: https://govt.westlaw.com/nycrr/Document/I8bdf0115366511f085fee08d50b7f070?contextData=%28sc.Default%29&originationContext=documenttoc&transitionType=CategoryPageItem&viewType=FullText

Recorded check status: original known compilation failures preserved unreopened

Retrieval/read result: Both returned HTTP 403; no substantive body read there.
Consequence: Current codification placement is supported by official adoption and agency listings, but the later-current compiled Part 600 body was not independently retrieved.
Direct source URLs: https://govt.westlaw.com/nycrr/Index?bhcp=1&contextData=%28sc.Default%29&transitionType=Default
https://govt.westlaw.com/nycrr/Document/I8bdf0115366511f085fee08d50b7f070?contextData=%28sc.Default%29&originationContext=documenttoc&transitionType=CategoryPageItem&viewType=FullText
https://govt.westlaw.com/nycrr/Document/I8bdf0115366511f085fee08d50b7f070?contextData=(sc.Default)&originationContext=documenttoc&transitionType=CategoryPageItem&viewType=FullText&utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_known_compilation_failures_preserved_unreopened", "scope": "Both original Westlaw403 routes remain failed; no attempt or variant. Current compiled legal text not checked.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S028 Saved research record

NYDFS industry-letter catalog. https://www.dfs.ny.gov/industry_guidance/industry_letters

Recorded check status: original attribution unreopened all limits retained

Retrieval/read result: Current catalog and relevant 2021/financing portions checked, together with targeted official-site searches.
Consequence: No separately published official commercial-financing FAQ, standalone current merchant model package, method-election filing instruction, or opt-in reporting instruction was retrieved. This is a source gap, not a finding that none exists. Department of Financial Services +2
Direct source URLs: https://www.dfs.ny.gov/industry_guidance/industry_letters
https://www.dfs.ny.gov/industry_guidance/industry_letters?utm_source=chatgpt.com

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_attribution_unreopened_all_limits_retained", "scope": "Whole original source row reconciled, but source body not reopened here. Every version, status, cross-reference, currentness and application limit retained.", "selected_evidence_keys": [], "all_original_limits_retained": true}

R028-P1-S029 Saved research record

Other unsuccessful public-page paths, listed in the failure log in §9 below.

Recorded check status: original failure log attribution no retry

Retrieval/read result: No substantive reliance on failed pages or private reproductions.
Consequence: Failures were not converted into absence-of-law conclusions.

Recorded coordinator check boundaries

coordinator review: {"at": "2026-10-29T09:04:13.367214+00:00", "identity": "delegated coordinator /root/review_wv1; not independent", "source_check": "[internal evidence reference]", "disposition": "original_failure_log_attribution_no_retry", "scope": "Original grouped failures retained with fifteen log rows; no failed text used as substantive authority.", "selected_evidence_keys": [], "all_original_limits_retained": true}

What was examined—and what is still missing

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

Search this report’s coverage and gaps

coverage-1 Saved research record