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

S_CO PASS-01 — Colorado provider market access and consumer fees

Baseline: October 22, 2026, Pacific. Actual access: October 22, 2026, PDT, corresponding to October 23, 2026, UTC.

Finding: Colorado establishes a registration pathway for covered debt-management providers, including concession-based debt management plans and principal-reduction settlement. Coverage turns on the actual intermediary services, compensation, customer, and relationship—not the marketing label or whether the provider holds consumer funds. The current statute directly verifies the DMP dollar limits, settlement performance triggers, completed-plan aggregate protection, and several refund and anti-evasion requirements. Colorado Revised Statutes 2026+2

Three material matters remain held: the full official text of the March 30, 2025 rule; the dated administrative instrument establishing today’s provider registration fees; and any named provider’s actual registration status. Those limitations affect the conclusions identified below. This component does not establish SettleADebt.com’s authorization, complete the Colorado dossier, or imply state or A066 acceptance.

For readability, S001 means S_CO-P1-S001, and C001 means S_CO-P1-C001. The source and claim tables give the full identifiers.

A. Substantive findings

1. Classification: what conduct Colorado regulates

The governing statute is the Colorado Uniform Debt-Management Services Act, C.R.S. Title 5, Article 19, Part 2.

Under §5-19-202(8), debt-management services involve acting as an intermediary between an individual and one or more creditors to obtain concessions. “Concessions” are repayment terms more favorable than the original credit contract. A provider includes someone who provides, offers, or agrees to provide those services, directly or through others. An “individual” is a natural person. [C001–C002; S001, §202(6), (8), (11), (15)]

[C002–C006; S001, §§114, 202, 203, 223; S010, p. 9.] The statute and current application support the custody distinction directly. Colorado Revised Statutes 2026+2

Consumer versus business purpose

The statutory customer definition focuses on natural persons. Section 203(b)(3) separately excludes a provider to the extent it provides debt-management services only to persons who incurred debt in the conduct of business. A business-owner label does not establish that a particular personal credit-card balance was incurred in business. Mixed-purpose debts, personal guarantees, and a provider serving both consumer and business segments require factual analysis. [C004]

Colorado resident and remote-provider nexus

Section 204(a) requires registration when the provider reasonably should know the individual resides in Colorado when it agrees to provide services. Sections 203(a) and 203(b)(1) address agreements or services where the provider has no reason to know of Colorado residence at the relevant agreement time.

An out-of-state office does not eliminate that nexus. Section 206(3) expressly allows an application stating that the applicant has no Colorado service location. Section 206.7 separately permits registered-provider employees to work remotely under specified privacy, supervision, record-access, and location safeguards. [C003; S001, §§203–204, 206(3), 206.7.] Colorado Revised Statutes 2026+1

2. Market access, exclusions, and failure cases

Ordinary covered providers: registration is legally available and required

The legal pathway comes from §§204–212, not from an agency webpage’s description of its programs. The administrator is the assistant attorney general designated under §5-6-103; operational administration is through the Colorado Department of Law’s Consumer Credit Unit. [C001, C012–C015]

Covered for-profit and nonprofit providers can use that registration pathway. Neither principal-reduction settlement nor noncustodial operation is categorically prohibited by the provisions reviewed. Operating without required registration is prohibited; an application alone is insufficient.

Applications must satisfy §§205–206, including prescribed information, fees, applicable entity qualifications, financial-responsibility documents, and other supporting materials. Section 209 provides substantive issuance and denial standards. It also allows a regulator-issued temporary certificate, for no more than 120 days, in the specified delayed-criminal-record-check circumstances. Section 210’s agency decision deadline does not create automatic approval: the remedy for failure to act is an appeal/hearing request. [C013]

Registration also does not authorize every proposed plan. Section 217 requires personal-finance education and financial analysis; for regular periodic payments, it additionally requires a plan, a suitability and ability-to-pay determination, and a belief that participating creditors will accept the planned payments. [C017] Colorado Revised Statutes 2026+2

Exclusions must fit the actual activity and entity

[C007–C012; S001, §§202–204, 209, 212; S013.] Colorado Revised Statutes 2026+3

In Coffman, the Colorado Supreme Court rejected an exemption theory involving a company whose purported attorney relationship did not provide meaningful attorney direction and supervision. Its discussion of the original statute must be distinguished from the amended statute’s express employee condition. [C008; S013, ¶¶31–40 and footnote 4.]

An exclusion from Part 2 does not establish unrestricted fees, authority to practice law, or exemption from independently applicable federal law.

3. Consumer fee structures, amounts, indexing, and refunds

Verified statutory amounts and restrictions

[C018–C028; S001, §§223–224, 228.] Colorado Revised Statutes 2026+1

The 2025 rule: corroborated provisions, with an explicit primary-text hold

The Secretary of State’s official index and docket identify a permanent 4 CCR 902-2 rule adopted February 7, 2025, published March 10, 2025, and effective March 30, 2025. The docket explains that the administrator considered fee caps but chose to retain the former statutory fee structure in regulation. [C034; S004–S005]

The official adopted DOCX and basis-and-purpose attachment could not be successfully read. The current official PDF link did not yield a usable current document through the available retrieval route. I did read the full Cornell reproduction of Rule 4, which reports:

• Proportional allocation of a total fee using enrollment-date debt amounts, or a fixed percentage of savings measured against enrollment-date debt.
• The same savings percentage from one debt to another.
• A standalone education/counseling provision of up to $100, with administrator approval for a larger amount.
• A refund if the individual enters an agreement before 90 days after completion or termination of those educational services.

These are reported as corroborated reproduction text, not as fully verified operative Colorado rule text. The reproduction’s refund clause also retains a reference to “subsection (d)(4),” although that statutory provision was repealed and Rule 4 has no corresponding subsection. I have not silently repaired that cross-reference or determined its legal consequence. The standalone $100 pathway and its refund implementation remain held. [C022, C024] sos.state.co.us+2

The state performance triggers and aggregate protection remain independently verified in the statute. Federal allocation rules, where applicable, are independently verified below.

Historical amounts and CPI reconciliation

[C032–C034; S003–S008, S014–S017, S020.] No CPI calculation has been invented. Colorado General Assembly+4

4. When fees may actually be requested or received

Colorado conditions

General gate: §223(b) prohibits imposing charges or receiving payment for debt-management services before the provider and individual sign an agreement complying with §§219 and 228. Required advance disclosure of a fee schedule under §217 is distinct from demanding payment. [C018]

DMP: The state statute permits the specified setup and monthly fee structure for the applicable concession plan after the agreement requirement is met. It does not impose §223(d)(2)’s settlement-specific performance trigger on §223(d)(1). That distinction does not displace federal timing where applicable. [C019]

Principal-reduction settlement: Before requesting or receiving any fee or consideration:

1. The provider must have settled at least one debt under a valid agreement executed by the individual.
2. The individual must have made at least one payment under that agreement with the creditor or collector.
3. The fee must satisfy the applicable administrator rules.

A provider contract, negotiated offer not accepted by the consumer, deposit into savings, or payment to the provider alone does not satisfy those stated conditions. Full payment of the settlement is not the statutory first-payment trigger, although final savings calculations can require additional facts. [C020–C022] Colorado Revised Statutes 2026

Federal TSR: common context, separately applicable

For covered telemarketing, 16 CFR §310.4(a)(5)(i) independently requires an executed agreement changing at least one debt’s terms, at least one payment under that agreement, and the prescribed proportional or savings-based allocation for individually resolved debts.

The federal definition reaches services represented as changing unsecured-creditor or debt-collector obligations, including interest and fees. Covered inbound calls responding to debt-relief advertising or direct mail do not receive the ordinary exemptions for those categories of inbound calls. Applicability still requires the federal jurisdictional and transactional analysis; it is not established merely because a business provides Colorado services. [C035–C036]

Consequently, Colorado’s $50 DMP setup ceiling is not federal permission to collect $50 at signup. The FTC’s guidance also distinguishes bona fide nonprofits from falsely claimed nonprofit status and supplies no general debt-relief attorney exemption. ecfr.gov+3

Deposits are not earned fees

Colorado §202(20)(B) and federal §310.4(a)(5)(ii) recognize qualifying dedicated accounts: insured institution, consumer ownership and interest, independent administrator, no specified referral compensation, and withdrawal protection. Funds in such an account are not thereby provider revenue.

Colorado requires immediate return of the relevant consumer funds on withdrawal/termination, subject to properly earned fees; the federal account provision supplies its own seven-business-day return requirement. The federal period does not relax the Colorado requirement. [C030, C037]

Cancellation and termination

• Three-business-day cancellation: §220 provides cancellation and the prescribed notice promises refund of all money paid. Specified agreement defects extend the cancellation period to 30 days.
• Emergency waiver: The narrow statutory waiver requires a signed, dated statement in the consumer’s own words describing the financial emergency; a standard-form waiver is void.
• Later termination: The consumer may terminate without penalty or obligation. Unexpended debt funds and consumer trust funds must be returned under the relevant provisions. Later termination does not automatically require return of every fee already lawfully earned and paid.
• Failed plans: §222(h) requires prompt return of money not paid to creditors, less fees actually payable under §223. No universal rule requiring refund of an otherwise earned settlement fee after a later installment default was established in this pass.

[C029–C031, C037; S001, §§202(20)(B), 219(d), 220, 222(h), 226(b), 228(a)(4).] Colorado Revised Statutes 2026+3

5. Actual application, renewal, lookup, and legal status

The current AG registration page links an actual 33-page application and instructions, with a filename ending 10.26.pdf. Its instructions provide an initial application route by completed PDF submitted to the Department of Law; renewals use the licensing portal. Page 9 expressly distinguishes providers that hold funds, do not hold or arrange third-party accounts, and do not hold funds but arrange or suggest those accounts. [C015; S009–S010]

The observed current administrative charges are:

These are provider administrative charges, not additional consumer fees. Sections 205(b)(1) and 232(e) supply fee-setting authority. The exact dated instrument setting these amounts was not found; therefore the current operational amounts are verified, while their precise change/effective-date chain remains held. The older Rule 1’s $1,000 figure does not establish today’s application amount. [C015] Colorado Attorney General+2

Registrations renew annually by July 1. A timely, complete renewal with the required fee preserves registration while the application is pending under §211(d); failure to file the complete application and fee by July 1 causes automatic expiration under §211(f). The AG warns that a displayed prior July 1 expiration may reflect a pending renewal. Neither a stale displayed date nor the provider’s assertion alone resolves actual status. [C014]

The actual public-report route is:

https://licensing.coag.gov/s/public-reports

That route returned a loading/CSS error during this research. This is an access failure, not a no-match result and not proof that the registry is universally unavailable. No named provider’s registration, activity category, renewal, or disciplinary status was established. [C016]

The statute is currently operative in the 2026 compilation; §242 schedules repeal for September 1, 2035. That future repeal is not a present expiration. [C001]

6–7. Worked examples and component coverage

The calculations appear in D.1. The full component coverage and exact next investigations appear in D.2. They preserve the distinction between verified limits, conditional calculations, and unresolved permission.

B. Source table

Access code A: actually accessed or attempted October 22, 2026, PDT / October 23, 2026, UTC. “Read” means operative content was retrieved, not merely a title or search snippet.

C. Claim table

“Verified” refers to the identified legal text or operational evidence, not approval of an unseen business model.

D. Worked examples and coverage

D.1 Bounded plain-text examples

All figures are hypothetical U.S. dollars. Each calculation is exact to whole dollars; no rounding is required. A numerical result does not establish registration, plan suitability, consumer assent, service performance, or other required conditions.

Example 1 — Lower-debt DMP

Inputs: $1,000 enrolled debt; two creditors remain when the monthly fee is assessed.

Base: remaining creditors, not debt dollars.

Operator: minimum of ($10 × 2) and $50.

Intermediate: $10 × 2 = $20.

Result: statutory monthly ceiling = $20. Setup ceiling = $50, separately.

Conditions: applicable §223(d)(1) plan, suitable payment obligations, compliant agreement, lawful services, and any federal timing satisfied. This does not mean a $50 setup fee is automatically payable at signup. [C017–C019, C036]

Example 2 — DMP creditor count changes

Inputs: six creditors remain in month 1; three remain in month 2.

Month 1: min($10 × 6, $50) = min($60, $50) = $50.

Month 2: min($10 × 3, $50) = min($30, $50) = $30.

The original six-creditor count cannot support another $50 monthly assessment after only three remain. Counting six accounts held by three creditors would also require the statutory creditor measure, not automatic account multiplication. [C019]

Example 3 — Partial settlement under the verified federal proportional method

Assumptions: TSR applies; enrolled debts total $20,000; the hypothetical contract’s total fee is 20% of enrolled debt. 20% is an example rate, not a Colorado ceiling.

Inputs: debt A = $5,000; debt B = $15,000.

Total contract fee: $20,000 × 0.20 = $4,000.

A’s proportion: $5,000 ÷ $20,000 = 0.25.

A’s allocated fee: $4,000 × 0.25 = $1,000.

If A has the required executed settlement and creditor payment but B remains unresolved, the first resolution does not support collecting the entire $4,000. If $500 of A’s fee has already been lawfully collected, the remaining A allocation is $1,000 − $500 = $500.

This verifies the federal arithmetic and performance boundary. Colorado Rule 4’s official-text comparison remains a hold before approving the fee schedule. [C020–C022, C036]

Example 4 — Savings fee uses the correct base

Assumptions: TSR applies; a hypothetical 25% savings rate; the debt has been fully satisfied, so the actual satisfaction amount is known.

Inputs: enrollment debt = $5,000; later displayed balance = $5,800; actual amount paid to satisfy debt = $3,000.

Savings base: $5,000 − $3,000 = $2,000.

Fee arithmetic: $2,000 × 0.25 = $500.

Using the later $5,800 balance would produce $700 and would use the wrong federal base. Using only a first installment of the $3,000 settlement as the satisfaction amount would also overstate savings. The same percentage must apply from debt to debt under this method.

Again, the percentage is hypothetical and Colorado’s full-rule verification remains held. Full payoff is assumed to make this example’s base certain; it is not substituted for the statute’s first-payment trigger. [C020, C022, C036]

Example 5 — Completed-plan aggregate cap with previous fees

Inputs: agreement-date principal = $20,000; aggregate settlement offers obtained = $17,000; all consumer obligations completed; $1,000 of fees already paid.

Total fee headroom: $20,000 − $17,000 = $3,000.

Remaining headroom: $3,000 − $1,000 = $2,000.

A contract demanding another $3,000 would exceed this aggregate protection by $1,000. The $2,000 figure is an outer constraint, not independent authorization to collect it; all other fee and timing rules still apply. [C021]

Example 6 — Low debt defeats a larger percentage-based demand

Inputs: agreement-date principal = $1,000; settlement offer = $800; all consumer obligations completed; hypothetical fee = 25% of $1,000.

Proposed fee: $1,000 × 0.25 = $250.

Combined amount: $800 + $250 = $1,050.

Excess: $1,050 − $1,000 = $50.

Maximum aggregate headroom: $1,000 − $800 = $200.

The proposed $250 fee fails the verified state aggregate condition. This example establishes neither a lawful 25% rate nor automatic permission to collect $200. [C021–C022]

Example 7 — Cancellation before any settlement performance

Inputs: $1,500 in consumer funds; no executed creditor settlement; no payment under a creditor settlement; no other properly earned fee.

Settlement fee satisfying the verified state trigger: $0.

Return calculation: $1,500 − $0 = $1,500.

An enrollment charge cannot become earned merely because the consumer accumulated settlement funds. No cancellation penalty is added. [C020, C030, C037]

Example 8 — Three-business-day DMP cancellation

Assumptions: no valid emergency waiver; no creditor disbursement; timely cancellation.

Inputs: $50 setup fee paid; $200 deposited for debt payments.

Refund: $50 + $200 = $250.

This is the statutory early-cancellation example. Later termination requires a different analysis and does not automatically unwind every fee lawfully earned and paid. [C029–C030]

Example 9 — Standalone education: hold rather than presumed permission

Inputs: proposed $80 standalone counseling charge; consumer later signs a plan 60 days after counseling ends.

Boundary arithmetic: 60 days < 90 days; the reproduced Rule 4 would indicate an $80 refund.

Result for this investigation: hold the charging pathway and refund implementation pending the official adopted text and cross-reference comparison. Do not recharacterize the reproduced refund as an optional $80 account credit. [C024]

Example 10 — Noncustodial and nonprofit boundary failures

Noncustodial inputs: an out-of-state company offers to negotiate personal credit-card principal reductions for a Colorado resident; the consumer pays creditors directly.

Classification: intermediary concession services remain potentially covered. Without verified registration, genuine agency under a registered provider, or an applicable exclusion, no lawful fee scenario is established for that company. [C002–C003, C012–C013]

Nonprofit inputs: consumer pays $0; creditor pays provider $50 for the services.

Compensation received: $0 + $50 = $50.

Result: the no-compensation exclusion does not apply merely because the consumer’s charge is zero. [C009]

Example 11 — Own-creditor boundary

Inputs: creditor owns its own $6,000 receivable and directly accepts $4,000 from its debtor; no separate intermediary is involved.

Difference: $6,000 − $4,000 = $2,000.

Classification: the $4,000 is debt satisfaction and the $2,000 is a concession—not, on these assumed facts, a provider settlement fee. The definition-based conclusion does not clear collection, servicing, lending, tax, or assignment issues. [C005]

Example 12 — Dishonor charge cannot be finalized from $25 alone

Inputs: proposed charge $25; reasonable charge on the facts assumed to be $18; other-law limit not yet verified.

Operator: minimum of $18, $25, and the applicable other-law limit.

Result: no more than $18, but exact permissible charge held until the other-law limit is established. [C026]

D.2 Component coverage and exact next investigations

E. Researcher self-check

Actual reading. The research retrieved the relevant 2026 statutory passages, enacted HB24-1380 and SB26-083 provisions, official SOS version and docket records, actual current application instructions, AG operational materials, relevant Coffman passages, official historical legislative materials, and the exact federal TSR provisions materially used. These were not treated as search-snippet evidence.

Material documents not read successfully. The official final 2025 rule attachment and final basis attachment did not yield readable content. The Cornell Rule 4 reproduction was read and expressly identified as secondary. The original 2011 act route failed. The 2011 annual report was read by a parallel research agent, while subsequent synthesis retrieval attempts timed out. No named-provider registry record was obtained.

Version discipline. Current statutes, official current-rule metadata, a secondary rule reproduction, proposed materials, archived rules, historical agency statements, and future repeal dates are separated. Webpage updates and filenames were not used as legal effective dates. The 2026 rule extension was checked without treating it as proof of substantive validity.

Calculation discipline. Examples use explicit bases and operators, preserve the distinction between agreement-date principal and enrollment-date debt, account for previous fees, and show partial-settlement and cancellation boundaries. Hypothetical percentages are not represented as Colorado statutory caps. No CPI adjustment was calculated.

Research mode and action limits. The requested chatgpt.com model selector was not available to verify or change in this session. Research proceeded in the available ordinary-chat environment with parallel task agents within this conversation. No DeepResearch or separate Chat conversations were opened. No application was filed, person contacted, purchase made, account changed, or publication performed.

Component conclusion: The statutory market-access pathway and principal statutory fee constraints are established. The exact current-rule comparison, administrative fee-setting instrument, and provider-specific authorization remain explicit holds. All later Colorado passes remain open.

END S_CO PASS-01