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

S_CT PASS-02 — Connecticut DMP adjustment-fee regulation investigation

Focused scope only: current Connecticut debt-adjustment/DMP consumer-fee regulations and the operative adoption/repeal history needed to determine whether Connecticut currently imposes a numerical DMP fee ceiling.

Research/access date: October 24, 2026, Pacific.

Bottom-line finding

I did not establish a current Connecticut numerical DMP/debt-adjustment fee ceiling from the public official sources retrieved in this pass.

What is affirmatively established is narrower:

1. Pre-agreement individualized credit counseling and budgeting assistance must be provided for $0. That remains an express statutory rule. [S_CT-P2-C001] Connecticut General Assembly+1
2. A debt-adjuster agreement must disclose the services and fees, and the licensee may remit debtor funds to creditors less prorated fees and costs. [S_CT-P2-C002] Connecticut General Assembly
3. The Banking Commissioner has statutory authority to adopt debt-adjustment regulations under §36a-662, but the current statute itself supplies no numerical consumer-fee ceiling other than the zero-dollar counseling requirement. [S_CT-P2-C003] Connecticut General Assembly+1
4. The Department of Banking’s own currently posted regulation-compilation page identifies its June 11, 2014 compilation and enumerates the included consumer-credit regulations. That list includes real-estate-broker fees, small-loan rules, creditor collection practices, and consumer-collection-agency rules, but does not identify a debt-adjuster fee regulation or debt-adjuster-specific regulation series. The Department expressly cautions that its compilation is not a substitute for the Secretary of the State’s official RCSA. [S_CT-P2-C004] CT.gov+1
5. I reached the Secretary of the State’s official eRegulations search/browse interface through a materially different route from PASS-01, and an actual Title 36a RCSA section was retrievable. However, targeted public searches for a debt-adjustment/debt-adjuster fee regulation, §36a-662 implementation, and associated regulation-making records did not surface an operative debt-adjuster fee rule or a repeal/adoption record. That means the historical administrative-rule chain is still not complete enough to assert either “no rule was ever adopted” or “a former rule was repealed on date X.” [S_CT-P2-C005] eRegulations+2
6. The 2009 legislation that reopened debt adjustment to for-profit providers amended §36a-660 to require written fee disclosure and free preagreement counseling. The enacted text retrieved for §25 does not show creation of a numerical DMP fee ceiling. [S_CT-P2-C006] Connecticut General Assembly+1
7. Accordingly, PASS-01’s hold on a numerical DMP ceiling remains appropriate. It should not be replaced by the debt-negotiation 10% schedule, by an assumed “reasonable fee” rule, or by an invented setup/monthly cap. [S_CT-P2-C007]

The result is therefore a narrowed unresolved issue, not a numerical answer: the current publicly retrieved statute and agency materials do not supply a DMP percentage/dollar ceiling, while the official historical regulation/adoption-repeal record remains incomplete.

A. Substantive findings

1. Current statutory fee rules for Connecticut debt adjustment

Current §36a-660 requires each licensed debt adjuster to:

• give the debtor a written agreement identifying the services and fees;
• provide individualized credit counseling and budgeting assistance without charge before the agreement;
• make remittances after receipt of debtor funds, less prorated fees and costs, subject to the statute’s accumulation exception.

Those provisions establish a zero-dollar counseling rule plus disclosure and allocation requirements, but they do not state a general percentage, monthly-dollar, setup-fee, per-creditor, savings-based, or aggregate DMP fee cap. [S_CT-P2-C001–C003] Connecticut General Assembly+1

Section 36a-661a separately allows a debtor to void the agreement and recover fees if the licensee charges or receives fees/payments not specified in the written agreement. That provision makes disclosure consequential; it does not convert the disclosed amount into an otherwise lawful fee or establish its numerical maximum. Connecticut General Assembly

Section 36a-662 states that the commissioner may adopt regulations needed to administer and enforce §§36a-655 through 36a-665. The provision is enabling authority. It is not itself a fee schedule. Connecticut General Assembly+1

Current numerical result established in this pass

This is not a conclusion that those other categories are unlimited. It is a conclusion that this evidence record does not establish their numerical ceiling.

2. Current official regulation sources

Department of Banking compilation

The Department of Banking’s current laws/regulations page says that the regulation compilations it provides were prepared by the Department but “are not intended to be a substitute” for the official RCSA maintained through the Secretary of the State’s eRegulations system. CT.gov

The linked Department regulation page describes a 158-page “Regulation Compilation, revised to June 11, 2014.” Its Consumer Credit section visibly enumerates regulations for:

• fees charged by real estate brokers and salesmen;
• small loan licensees;
• collection practices of creditors;
• consumer collection agencies;

and other subject-specific rules. The displayed compilation index does not list debt adjusters or a debt-adjustment fee regulation. [S_CT-P2-C004] CT.gov

That omission is useful evidence, but not enough by itself to prove that no later RCSA section exists, because the Department expressly labels the compilation nonofficial and dates it to 2014.

Secretary of the State eRegulations

Unlike the failed PASS-01 path, I successfully reached the official Secretary of the State eRegulations interface:

• Title 36a browse page;
• RCSA search interface;
• an actual indexed Title 36a section, §36a-1-3.

The search interface expressly supports exact-section and content searching. eRegulations+2

However, materially new targeted public searches for:

• debt adjuster
• debt adjustment
• 36a-662
• debt-adjuster fee language
• debt-adjuster final-approved regulations
• debt-adjustment regulation-making records

did not yield an operative debt-adjuster fee section or an adoption/repeal document in the retrievable public results.

That is an access/evidence limitation, not authority for the proposition that such a regulation never existed.

3. Adoption and amendment history actually established

1967 — statutory regulation authority originates

Current §36a-662 traces to 1967 P.A. 882 §14, later transferred from former §36-377 to §36a-662 in the 1995 recodification. The current history note shows only the 1994 technical change and recodification; it does not identify a particular regulation adopted under the authority. [S_CT-P2-C008] Connecticut General Assembly

1979 — nonprofit-only restructuring

The Connecticut Banking Commissioner’s 1979 report describes P.A.79-160 as eliminating for-profit debt adjustment and creating a licensing procedure for nonprofit adjusters. CT.gov

The current statutory history confirms that the 1979 act substantially rewrote the licensing structure and deleted certain earlier provisions. The current §36a-661 history also records that P.A.79-160 deleted a former prohibition concerning acceptance of a promissory note, wage assignment, mortgage, or other security for a fee. Connecticut General Assembly

What this does not establish: it does not reveal an operative historical numerical fee regulation or its repeal date.

2002 — licensing changes, not a verified consumer-fee ceiling

The Department’s official 2002 legislative summary reports amendments to debt-adjuster licensing, including the application fee, license duration, standards, and related licensing mechanics. Nothing in the retrieved summary identifies a numerical consumer DMP fee ceiling. CT.gov

2009 — for-profit debt adjustment restored; written fee agreement/free counseling added

P.A.09-208 changed the system materially:

• it removed the nonprofit-only limitation;
• it made compensation part of the debt-adjustment definition again;
• §25 amended §36a-660 to require a written agreement identifying services and fees and required free individualized counseling and budgeting before agreement.

The enacted-act search result exposes the actual beginning of §25, including the inserted written-agreement and no-charge counseling language. Connecticut General Assembly

The General Assembly’s official public-act summary likewise describes §§23–27 as adding fee disclosure, free counseling, suitability, creditor contact, and voidability protections. It does not describe an enacted numerical DMP consumer-fee maximum. Connecticut General Assembly

This is important because 2009 is also when Connecticut created the separate debt-negotiation regime and authorized a negotiation maximum-fee schedule. That separate schedule cannot be imported into debt adjustment.

2014 onward

The Department’s compilation is dated June 11, 2014 and does not display a debt-adjuster regulation series. Current 2026 Department consumer-information and licensing pages continue to describe DMP licensing, written fee disclosure, free counseling, remittance duties, and voidability without publishing a debt-adjuster maximum-fee schedule. CT.gov+2

This supports—but does not by itself conclusively prove—the present finding that no separate numerical DMP fee ceiling is publicly identified in the Department materials retrieved.

B. PASS-02 source table

C. Material claim table

D. Original PASS-01 claim patch map

E. Failed-route / dependency table

F. Granular scope coverage and remaining dependency

Final disposition for the coordinator

For the Connecticut DMP/debt-adjustment branch, the defensible fee field after PASS-02 is:

Required pre-agreement counseling fee: $0.

Other numerical DMP consumer fee ceiling: HOLD — no current numerical ceiling verified from retrieved official Connecticut statute/regulation sources; complete official administrative adoption/repeal history not yet retrieved.

Do not populate a $50 setup fee, $8-per-creditor monthly fee, $40 monthly cap, 10%-of-savings cap, or any other debt-negotiation number into the debt-adjustment/DMP row.

I did not create another chat, use Deep Research/Work/Codex, contact any regulator, file anything, make an account change, or claim a local save. This is a researcher self-check, not independent review, whole-state completion, or publication-readiness approval.

END S_CT PASS-02.