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

S_AK PASS-01 — Alaska provider market access and consumer fees

Current-law check and source access: October 24, 2026, America/Los_Angeles. Scope: Alaska provider access, legal classification, fee structures, fee timing, and public application/lookup procedures. This is not an Alaska state overview or state acceptance. Agreement terms, client-fund architecture, bonding, remedies, enforcement, limitations, litigation, sector-specific rules, secured debt, local/tribal law, and full case-law coverage remain open for later passes.

Executive determination

After reviewing Alaska’s published statutes, 2026 enacted legislation, operative regulations and adoption orders, official regulator materials, forms, public rosters, and targeted official-site searches, I did not locate or verify a dedicated Alaska “debt adjuster,” “debt settlement,” “debt management,” or “credit-counseling” licensing and consumer-fee regime comparable to the specialized statutes used by many other states. That is a bounded research finding, not a claim that no uncatalogued authority could exist.

Alaska instead regulates the relevant conduct through a stack of generally applicable laws:

1. A provider conducting Alaska business activity ordinarily needs an Alaska business license.
2. A provider selling services through Alaska’s unusually broad definition of “telephonic means” ordinarily must register each solicitation campaign with the Alaska Department of Law at least 30 days before launch, unless a specific, conditional exemption applies.
3. A provider that receives consumer money for transmission to creditors or collectors likely enters Alaska’s money-transmission regime and may not operate without an Alaska license, authorized-delegate relationship, qualifying out-of-state approval, or statutory exclusion.
4. A provider acting for creditors to collect claims can enter Alaska’s collection-agency regime. A conventional debtor-side negotiator is not plainly within the creditor-side statutory text, but Alaska-specific decisional authority resolving every hybrid DMP arrangement was not located.
5. Alaska does not supply a verified numerical debt-relief service-fee ceiling for setup fees, monthly fees, settlement percentages, savings percentages, per-debt charges, or aggregate fees. That does not make fees unrestricted: contracts, Alaska’s telephonic-sales and unfair-practices laws, money-transmission duties, and the federal Telemarketing Sales Rule may independently constrain them.
6. For a federally covered debt-relief sale, the TSR’s performance rule remains separate: a provider may not request or receive its fee merely because Alaska lacks a numerical cap or because an Alaska telephonic contract has been signed.
7. The current-law baseline includes SB 249, Chapter 50 SLA 2026, effective October 1, 2026. The broad money-transmission replacement enacted by SB 86, Chapter 48 SLA 2026, generally does not become operative until July 1, 2027. LegiScan+3

A. Substantive findings

1. How Alaska currently defines and classifies the relevant conduct

1.1 No verified Alaska debt-relief-specific taxonomy

No current Alaska statute or regulation was located that independently defines:

• “debt adjustment”;
• “debt settlement”;
• “debt negotiation”;
• “debt-management plan”;
• “credit counseling”; or
• a debt-relief provider’s permissible consumer fee.

Alaska’s official consumer-law index lists the state’s Telephonic Solicitations Act, UTPA, and other consumer statutes, but no debt-adjuster chapter. DCCED’s complete professional-license menu includes collection agencies but no debt-settlement or credit-counseling profession. A legacy Alaska “Company Uniform Application” does list debt negotiation, debt settlement/debt adjuster, and debt management/credit counseling—but that same form expressly says its activity list includes businesses for which the applicant is not seeking licensing authority. It therefore cannot be treated as a debt-settlement license application. Claims C001, C002, C025. Alaska Department of Law+3

Alaska classification must consequently follow the provider’s actual functions, not its marketing label.

1.2 Conduct matrix

Current AS 06.55 defines money transmission to include receiving money or monetary value for transmission to, from, or within Alaska. A person may not engage in or hold itself out as providing money transmission unless licensed or an authorized delegate; AS 06.55.103 also supplies a qualifying approval route for certain entities licensed in another state. LegiScan+2

1.3 Principal reduction versus concession/distribution services

For Alaska purposes, the material distinctions are not simply “settlement” versus “DMP”:

• A principal-reduction company that never handles money may avoid the money-transmission classification.
• A DMP that never reduces principal but receives a consolidated monthly payment and distributes it can fall squarely within the money-transmission language.
• Pure credit counseling can remain outside both functions if the provider neither promises altered creditor terms nor handles money.
• A hybrid provider may be subject to different regimes for different parts of the same program.

For federal TSR purposes, by contrast, a “debt relief service” broadly includes a program represented to renegotiate, settle, reduce, or otherwise alter payment terms or other terms of unsecured debt—including balance, interest, or fees. Thus both settlement and concession-oriented DMP services can be covered when the telemarketing nexus exists. eCFR

1.4 Custodial versus noncustodial models

Noncustodial: Merely advising a consumer or communicating offers between the consumer and creditor does not, without more, satisfy the words “receiving money or monetary value for transmission.” That conclusion is a reasoned reading of the text, not an Alaska safe harbor.

Custodial: A provider that takes $500 from an Alaska consumer and is obligated to send some or all of it to creditors is receiving money for transmission. Unless licensed, approved, acting as a properly appointed authorized delegate, or within an exclusion, AS 06.55.101 prohibits the activity. Justia Law+1

Control without literal receipt: Alaska’s present definition does not supply a debt-relief-specific rule for constructive receipt, payment instruction authority, or consumer-owned dedicated accounts. Account documents and the administrator’s role must be investigated before making a market-access determination.

1.5 Consumer versus business purpose

Alaska’s telephonic-sales chapter defines a “buyer” simply as a person solicited by telephonic means. It does not contain a household-purpose qualifier in that definition. Its “telephonic means” definition includes electronic communication between computing devices and certain written communications encouraging the recipient to contact the seller. Justia Law

Similarly, AS 06.55’s transmission definition is based on receiving and transmitting value to, from, or within Alaska, not on whether the underlying debt is consumer or commercial.

The federal TSR is different. Its business-to-business call exemption generally excludes calls made to induce purchases by a business, subject to the exceptions stated in 16 C.F.R. § 310.6(b)(7). That federal exemption does not rewrite Alaska’s definitions. eCFR

1.6 Alaska-resident and remote-provider nexus

Alaska’s business-licensing agency states that physical presence is not required; the obligation is based on business activity, and the agency expects a license when any portion of the business activity occurs within Alaska. Because that is administrative guidance rather than a debt-relief-specific jurisdictional holding, edge cases should be analyzed from the actual sales, service, and payment facts. Alaska Department of Commerce+1

For money transmission, SB 249’s currently effective definition expressly covers transmission:

• to Alaska;
• from Alaska; or
• within Alaska. LegiScan

For telephonic selling, remote providers can be covered because “telephonic means” is not confined to a conventional outbound voice call. Written prompts, electronic communications, and substantially identical campaigns to two or more persons can trigger the chapter. Justia Law+1

2. Whether each business model is prohibited, licensed, registered, authorized, or exempt

2.1 Market-access matrix

2.2 Telephonic seller registration is an access condition, not a debt license

AS 45.63.010 prohibits selling or attempting to sell services through a qualifying campaign unless the telephone seller is registered with the Department of Law at least 30 days before the campaign. A separate notice is required for each campaign, and registration is not complete until the seller receives the Department’s acknowledgment. Justia Law

The official application requires:

• a separate filing per campaign;
• a $200 nonrefundable fee;
• service descriptions and costs;
• a sample written contract;
• updates within 10 days for material changes; and
• salesperson updates every 90 days. Alaska Department of Law+3

That registration permits operation of the telephonic sales channel subject to the Act. It is not a substantive determination that the applicant may lawfully provide debt settlement, hold consumer funds, charge any particular fee, or avoid federal law.

2.3 Money-transmission authorization

For a custodial model, the current pathways are:

1. an Alaska money-transmission license;
2. operation as an authorized delegate of an Alaska-licensed transmitter;
3. qualifying approval under AS 06.55.103 for a person licensed in another state; or
4. an actual statutory exclusion.

The Division of Banking and Securities states that all licensing activity is conducted through NMLS. Applications require the statutory information, screening materials, security evidence, background authorization, and applicable fees. Alaska Department of Commerce+2

2.4 Attorney status

No blanket attorney exemption was located in either:

• AS 45.63’s telephonic-solicitation exemptions; or
• AS 06.55.802’s current money-transmission exclusions.

Attorneys are expressly excluded from Alaska’s collection-agency chapter when acting in the regular course of their legal business, but that does not itself exempt an attorney-controlled business from money-transmission or telephonic-selling rules. Justia Law+3

The federal TSR likewise has no general attorney exemption for attorneys engaging in covered interstate telemarketing. The FTC staff guide notes that particular attorneys may fall outside the rule because of their actual sales method, such as a qualifying face-to-face process, not merely because they use a law-firm or retainer label. Federal Trade Commission

2.5 Nonprofit status

A nonprofit label does not create a general Alaska exemption.

• Alaska’s business-license guidance includes nonprofit entities when they engage or offer to engage in activity for financial benefit in exchange for services or goods.
• The telephonic chapter’s charitable exemption applies only to a charitable organization or paid solicitor registered under AS 45.68 and acting within the capacity covered by that registration.
• Even the listed AS 45.63 exemptions exclude only specified provisions: AS 45.63.010, .015, .020, and .030(c)–(d). They do not, by their text, erase the buyer’s refund rights in .030(a)–(b).
• AS 06.55.802 contains no generic nonprofit exclusion. Alaska Department of Commerce+3

For federal TSR purposes, bona fide nonprofits generally fall outside the rule because the rule applies to for-profit sellers, while a company falsely claiming nonprofit status remains covered. That is federal treatment and cannot be imported as an Alaska money-transmission or telephonic-registration exemption. Federal Trade Commission

2.6 Financial institutions and other institutional exclusions

AS 45.63.080 provides a conditional telephonic-sales exemption for a supervised financial institution and its parent, subsidiary, or affiliate. It also covers certain RCA-regulated businesses and insurers. The exemption is only from the particular sections identified in subsection (a), not necessarily every requirement in the chapter. Justia Law+1

AS 06.55.802 excludes enumerated government entities, USPS transmission, qualifying banks and bank-related entities, government-benefit transfers, regulated securities/commodities clearance activity, certain payment-system operators, and securities broker-dealers to the extent stated. No general debt-relief, lawyer, or nonprofit exclusion appears in the present list. Justia Law+1

2.7 Collection-agency crossover and self-creditor boundary

AS 08.24.090 prohibits an unlicensed person, for compensation, from collecting claims for others, soliciting the right to collect or receive another’s claim, or seeking payment on another’s behalf. The definition focuses on claims owed or asserted to be owed to another. Justia Law+1

The regulator states:

• an out-of-state agency does not need an Alaska license merely because it is collecting from Alaska debtors when its creditor clients are outside Alaska;
• licensing is required when the out-of-state agency collects or solicits claims for Alaska-based creditor clients; and
• the division does not issue exemption letters. Alaska Department of Commerce

A standard consumer-retained debt negotiator is not plainly collecting for the creditor. A hybrid provider that is paid by, contracted with, or delegated authority by creditors requires a separate functional analysis. No Alaska appellate decision or published agency interpretation resolving every such hybrid was located.

3. Current fee structures, dollar limits, percentages, and refunds

3.1 Consumer-facing debt-relief fees

No Alaska-specific numerical limit was located or verified for:

• enrollment or setup fees;
• monthly maintenance fees;
• counseling fees;
• per-debt fees;
• settlement fees;
• a percentage of enrolled debt;
• a percentage of savings;
• an aggregate program fee; or
• an indexed or CPI-adjusted debt-relief fee.

That is not a conclusion that any amount is automatically lawful. It means Alaska did not supply a verified debt-relief-specific numerical schedule in the authorities found. Fee enforceability and timing remain subject to the applicable sales contract, Alaska refund and UTPA rules, federal TSR requirements, and any money-transmission or other law implicated by the actual model. Claim C015.

No Alaska bulletin or dated table establishing a debt-relief CPI adjustment was located. Accordingly, no “current adjusted amount” was calculated or inferred.

3.2 Verified provider-side governmental fees

The telephonic fee is confirmed by both 9 AAC 14.060 and the current official application. Alaska Department of Law+1

The current money-transmission fee amounts are stated in 3 AAC 13.840. The regulation’s history identifies the fee amendment as effective November 22, 2017; the official adoption order contains the same amounts. Legal Information Institute+1

These are governmental/provider access fees, not consumer debt-relief charges and not evidence that Alaska has approved the provider’s consumer pricing.

3.3 Money-transmission transaction fees

AS 06.55.820 requires the licensee, generally within ten business days after receiving the value, to transmit the monetary equivalent after deduction of fees or make it available to the designated recipient. AS 06.55.830 requires a receipt stating the amount presented and total fees charged. Justia Law+1

Those provisions establish transaction-performance and disclosure duties. They do not:

• authorize a debt-settlement percentage;
• approve a debt-management service charge;
• create an advance-fee exception; or
• transform a telephonic registration into a debt-relief license.

3.4 Virtual-currency kiosk cap is not a debt-relief cap

SB 249 created a 10% fee ceiling for a “virtual currency kiosk transaction.” Its definition and surrounding provisions concern transactions conducted through a virtual-currency kiosk. The same act amended the general location language in the money-transmission definition and took effect October 1, 2026. LegiScan+3

A $4,000 credit-card debt settlement is not converted into a virtual-currency kiosk transaction merely because the same chapter contains a 10% limit.

3.5 Refund and credit conditions

Telephonic services: A buyer is entitled to a refund or credit when, within seven days after paying and before services are provided, the buyer makes a written request. Separate protection applies when services are defective, not as represented, or not received as promised. A timely request can be made in person or properly mailed and postmarked within the period. Justia Law

SB 252, effective September 30, 2026, amended AS 45.63.030 only to add the new AS 45.36 UCC cross-reference. It retained the seven-day service-refund wording. LegiScan+2

Money transmission: A money-transmission licensee must generally refund money equal to the money or equivalent value received for the transmission within ten days after a written request, unless the value has already been transmitted or made available, crime concerns exist, or another law prohibits the refund. The statute should not be treated as an automatic refund rule for every separate debt-relief service fee. Justia Law

SB 249 separately excluded virtual-currency kiosk refunds under the new kiosk provisions from AS 06.55.840. That kiosk amendment does not alter ordinary debt-relief service-fee rules. LegiScan

4. When fees may actually be requested or received

4.1 Alaska telephonic contract trigger

A telephone seller may not:

• solicit payment;
• charge a credit card;
• negotiate a check or other payment instrument; or
• accept cash

until it has received a signed written contract from the buyer. The contract must disclose the buyer’s AS 45.63.030 rights and required regulatory information. Justia Law

This is a minimum Alaska sales-channel condition, not affirmative authorization to collect a debt-relief fee immediately after signature.

4.2 Federal TSR performance trigger

For a covered debt-relief service, 16 C.F.R. § 310.4(a)(5) prohibits requesting or receiving the provider’s fee until all three conditions are satisfied:

1. at least one debt has been renegotiated, settled, reduced, or otherwise altered under a valid settlement agreement, DMP, or other contractual agreement;
2. the customer has made at least one payment under that agreement to the creditor or collector; and
3. when debts are handled individually, the fee attributed to that debt follows one of the permitted allocation methods. eCFR

The allocation alternatives are:

• Proportional enrolled-debt method: the fee for the resolved debt bears the same proportion to the total contracted fee as that debt bore to total enrolled debt; or
• Savings method: the provider charges a percentage of actual savings, using the same percentage from one individual debt to another. eCFR

The TSR sets timing and allocation requirements; it does not itself prescribe a maximum 15%, 20%, 25%, or other fee.

4.3 Dedicated accounts

The TSR permits requiring a customer to place funds in an account for creditor payments and lawful provider fees only if, among other things:

• the account is at an insured financial institution;
• the customer owns the funds and receives any interest;
• the account administrator is not owned, controlled by, or affiliated with the debt-relief provider;
• no referral compensation passes between the administrator and provider; and
• the customer can withdraw at any time without penalty and receive all funds other than properly earned provider fees within seven business days. eCFR

This federal permission to fund an independent account is not an Alaska money-transmission ruling. Alaska status still turns on who receives, controls, administers, and transmits the money.

4.4 State and federal conditions must be stacked

A covered telephonic transaction can therefore require all of the following:

• Alaska campaign registration;
• a signed Alaska-compliant contract before payment is solicited or accepted;
• satisfaction of the federal performance trigger before the provider receives its service fee;
• money-transmission authorization if the provider or related entity receives funds for creditor transmission; and
• compliance with Alaska refund and deceptive-practices rules.

Passing one condition does not satisfy the others.

5. Actual regulator procedure, application, and lookup routes

5.1 Business-license procedure

The official page provides:

• online new and renewal applications;
• business-license records and status search;
• forms and fees; and
• immediate posting of online new or renewed licenses to the search database. Alaska Department of Commerce

An Alaska business license is a baseline permission to conduct business. AS 43.70.020(d) expressly requires a business subject to another regulatory regime to satisfy that regime as well. Justia Law

5.2 Telephonic registration is operational

The Department of Law’s current list is dated October 15, 2026 and includes, among others:

• Beyond Finance—described as offering debt management, debt settlement, and marketing services;
• Century Support Services—debt settlement;
• ClearOne Advantage—debt settlement, debt negotiation, and financial education; and
• DebtBlue—debt-relief services. Alaska Department of Law+1

This proves that the Department is currently administering AS 45.63 registrations for campaigns described as debt-relief campaigns. It does not prove:

• authorization under AS 06.55;
• an Alaska debt-settlement license;
• approval of consumer fees;
• compliance with the federal TSR;
• compliance with contract or client-funds duties; or
• current authorization of any provider not separately checked.

5.3 Money-transmission procedure and lookup limitation

The Division of Banking and Securities states that all licensing activity is conducted through NMLS and links to the licensing checklist, statutes, regulations, and filing systems. Alaska Department of Commerce

The Alaska-hosted MSB roster available during this research has a filename indicating March 19, 2026. It contains filing status and license numbers, but it is older than the October 24, 2026 current-law check. It is useful as a public roster, but it should not be treated as conclusive current status when a current NMLS verification is available. Alaska Department of Commerce

No provider-specific NMLS determination was made in this pass.

5.4 The legacy “Company Uniform Application” is not a debt-relief application

The legacy form’s debt-related activity checklist is potentially misleading. Immediately before the checklist, the form instructs applicants to identify activities including those “for which your company is not specifically seeking licensing authority.” The following list includes debt negotiation, debt settlement/debt adjuster, and debt management/credit counseling. Alaska Department of Commerce+1

It is therefore a general business-activity disclosure taxonomy, not evidence that Alaska historically or currently grants a debt-settlement license.

5.5 Advertising authorization or status inaccurately creates UTPA risk

Alaska prohibits unfair or deceptive trade practices, including creating confusion about approval, affiliation, certification, sponsorship, or status. A provider should not advertise a business license, telephonic registration, nonprofit relationship, attorney relationship, or NMLS filing as an Alaska endorsement of its debt-relief program. Justia Law

Alaska’s 2023 FirstChoice action illustrates the enforcement posture: the complaint alleged that debt-relief solicitations were designed to resemble government financial-assistance notices. It is an allegation and enforcement example, not a controlling judicial classification of debt settlement. Alaska Department of Law

6. Fee and boundary examples

Detailed examples appear in D.1 below. The key outcomes are:

• a hypothetical percentage can be used to demonstrate the federal proportional or savings calculation, but it is not an Alaska-approved percentage;
• no fee may be allocated to an unresolved individual debt under the TSR’s individual-debt rule;
• a telephonic buyer can have a seven-day pre-service refund right;
• a licensed money transmitter’s disclosed transaction fee does not become a debt-management fee authorization; and
• a provider that receives creditor funds without required AS 06.55 authority has no verified lawful custodial fee scenario to calculate.

7. Component coverage and next investigations

This pass resolves the basic market-access and fee architecture but does not close Alaska.

Material holds remain concerning:

• Alaska agency interpretation of DMP and dedicated-account fund flow under AS 06.55;
• complete provider-specific NMLS and authorized-delegate verification;
• creditor-side collection crossover for hybrid debt-relief arrangements;
• Alaska appellate or published administrative decisions directly classifying debt settlement;
• client-fund account, trust, segregation, remittance, and reconciliation duties beyond the limited AS 06.55 provisions needed here;
• security/bond and financial-condition requirements;
• contract form and disclosure requirements beyond the telephonic-sales threshold;
• remedies, penalties, private actions, and limitation periods;
• secured debts and sector-specific products;
• local, municipal, Alaska Native, and tribal issues; and
• enforcement-history and full case-law review.

The full component table is in D.2.

B. Source table

Access date for every source below: October 24, 2026, unless a different source date is stated. “Mirror” means the operative text was read there because the official Alaska Legislature endpoint returned a public-web 403 response. The failed official routes are preserved in S_AK-P1-S019.

C. Claim table

D. Worked examples and coverage/gap table

D.1 Plain-text worked examples

Example 1 — TSR proportional fee after one individual debt is resolved

Plain text

Assumptions:
- Federal TSR applies.
- Alaska telephonic and other access requirements have also been satisfied.
- Debts enrolled at contract date:
    Debt A = $8,000
    Debt B = $7,000
    Debt C = $5,000
- Total enrolled debt = $20,000
- Hypothetical contracted total fee = 25% of enrolled debt.
- The 25% is an example only. It is not an Alaska-approved rate or Alaska cap.
- Debt C is settled, a valid agreement is executed, and the consumer makes the
  first payment required by that agreement.

Base:
$20,000 total enrolled debt

Total hypothetical fee:
$20,000 × 25% = $5,000

Resolved-debt proportion:
$5,000 ÷ $20,000 = 0.25

Fee attributable to Debt C:
0.25 × $5,000 = $1,250.00

Result:
- Fee currently attributable to Debt C = $1,250.00
- Fee not yet attributable to Debts A and B = $3,750.00
- Units: U.S. dollars
- Rounding: nearest cent

Legal condition: The calculation is not triggered merely by obtaining the consumer’s signature. The debt alteration and first creditor payment must both have occurred. Claims C021–C022. eCFR

Example 2 — TSR savings-percentage method

Plain text

Assumptions:
- TSR applies.
- The provider uses the same 25% savings percentage for every individual debt.
- Enrolled balance of the resolved debt = $5,000
- Amount actually paid to satisfy it = $3,000
- Valid agreement and first consumer payment have occurred.

Actual savings:
$5,000 - $3,000 = $2,000

Fee:
$2,000 × 25% = $500.00

Result:
Fee attributable to that debt = $500.00
Units: U.S. dollars
Rounding: nearest cent

The 25% figure is hypothetical. Alaska supplies no verified 25% ceiling or approval. The example treats the savings and proportional methods as alternatives, not cumulative fees. Claims C015, C021, C023.

Example 3 — Lower-balance debt shows why the fee base matters

Plain text

Inputs:
- Enrolled balance = $800
- Settlement payment = $600
- Savings = $800 - $600 = $200
- Hypothetical percentage = 25%

Alternative A — enrolled-debt fee:
$800 × 25% = $200.00

Alternative B — savings fee:
$200 × 25% = $50.00

Difference:
$200 - $50 = $150.00

Result:
The same written percentage produces materially different fees depending on
the contractual base. Alaska did not verify or approve either base.

For a federally covered individually resolved debt, the provider must use the applicable TSR allocation method and satisfy the performance trigger. Claims C021–C023.

Example 4 — Prior earned fees, partial program performance, and cancellation

Plain text

Inputs:
- Debts at enrollment:
    Debt A = $10,000
    Debt B = $5,000
    Debt C = $5,000
- Total = $20,000
- Hypothetical total fee = 20% = $4,000
- Proportional method is used.
- Debt A and Debt B have each satisfied all TSR triggers.
- Debt C remains unresolved.
- Consumer then cancels.

Debt A proportion:
$10,000 ÷ $20,000 = 50%
Fee for Debt A:
50% × $4,000 = $2,000

Debt B proportion:
$5,000 ÷ $20,000 = 25%
Fee for Debt B:
25% × $4,000 = $1,000

Debt C proportion:
$5,000 ÷ $20,000 = 25%
Potential allocation = $1,000
Current earned amount = $0 because Debt C has not satisfied the trigger.

Total previously triggered fee:
$2,000 + $1,000 = $3,000

Additional fee due solely because the consumer cancels:
$0

Result:
- Previously triggered fees = $3,000
- Untriggered Debt C fee = $0
- No cancellation fee is supplied by this example.

A compliant dedicated account would separately have to return consumer-owned funds other than properly earned fees within seven business days after withdrawal. eCFR

Example 5 — Alaska telephonic pre-service cancellation

Plain text

Inputs:
- Consumer pays $300 on Day 0 after signing the required written contract.
- Consumer makes a written refund request on Day 5.
- No service has yet been provided.

Elapsed period:
5 days

Statutory window:
Within 7 days after paying and before services are provided.

Refund or credit:
$300.00

Result:
The consumer is entitled to a $300 refund or credit under AS 45.63.030(a)(3),
assuming the transaction is covered and no other factual issue defeats the claim.

If the service was already provided before the request, the unconditional pre-service branch does not apply on those facts. Claims that services were defective, misrepresented, or not provided as promised remain separately analyzed under subsection (a)(1). Claim C012. Justia Law

Example 6 — Licensed custodial DMP transmission calculation

Plain text

Assumptions:
- Provider is properly authorized under AS 06.55.
- $400 is received for transmission.
- A separately disclosed $30 transaction fee is lawful under the applicable
  contract and all other law.
- No contrary consumer instruction or crime concern exists.

Amount received:
$400.00

Disclosed transaction fee:
$30.00

Net monetary equivalent for transmission:
$400 - $30 = $370.00

Timing:
Transmit $370 or make it available to the consumer-designated recipients
within 10 business days.

Receipt:
Must clearly show $400 presented and $30 total fees.

This example demonstrates AS 06.55’s transaction rule. It does not establish that a $30 debt-management service fee is approved, capped, or earnable in advance. Claim C016. Justia Law+1

Example 7 — Unlicensed custodial model: classification hold, not a fee calculation

Plain text

Facts:
- Provider receives $1,000 from an Alaska consumer.
- Provider promises to remit the money to three creditors.
- Provider has no Alaska money-transmission license.
- Provider is not an authorized delegate.
- No AS 06.55.103 approval or statutory exclusion is established.

Classification:
Receiving the $1,000 for creditor transmission fits the ordinary current
money-transmission language.

Legal access result:
The provider may not proceed with the custodial activity on these facts.

Lawful service-fee calculation:
Held. No licensed custodial scenario has been established, so no fee is
invented or calculated.

Claims C004 and C017. LegiScan+1

Example 8 — Independent dedicated account boundary

Plain text

Facts requiring verification:
- Consumer deposits $900 into an insured account in the consumer's own name.
- Consumer receives any interest.
- Independent administrator is not owned, controlled by, or affiliated with
  the debt-relief provider.
- No referral compensation passes between them.
- Consumer may withdraw at any time.
- Provider cannot unilaterally take or redirect creditor funds.
- Provider receives only fees that have satisfied the TSR trigger.

Federal result:
The structure may satisfy the TSR dedicated-account conditions.

Alaska result:
Held pending:
1. who legally receives the funds;
2. who can issue payment instructions;
3. whether the administrator transmits value to or from Alaska;
4. whether the provider has direct or constructive control;
5. whether either entity is licensed, approved, delegated, or excluded.

No Alaska debt-relief-specific safe harbor was found for this architecture. Claim C024.

Example 9 — The virtual-currency kiosk cap does not create a debt-relief cap

Plain text

Transaction:
Ordinary credit-card debt settlement program
Enrolled debt:
$4,000
Virtual-currency kiosk used:
No

SB 249 kiosk fee calculation:
Not applicable

Incorrect calculation:
$4,000 × 10% = $400 as an "Alaska debt settlement cap"

Correct result:
No Alaska debt-relief cap is derived from the kiosk statute.

Claim C025. LegiScan

D.2 Full PASS-01 coverage and gap table

E. Researcher self-check

Material actually read

I read the relevant operative passages of:

• AS 45.63 registration, written-contract, cancellation, exemption, and definition provisions;
• 9 AAC 14 registration, update, and fee regulations;
• the official Alaska telephonic seller application;
• the October 15, 2026 registered-telemarketer PDF;
• AS 43.70 business-license provisions and current DCCED instructions;
• AS 06.55 license, approval, exclusion, transmission, receipt, and refund provisions;
• 3 AAC 13 application, approval, and fee provisions;
• the official 2017 money-services fee adoption order;
• the official 2023 virtual-currency regulation filing;
• SB 249’s enrolled definition, kiosk-fee, refund, and effective-date provisions;
• SB 86’s transition and effective-date provisions;
• SB 252’s AS 45.63 amendments and effective status;
• AS 08.24 collection-agency licensing and definition provisions;
• Alaska’s collection-agency regulator guidance and verification page;
• Alaska’s UTPA text and consumer-protection materials;
• the federal TSR definition, fee trigger, allocation, dedicated-account, and business-call provisions;
• the FTC debt-relief guide’s attorney and nonprofit treatment; and
• the legacy Alaska Company Uniform Application language showing that its activity list is not a licensing request.

PDFs material to the conclusions—including the applications, rosters, enrolled bills, and regulation adoption orders—were opened and their relevant pages visually inspected, not treated as title-only search results.

Material not established or not fully read

• The Alaska Legislature’s official statute and bill-text endpoints repeatedly returned 403 responses in the available public browsing route. I preserved those failures rather than claiming direct access. Current statutory text was therefore assembled from the 2025 codification mirrors, official agency materials, enrolled-bill mirrors, and official chapter/effective-status corroboration.
• I did not treat a search snippet, association chart, company website, or legacy form as legal authorization.
• I did not obtain nonpublic Alaska agency opinions.
• I did not complete a comprehensive paid-database, PACER, or every-trial-court docket search.
• I did not inspect any provider’s private contracts, consumer files, bank agreements, dedicated-account agreements, creditor agreements, or actual transaction records.
• I did not verify any named provider’s complete current Alaska status across business licensing, telephonic registration, NMLS, authorized-delegate records, collection licensing, and entity status.
• The Alaska MSB roster available on the official site was dated March 19, 2026, so it was not used as conclusive current status.
• I did not file an application, contact a regulator, solve a CAPTCHA, change an account or permission, access private borrower data, or represent that any provider was authorized.
• I did not make local-file, publication, website-change, or publication-readiness claims.
• This is researcher self-checking, not independent legal review.
• Actual model and mode provenance is whatever the ChatGPT interface records; it is not inferred from the assignment wording.

Overall confidence

• High: telephonic registration, contract timing, cancellation text, governmental fees, current 2026 effective dates, money-transmission licensing prohibition, public application procedures, and federal TSR timing.
• Moderate-high: bounded conclusion that Alaska has no located dedicated debt-relief license or numerical fee schedule.
• Moderate: applying AS 06.55 to particular custodial DMP arrangements and applying AS 08.24 to hybrid debtor/creditor relationships.
• Held: dedicated-account arrangements without complete ownership, control, administrator, affiliate, instruction, and licensing facts.

No Alaska state completion, SettleADebt state acceptance, or A066 acceptance is implied.

END S_AK PASS-01.