Check a debt-help provider’s evidence

S_AR — PASS-01

Arkansas provider market access and consumer fees

Actual research mode: Regular Chat, GPT-5.6 Sol Pro fallback; no Deep Research, Work, Chrome control, other chats, API access, purchases, contacts, applications, or account changes. Baseline supplied: October 22, 2026, America/Los_Angeles. Actual public-source access date: October 24, 2026, Pacific time. Scope: Provider classification, lawful market access, fees, and fee timing only. This is not the complete Arkansas dossier and does not imply Arkansas-state or A066 acceptance.

Bottom-line determination

Arkansas is best classified as a statutory prohibition/exclusion state, not an ordinary debt-settlement licensing state:

1. A for-profit provider that receives a consumer’s money for distribution to creditors under a DMP falls within Arkansas’s first definition of “debt adjusting.”
2. A for-profit settlement or negotiation provider that acts as an intermediary and receives money or property for creditor payment or distribution falls within the second definition.
3. Covered conduct—including offering or attempting to perform it—is prohibited and classified as a Class A misdemeanor. Arkansas supplies injunction and receivership remedies but no ordinary debt-adjuster licensing pathway. Justia Law+2
4. A qualifying nonprofit organization is excluded only when it provides “debt management service” free or charges no more than its actual expenses incurred in offering the service. Arkansas supplies no fixed dollar amount, percentage schedule, CPI adjustment, setup fee, monthly fee, settlement fee, or savings-fee formula for that exclusion. Justia Law
5. A purely noncustodial negotiation model—consumer pays creditors directly and the provider never receives or controls settlement funds—may fall outside the literal receipt element of § 5-63-301(2)(B), but no controlling Arkansas decision or official interpretation resolving that question was located. That is a legal-classification hold, not verified permission to launch or charge fees.
6. Other licenses—money transmission, currency exchange, mortgage, collection-agency, or similar—do not convert activity prohibited by § 5-63-302 into licensed debt adjusting. The public Arkansas Securities Department/NMLS routes reviewed cover other stated license categories, not debt adjusting. Arkansas Securities Department+1

A. Substantive answers

1. Current Arkansas definitions and classifications

1.1 Statutory definition

Arkansas Code § 5-63-301 uses two distinct operative branches:

Branch A — periodic payment and distribution model. A debtor contracts with a person, agrees to pay that person periodically, and the person—for consideration—agrees to distribute or distributes the money among specified creditors under an agreed plan. This language directly captures the classic custodial debt-management plan or consolidated-payment model. It does not require principal reduction or even creditor concessions. S_AR-P1-C001–C004. Justia Law

Branch B — settlement/intermediation plus receipt model. A person holds itself out, for consideration, as an intermediary between a debtor and creditors to settle, compound, or otherwise alter payment terms and, to that end, receives money or property from or for the debtor for payment to or distribution among creditors. This directly captures a custodial settlement model. S_AR-P1-C005–C007. Justia Law

A “debt adjuster” includes a person who engages, attempts to engage, or offers to engage in debt adjusting. The prohibition separately covers engaging, offering, and attempting. Consequently, the analysis is not limited to completed settlements or completed receipt of funds. S_AR-P1-C008. Justia Law+1

1.2 Classification matrix

1.3 Principal reduction versus concessions and distribution

Arkansas does not divide coverage according to the marketing term “settlement,” “DMP,” “credit counseling,” or “consolidation.”

• A plan that merely collects one payment and distributes it may fit Branch A, even when creditors make no concessions.
• An interest-rate reduction, fee waiver, extended term, or lower payment can fit Branch B’s language concerning alteration of payment terms.
• A principal-reduction settlement fits Branch B when the provider also receives debtor money or property for payment or distribution.
• Calling a service “financial coaching,” “legal support,” “credit restoration,” or “account administration” does not change the underlying functional elements. S_AR-P1-C003–C008.

The Arkansas Attorney General’s consumer page also distinguishes counseling/DMPs from settlement services and warns about advance charges and requiring payments before creditor acceptance, but that page is consumer guidance—not a license, fee schedule, or authoritative expansion of the statute. S_AR-P1-C029. Arkansas Attorney General

1.4 Custodial versus noncustodial models

The custody issue is material because § 5-63-301(2)(B) does not end after describing negotiation. It adds that the intermediary “receives money or other property” for payment or distribution to creditors. Justia Law

Accordingly:

• Provider bank account or provider-controlled trust account: strong coverage indication.
• Provider collects monthly consumer funds and remits them: covered under Branch A and often Branch B.
• Independent account in the consumer’s name: not automatically outside Arkansas law. The result can turn on withdrawal authority, payment-direction powers, contractual control, fee deductions, affiliation, and whether the provider or its agent effectively receives the property.
• Direct consumer-to-creditor payment: strongest textual argument against the receipt element, but there is no verified Arkansas safe harbor or agency approval for that model.
• Provider receives only its own fee: this may not be receipt of money “for the payment to or distribution among” creditors, but no Arkansas controlling decision located in this pass resolves whether the entire arrangement, related entities, or payment flow nevertheless satisfies the definition.

No launch conclusion should be based solely on moving money through a nominally independent account.

1.5 Consumer versus business-purpose debt

The debt-adjusting subchapter defines “debtor” as an individual, including jointly or severally indebted individuals. It does not contain a personal, family, or household-purpose limitation. Justia Law

The best bounded textual reading is therefore:

• An individual’s business-purpose debt can fall within the statute.
• A sole proprietor is still an individual.
• A corporation or LLC, standing alone, is not an “individual.”
• An owner’s personal guaranty or joint liability can create an individual debtor even if the underlying loan financed business activity.
• No controlling Arkansas decision resolving mixed individual/entity obligations under this subchapter was located.

That differs from Arkansas’s separate credit-repair statute, whose “extension of credit” definition is tied primarily to personal, family, or household purposes. Justia Law

1.6 Arkansas resident and remote-provider nexus

Section 5-63-302 prohibits debt adjusting “in this state.” Arkansas’s general territorial criminal statute permits conviction where conduct or a result that is an element occurs in Arkansas or where outside conduct constitutes an attempt to commit an offense within Arkansas. S_AR-P1-C013. Justia Law+1

Therefore, an out-of-state office is not a categorical safe harbor. Conduct involving an Arkansas debtor, an Arkansas-directed offer, communications performed into Arkansas, an Arkansas execution or payment event, or fund flows involving Arkansas can create material exposure.

However, this pass did not locate a controlling Arkansas case deciding precisely whether any one of the following, standing alone, is sufficient under this offense:

• a nationally available website viewed by an Arkansas resident;
• an inbound Arkansas consumer call;
• remote contract execution;
• payments initiated from Arkansas;
• an out-of-state provider’s negotiation with an out-of-state creditor.

Those questions remain a case-law and fact-pattern hold. Act 736 of 2023 amended § 5-1-104(a)(6), but the more immediately relevant general paths for this offense remain § 5-1-104(a)(1)–(2). Arkansas Legislature+1

2. Prohibition, authorization, and exclusions

2.1 Covered debt adjusting is prohibited, not ordinarily licensed

Arkansas Code § 5-63-302 states that a person shall not engage in, offer to engage in, or attempt to engage in debt adjusting in Arkansas. Violation is a Class A misdemeanor. Official Act 1263 of 2015 placed the penalty in § 302 and repealed former § 304’s duplicative penalty section. S_AR-P1-C014–C016. Justia Law+1

This architecture matters:

A separate financial-services license cannot be treated as authorization to perform conduct that § 5-63-302 prohibits.

The Attorney General or a prosecuting attorney may seek an injunction. The circuit court may appoint a receiver over money and property used in the business to facilitate return of debtor money not paid to creditors. S_AR-P1-C017. Justia Law

2.2 Statutory exclusions

Section 5-63-305 says the following persons are “not considered a debt adjuster” for this subchapter:

These are exclusions from the debt-adjuster classification, not an ordinary licensing program. S_AR-P1-C018–C023. Justia Law

2.3 Attorney connection is not presumed sufficient

The statute identifies “an attorney at law”; it does not expressly identify:

• a nonlawyer debt-settlement company owned by or affiliated with an attorney;
• a national marketing company that assigns consumers to local attorneys;
• a lead generator;
• an account administrator;
• an operations vendor;
• a law-firm-branded management company;
• nonlawyer negotiators supervised only nominally by counsel.

No controlling Arkansas case or formal Attorney General opinion was located defining the exclusion’s treatment of those structures. An actual attorney’s inclusion in a workflow therefore should not be represented as established blanket permission. S_AR-P1-C022, C030.

Separately, the federal TSR does not provide a general attorney exemption for covered interstate telemarketing. The FTC’s guidance states that attorneys may fall outside the TSR for fact-specific reasons, such as no interstate telemarketing or a qualifying face-to-face transaction, but not merely because they are attorneys. Federal Trade Commission

2.4 Nonprofit status is not enough

The nonprofit exclusion has at least three cumulative textual elements:

1. The provider must be a nonprofit organization.
2. It must be giving “debt management service.”
3. The service must be free or its fee must not exceed actual expenses incurred in offering it.

The reviewed statute does not define “debt management service,” prescribe an expense-accounting method, identify permitted overhead allocations, or state that a nonprofit principal-reduction settlement program qualifies. No responsive rule or controlling interpretation was located. S_AR-P1-C018–C021.

2.5 Self-creditor and institutional boundaries

A creditor working out its own receivable is ordinarily not an intermediary “between a debtor and the debtor’s creditors.” That is a textual noncoverage conclusion rather than an express § 305 exclusion. The result becomes less certain when the negotiator is a servicer, affiliate, purchaser, common-control entity, or separate fee-taking company. S_AR-P1-C010.

Likewise, a bank or fiduciary exclusion should not be extended to an unregulated affiliate merely because a bank account, lending institution, or trust company appears somewhere in the payment chain.

3. Applicable fee structures and current limits

3.1 Arkansas debt-adjusting fee results

The only express debt-adjusting fee formula found is the nonprofit exclusion’s actual-expenses limit. S_AR-P1-C024–C027. Justia Law

3.2 No verified fixed or indexed amount

No reviewed current Arkansas debt-adjusting source establishes:

• a maximum enrollment or setup fee;
• a maximum monthly maintenance fee;
• a percentage of payments;
• a percentage of enrolled debt;
• a percentage of settled debt;
• a percentage of savings;
• a per-creditor or per-account charge;
• an aggregate program cap;
• a CPI-linked amount;
• an annual regulator adjustment.

Accordingly, no dollar amount should be calculated by analogy to another state, a trade-association chart, an old multistate table, or a guessed CPI adjustment.

3.3 Meaning and limitations of “actual expenses incurred”

The statute does not specify:

• cash basis versus accrual basis;
• direct costs versus indirect overhead;
• organization-wide versus Arkansas-client allocation;
• treatment of advertising, lead costs, fundraising, executive pay, affiliate charges, or reserves;
• whether expenses may be collected prospectively and later reconciled;
• documentation required;
• treatment at early cancellation;
• timing of refunds or credits.

The safest bounded interpretation is that the nonprofit cannot retain more than actual expenses properly attributable to offering the debt-management service. But the exact accounting methodology and legal consequence of temporary overcollection remain unresolved. S_AR-P1-C019–C020, C025–C027.

3.4 Arkansas Attorney General “nominal fee” language

The Attorney General’s consumer page warns consumers about an organization that charges more than a nominal fee before settling debts. That statement is not an Arkansas statutory fee schedule, does not define “nominal,” and cannot authorize an advance charge that another law prohibits. S_AR-P1-C029. Arkansas Attorney General

3.5 Separate credit-repair overlap

A debt-relief provider can also enter Arkansas’s Credit Repair Services Organizations Act if, for consideration, it represents that it will improve credit history/rating, obtain credit, locate a lender, or provide related advice concerning covered consumer credit. That statute has its own exclusions and requirements. Justia Law+1

Under § 4-91-202(e)(1), a covered credit-repair organization may not charge or receive consideration before complete performance unless it both:

• obtains a $10,000 surety bond; and
• establishes a federally insured trust account at an Arkansas state or national bank or savings and loan association.

The contract has a five-day cancellation provision, and the statutory notice states that payments must be returned within ten days after receipt of a cancellation notice. S_AR-P1-C028. Justia Law+1

This credit-repair provision does not authorize debt adjusting prohibited by § 5-63-302. It is a separate cumulative overlay when its own definition is met.

4. When fees may be requested or received

4.1 Arkansas state-law timing

Covered for-profit debt adjusting: There is no verified lawful point at which a provider can begin charging for covered prohibited conduct. The issue is prohibition, not merely premature collection.

Qualifying nonprofit: Section 5-63-305(6) supplies no express enrollment, monthly-service, creditor-acceptance, settlement, consumer-payment, or completion trigger. It states only that the fee may not exceed actual expenses incurred. “Incurred” places a substantive ceiling on retained charges, but the statute does not supply an exact prepayment, reconciliation, cancellation, or refund timetable. S_AR-P1-C024–C027.

Attorney and other exclusions: Section 5-63-305 does not supply their fee timing. Separate professional-conduct, fiduciary, contract, consumer-protection, banking, or other law must be evaluated in later passes.

4.2 Federal TSR baseline—only when independently applicable

The federal TSR defines “debt relief service” broadly to include programs represented to renegotiate, settle, or alter the terms of unsecured debt, including balance, interest, or fees. eCFR

Where the TSR applies, 16 C.F.R. § 310.4(a)(5) prohibits requesting or receiving a fee until all three conditions are met for at least one debt:

1. The provider has renegotiated, settled, reduced, or otherwise altered the debt under a valid agreement executed by the customer.
2. The customer has made at least one payment under that agreement.
3. For debts resolved individually, the fee is allocated either proportionally by enrolled debt or through a uniform percentage-of-savings method. eCFR+1

The savings base is:

Savings=amount owed when enrolled−amount actually paid to satisfy the debt\text{Savings}=\text{amount owed when enrolled}-\text{amount actually paid to satisfy the debt}Savings=amount owed when enrolled−amount actually paid to satisfy the debtThe percentage charged under that method cannot vary from one individual debt to another. eCFR

The inbound-call exemption generally does not protect calls made in response to advertisements for debt-relief services. eCFR

4.3 Federal dedicated-account requirements

The TSR permits requiring money to be placed in a dedicated account only if:

• the account is at an insured financial institution;
• the customer owns the funds and receives accrued interest, if any;
• the administrator is not owned, controlled by, or affiliated with the debt-relief provider;
• the administrator does not give or receive compensation for debt-relief referrals; and
• the customer can withdraw without penalty and receive all funds other than properly earned fees within seven business days. eCFR

Those federal conditions do not decide whether a payment arrangement constitutes “receives money or other property” under Arkansas’s criminal statute.

4.4 State permission and federal timing must stay separate

Compliance with federal performance-based timing does not cure Arkansas’s state prohibition. Conversely, a state exclusion or state-law fee ceiling does not authorize advance fees prohibited by federal law.

The proper order is:

1. Determine whether Arkansas prohibits, excludes, or does not cover the model.
2. Determine whether other Arkansas laws apply.
3. Determine independently whether the federal TSR applies.
4. Apply the strictest cumulative conditions.

5. Regulator permission, lookup, and application status

5.1 No debt-adjuster application or registry located

No public Arkansas application, registration, license type, or provider registry was located for ordinary commercial debt adjusting under §§ 5-63-301–305. The statutory framework itself establishes a prohibition and conditional exclusions, not a license. S_AR-P1-C014–C018, C031.

The reviewed Arkansas Securities Department pages identify public pathways for securities, mortgage activities, money transmitters, and currency exchangers. The NMLS page states that its money-services application and public lookup concern money transmitters and currency exchangers; it does not identify debt adjusting as an NMLS license category. Arkansas Securities Department+1

5.2 Public route results

The official Code of Arkansas Rules database states that it became the official online codification on January 1, 2025, is updated weekly, may lag recent rulemaking, and was last updated October 19, 2026. Targeted public searches for debt adjusting, debt adjuster, debt settlement, and related phrases returned unrelated provisions rather than an operative provider rule. S_AR-P1-C030–C031. Code of Arkansas Rules+2

5.3 Named-provider status

No named provider was submitted for verification, and this pass did not test a named company against corporate, charitable, attorney, money-services, or collection-agency records.

A company’s website statement that it is “licensed,” “accredited,” “attorney backed,” “compliant,” or “available in Arkansas” is not proof of Arkansas debt-adjusting authorization.

B. Source table

Unless otherwise stated, each source was accessed or attempted on October 24, 2026, Pacific time.

C. Claim table

D. Worked examples and component coverage

Example 1 — Covered custodial DMP; no lawful commercial fee calculation

Inputs

• Consumer sends provider: $600 per month
• Creditors: 4
• Proposed setup fee: $50
• Proposed monthly fee: $35
• Provider distributes the remaining money among the creditors

Base

Periodic consumer money delivered to the provider for distribution.

Operator

§ 5-63-301(2)(A) classification, followed by § 5-63-302 prohibition.

Intermediate

• Periodic payment to provider: yes
• Distribution among specified creditors: yes
• Consideration: yes
• Express/implied plan: yes

Result

The model is covered debt adjusting and prohibited unless an actual statutory exclusion applies. The calculation is not “maximum fee = $0.” The legally important result is that no lawful commercial fee pathway was established for the covered activity.

Units/rounding

Dollars and dollars/month; no rounding issue.

Claims

C001–C004, C014–C016, C024.

Example 2 — Custodial settlement with a 20% proposed fee

Inputs

• Debt A: $5,000
• Debt B: $10,000
• Debt C: $15,000
• Total enrolled debt: $30,000
• Proposed fee: 20% of enrolled debt
• Provider receives consumer settlement funds and pays creditors

Arithmetic

$30,000×20%=$6,000$30{,}000 \times 20% = $6{,}000$30,000×20%=$6,000Base

Enrolled debt.

Operator

Multiplication by 0.20.

Intermediate

Proposed commercial fee = $6,000.

Legal result

The arithmetic does not establish a collectible Arkansas fee. Because the provider acts as intermediary and receives money for creditor payment, the model fits § 5-63-301(2)(B) and is prohibited absent an exclusion.

Units/rounding

Dollars; rounded to nearest cent: $6,000.00.

Claims

C005, C014, C024.

Example 3 — Qualifying nonprofit DMP; actual-expense ceiling

Assumptions

• The organization is genuinely nonprofit.
• The service qualifies as “debt management service.”
• No other disqualifying fact exists.
• The stated costs are properly attributable actual expenses.

Inputs

• Intake expense: $40
• Monthly servicing expense: $18
• Service duration: 6 months
• Proposed setup charge: $35
• Proposed monthly charge: $20

Actual-expense computation

$40+(6×$18)=$148$40 + (6 \times $18)=$148$40+(6×$18)=$148Proposed-charge computation

$35+(6×$20)=$155$35 + (6 \times $20)=$155$35+(6×$20)=$155Difference

$155−$148=$7$155-$148=$7$155−$148=$7Result

Under the stated assumptions, $148 is the maximum amount supported by the statutory actual-expense formula. The proposed $155 exceeds that amount by $7.

Boundary

Arkansas does not state how the expenses must be allocated, documented, accrued, or reconciled. The example demonstrates the statutory formula; it does not approve these specific expense categories.

Units/rounding

Dollars; nearest cent.

Claims

C019–C020, C025–C027.

Example 4 — Lower-debt nonprofit case

Inputs

• Consumer debt: $1,000
• Proposed fee: 5% of debt
• Actual qualifying expense: $40

Percentage result

$1,000×5%=$50$1{,}000 \times 5%=$50$1,000×5%=$50Statutory comparison

min⁡($50,$40)=$40\min($50,$40)=$40min($50,$40)=$40Result

The debt-based percentage does not set the Arkansas limit. Under the assumptions, the actual-expense ceiling would be $40, so $10 of the proposed $50 would exceed it.

Claims

C025–C027.

Example 5 — Cancellation or early termination after prior collection

Assumptions

• The nonprofit exclusion applies.
• Consumer paid $100 before cancellation.
• Properly attributable actual expenses incurred through cancellation equal $72.

Computation

$100−$72=$28$100-$72=$28$100−$72=$28Result

At least $28 cannot be retained within the § 5-63-305(6) actual-expense condition on those assumptions.

Unresolved point

The debt-adjusting subchapter does not state a refund deadline, reconciliation date, credit method, or notice procedure. This example does not import the separate credit-repair statute’s ten-day deadline unless the provider independently meets that statute’s definition.

Claims

C019, C025–C028.

Example 6 — Pure noncustodial settlement model

Facts

• Provider negotiates with creditors.
• Consumer pays each creditor directly.
• Provider never receives, holds, directs, or controls money for creditors.
• Provider charges only its own performance fee.

Classification steps

1. Branch A: no periodic money is paid to the provider for distribution.
2. Branch B: provider is an intermediary for consideration, but the express receipt-for-payment/distribution element may be absent.
3. No controlling Arkansas interpretation was located.
4. No ordinary license or state fee authorization was located.

Result

Classification and fee chargeability held. This is not a verified lawful Arkansas scenario.

Claims

C006–C007, C024, C030–C031.

Example 7 — Federal proportional allocation, assuming the TSR applies

This calculation supplies only the federal allocation result; it does not override Arkansas law.

Inputs

• Debt A: $5,000
• Total enrolled debt: $30,000
• Total contracted fee: $6,000

Operator

Debt A share=$5,000$30,000\text{Debt A share}=\frac{$5{,}000}{$30{,}000}Debt A share=$30,000$5,000​Fee share=$5,000$30,000×$6,000\text{Fee share}=\frac{$5{,}000}{$30{,}000}\times $6{,}000Fee share=$30,000$5,000​×$6,000Result

$1,000$1{,}000$1,000The $1,000 cannot be requested or received merely because the debt was enrolled. The provider must first achieve a valid agreement for that debt and the customer must make at least one payment under it.

Units/rounding

Dollars; $1,000.00 to nearest cent.

Arkansas condition

If the underlying model is covered prohibited Arkansas debt adjusting, satisfying the federal trigger still does not authorize the fee.

Claims

C024, C033–C035.

Example 8 — Federal percentage-of-savings calculation

Inputs

• Amount owed when enrolled: $4,000
• Amount actually paid to satisfy: $2,500
• Uniform savings fee percentage: 25%

Savings

$4,000−$2,500=$1,500$4{,}000-$2{,}500=$1{,}500$4,000−$2,500=$1,500Fee

$1,500×25%=$375$1{,}500\times25%=$375$1,500×25%=$375Result

Federal calculated fee = $375 after the TSR performance conditions are met.

Limitations

• The 25% rate must not change from one individual debt to another under that method.
• The calculation is not an Arkansas fee authorization.
• The underlying model’s Arkansas classification must first be resolved.

Claims

C024, C033–C035.

Example 9 — Business-purpose and entity-debt boundary

Scenario A

A sole proprietor personally owes $50,000 used for business inventory.

Result

The debtor is an individual; the absence of a household-purpose element means the debt can textually fall within § 5-63-301.

Scenario B

An LLC alone owes $50,000, with no personal guaranty or individual joint liability.

Result

The entity does not fit the literal definition of “debtor” as an individual.

Scenario C

The LLC owes the debt and the owner personally guarantees it.

Result

The individual guarantor can be a debtor with respect to the personal obligation. Exact coverage depends on the contract and service provided.

Claims

C011–C012.

Pass coverage and gap table

E. Researcher self-check

Actually read or directly inspected

• The displayed 2025 text of Arkansas Code §§ 5-63-301, 5-63-302, 5-63-303, and 5-63-305.
• Official Act 1263 of 2015, including the page amending § 5-63-302 and repealing § 5-63-304.
• The displayed 2025 text of Arkansas’s territorial-applicability statute, § 5-1-104.
• Official Act 736 of 2023’s amendment to § 5-1-104(a)(6).
• The official Arkansas legislative homepage and 2026 session status.
• The official Code of Arkansas Rules database description and targeted public search results.
• The Arkansas Attorney General debt-relief consumer page.
• Arkansas Securities Department and its NMLS money-services page.
• Arkansas Code § 4-91-202 for the limited credit-repair overlap.
• Current eCFR text for 16 C.F.R. §§ 310.2, 310.4, and 310.6, displayed current through October 22, 2026.
• FTC debt-relief TSR guide and staff Q&A.
• Targeted public searches for Arkansas cases and Attorney General opinions.

Not read or not fully obtained

• A current official Arkansas Code rendering from the state code portal; that route returned an access barrier. The core text was therefore checked through the 2025 secondary codification, the official 2015 enactment, official session materials, and targeted amendment searches.
• Original scans of Acts 61 of 1967 and 189 of 1983. The official historic-legislation page states that electronic copies are unavailable through that site/BLR.
• Subscription annotations, citator treatment, unpublished trial-court orders, sealed matters, or complete enforcement-file databases.
• Full direct content of the Arkansas collection-agency pages; discovered routes returned access errors during direct opening.
• Any private provider records, application file, privileged legal analysis, borrower record, or authenticated regulator account.
• Any provider-specific corporate, charitable, attorney, collection, money-services, or other status, because no named provider was submitted.
• The later-required agreement, funds, bonds, remedies, litigation, limitations, secured-debt, sector, local, tribal, contract, and comprehensive case-law passes.

Currentness qualification

The core prohibition and exclusion text has high currentness confidence, supported by the 2025 codification, official enactment, official 2026 session context, and targeted official searches. It is not represented as absolute official-code verification because the state’s current-code portal was inaccessible and the amendment-index interface did not yield a clean machine-readable confirmation for every section.

No future-effective, proposed, stayed, vacated, withdrawn, or expired Arkansas debt-adjusting amendment was located in this pass. That is a bounded public-search result, not a guarantee that no unindexed or very recent material exists.

This report is the completed Arkansas provider-market-access and consumer-fees component with stated holds. It is not the full Arkansas dossier, not a provider authorization, not a qualified legal opinion, not an independent review, and not a claim of local saving or publication readiness.

END S_AR PASS-01.