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

S_CT PASS-03 — Connecticut consumer agreements and client-money duties

Focused component only: Connecticut debt-negotiation/debt-settlement and debt-adjustment/DMP consumer agreements, cancellation, client-money custody, disbursement, accounting, and records.

Current-source check: October 24, 2026, Pacific. Prior PASS-02 hold preserved: this pass does not resolve the numerical DMP fee-ceiling or complete administrative-regulation-history hold.

The central distinction is important:

• A noncustodial debt negotiator is governed by Connecticut’s detailed negotiation-contract statute, including mandatory individualized evaluation and a statutory three-business-day cancellation clause.
• A provider that receives Connecticut-resident debtor money for creditors as the debtor’s agent crosses into the statutory debt-adjustment model regardless of a “settlement” label. That model carries a separate-bank-account requirement, creditor-remittance duties, debtor accounting, and seven-year records.
• The same custody flow can also independently constitute money transmission, adding its own current remittance, reserve/trust-by-operation-of-law, delegate, and record duties. A debt-adjuster or negotiator license by itself does not establish permission for every money flow. [S_CT-P3-C001–C005, C019–C028] Connecticut General Assembly+2

A. Substantive answers

1. Consumer agreements: negotiation versus DMP/debt adjustment

A1. Debt negotiation / debt settlement

For a covered debt-negotiation transaction, §36a-671b(a) requires the negotiator to provide each debtor a contract containing:

• a complete, detailed list of services;
• the costs of those services;
• the results to be achieved;
• a certification that the provider reviewed the consumer’s debt;
• an individualized evaluation of the likelihood that the proposed services will reduce debt or debt service, or, where appropriate, prevent residential foreclosure;
• the statutory three-business-day cancellation provision, with the prescribed conspicuous caption and cancellation wording.

The contract therefore cannot lawfully be a generic “we may attempt to help” enrollment document that omits the actual services, costs, intended result, debt review, or individualized likelihood evaluation. [S_CT-P3-C006] Connecticut General Assembly

The current statute also ties the cooling-off period to the date the consumer signed the contract. The retrieved debt-negotiation provisions do not separately prescribe a provider countersignature, duplicate-paper-copy deadline, minimum font size for the entire agreement, or a general English-language requirement. The one explicit presentation standard is that the cancellation caption be clear and conspicuous. I therefore do not invent additional debt-negotiation formatting requirements from another statute. [S_CT-P3-C007] Connecticut General Assembly

Section 36a-671f independently prohibits covered persons from fraud or misleading schemes, unfair or deceptive practices, false/deceptive representations, failure to truthfully account for debtor money, and failures to comply with the governing statutes or applicable law. Thus the written service promises cannot be considered in isolation from the accuracy and performance duties. [S_CT-P3-C008] Connecticut General Assembly

Electronic execution

Connecticut UETA generally recognizes an electronic record as satisfying a writing requirement and an electronic signature as satisfying a signature requirement. But it applies only where each party has agreed to conduct the transaction electronically; agreement is determined from context and circumstances. A party may decline electronic treatment of later transactions, and that right cannot be prospectively waived. [S_CT-P3-C009] Connecticut General Assembly+1

Where law requires written information to be provided or delivered and the parties have agreed to transact electronically, the electronic record must be capable of retention at receipt. If the sender prevents printing or storage, the record is not capable of retention and can be unenforceable against the recipient. UETA also expressly preserves another statute’s required method or format of transmission. [S_CT-P3-C010] Connecticut General Assembly

Accordingly:

• an otherwise qualifying Connecticut negotiation agreement is not invalid merely because it is electronic;
• electronic contracting is not compulsory;
• the debtor must be able to retain the electronic written information when required;
• UETA does not erase §36a-671b’s specially prescribed cancellation-notice method and format.

I did not find authority in this pass permitting a provider to replace the statutory certified/registered-mail cancellation instruction with an email-only process. [S_CT-P3-C009–C011]

Coverage and exceptions needed for applying the contract rule

The negotiation regime reaches compensated or expected-to-be-compensated assistance negotiating debtor obligations. It expressly reaches an out-of-state provider contracting with a Connecticut resident in person, by mail, telephone, or Internet, as well as specified Connecticut-property debt. [S_CT-P3-C012] Connecticut General Assembly+1

Section 36a-671c excludes specified banks/credit unions and subsidiaries, qualifying court-ordered actors, licensed debt adjusters while performing debt-adjuster services, qualifying bona fide §501(c)(3) nonprofits, and the attorney category. These are activity/entity-specific; they are not generic permission to omit a contract because the business calls itself a nonprofit, law firm affiliate, counselor, or processor. [S_CT-P3-C013] Connecticut General Assembly

For attorneys, Persels held the debt-negotiation statutes unenforceable against Connecticut attorneys engaged in bona fide legal practice, but the court also explained that the presumption can be overcome where there is no meaningful attorney supervision, no genuine legal advice/services, or no bona fide attorney-client relationship. The 2025 Connecticut Supreme Court’s Commonwealth Servicing Group decision continued to describe that framework rather than abolishing it. [S_CT-P3-C014] Justia Law+1

That judicial rule is not automatically transferred to the separate debt-adjustment attorney exception.

A2. Debt adjustment / custodial DMP

For a covered debt adjuster, §36a-660 requires the licensee to provide the debtor a written agreement setting out:

• the services to be provided;
• any fees for those services.

Before entering the written agreement, the licensee must also provide individualized credit counseling and budgeting assistance without charge, determine that the debtor can make the stated payments and that the payments are suitable, and contact each creditor to determine whether it will accept payment contemplated by the agreement. [S_CT-P3-C015] Connecticut General Assembly

Those creditor contacts matter. The statute does not support presenting creditor participation as guaranteed merely because a DMP agreement has been signed. The provider must investigate whether each creditor will accept the contemplated payment. [S_CT-P3-C016] Connecticut General Assembly

Debt-adjustment contracts also have a completion rule: a person subject to the act may not execute a contract for the debtor to sign unless it is fully and completely filled in and finished. The provider may not condition enrollment on purchase of other services or materials, and deceptive fee/service statements and failure to truthfully account for debtor money are prohibited. [S_CT-P3-C017] Connecticut General Assembly

If a licensed debt adjuster imposes a fee or other charge, or receives money or another payment, that was not specified in the written agreement, the debtor may void the agreement and recover fees paid. If the person lacked a required debt-adjuster license, the written agreement is also voidable. Once the debtor voids under §36a-661a, the statute denies the provider a breach-of-contract or restitution claim against the debtor. [S_CT-P3-C018] Connecticut General Assembly

That is materially different from saying every disclosed fee is valid. The unresolved PASS-02 numerical DMP-fee issue remains unresolved.

The adjustment regime applies where a person, for compensation or expected compensation, receives as the debtor’s agent money or evidence of money for distribution among creditors. The retrieved adjustment statute applies to personal/family/household debt and contains its own exemptions in §36a-663. There is no general nonprofit exemption in §36a-663. [S_CT-P3-C001, C029] Connecticut General Assembly+1

2. Cancellation, termination, refunds, and money return

B1. Debt negotiation statutory cooling-off right

Current §36a-671b provides an express three-business-day cancellation/rescission right after the date the consumer signs.

The contract must display the clear and conspicuous caption “Debtor’s three-day right to cancel” and tell the debtor that cancellation may be made by mailing written notice by certified or registered mail to the specified address. The notice must say that the debtor does not wish to be bound, and the statutory language requires the notice to be delivered or mailed before midnight of the third business day after signature. [S_CT-P3-C030] Connecticut General Assembly

The statutory counting rule

Section 36a-671b itself supplies the relevant counting definition. A “business day” is any calendar day except Sunday and the nine enumerated holidays:

New Year’s Day, Washington’s Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day, and Christmas Day.

That means Saturday counts, unless it is itself one of the listed holidays. The current definition resulted from P.A.25-111 §37 and became effective July 1, 2025. This provision appears in the 2026 Supplement. [S_CT-P3-C031] Connecticut General Assembly

No outside generic deadline rule is needed for that particular three-business-day calculation because the debt-negotiation statute supplies its own definition.

What cancellation does not answer

Section 36a-671b(c) says a contract failing to comply with the section is voidable by the consumer. It does not, in the text retrieved, specify a universal number of days within which a negotiator must return every payment after an ordinary three-day rescission, nor does it provide a complete allocation formula between lawfully earned compensation, unearned compensation, and creditor-directed funds. [S_CT-P3-C032] Connecticut General Assembly

I therefore hold rather than invent:

• a universal Connecticut debt-negotiation cancellation-refund deadline;
• treatment of an arguably earned periodic payment upon a timely rescission;
• a rule allowing retention of consumer creditor funds by a noncustodial negotiator;
• any federal TSR fee timing as a substitute for Connecticut construction.

The separately identified state periodic-payment interpretation remains for the later pass.

B2. DMP/debt-adjustment termination and voiding

The adjustment provisions retrieved do not establish a general three-day cooling-off period analogous to §36a-671b.

They do establish specific voidability:

• undisclosed fee/charge/payment → debtor may void and recover fees paid;
• required license absent → agreement voidable;
• after statutory voiding, licensee has no breach or restitution claim.

[S_CT-P3-C018] Connecticut General Assembly

Section 36a-660 explicitly contemplates both cancellation and completion when defining the seven-year agreement-record retention period, but that reference does not itself create a general at-will termination right or establish a money-return deadline. [S_CT-P3-C033] Connecticut General Assembly

Likewise, I did not locate in §§36a-659–661a an express deadline requiring a debt adjuster, following cancellation, to return all undisbursed creditor funds to the debtor within X days.

That absence is a specific unresolved rule, not permission to retain the funds.

3. Client-money custody, control, accounts, and disbursement

C1. Custodial DMP/debt-adjustment funds

Section 36a-659 is unusually direct:

a licensee must maintain a separate bank account for the benefit of debtors, and all payments received from Connecticut-resident debtors for the benefit of creditors must be deposited there.

[S_CT-P3-C019] Connecticut General Assembly

Important limits on what that text establishes:

• It says separate bank account; it does not call the account an individually titled trust account.
• It does not require a separate bank account for each debtor.
• It does not in §36a-659 itself impose an FDIC-insurance requirement.
• It does not state that the provider may put the same creditor-directed funds in its ordinary operating account.
• Historical text matters: P.A.02-111 deleted a former sentence requiring payments to remain in the bank account until remittance to a debtor or creditor. The current law should not silently reinsert that deleted language. [S_CT-P3-C020] Connecticut General Assembly

The statute nevertheless imposes continuing accounting controls:

• books, accounts, and records sufficient for the commissioner to determine compliance;
• those transaction records preserved at least seven years after final entry;
• agreement-specific records—including agreement/extensions, payments, disbursements, and charges—during the agreement and seven years after cancellation or completion;
• written debtor account statements periodically and at least quarterly;
• a final written statement no later than 90 days after completion of debt adjustment;
• verbal accounting on debtor request during normal business hours.

[S_CT-P3-C021] Connecticut General Assembly+1

There are therefore two overlapping seven-year rules with different anchors:

1. §36a-659: seven years after the final entry on the transaction;
2. §36a-660(5): seven years from cancellation or completion of the written agreement.

A compliant records system has to satisfy whichever duty continues to apply; this pass does not collapse those distinct statutory anchors. [S_CT-P3-C022]

Creditor disbursement

Section 36a-660(6) requires remittances to creditors within a reasonable time after receipt, less prorated fees and costs, unless reasonable payment of one or more obligations requires holding funds longer to accumulate a sum certain. [S_CT-P3-C023] Connecticut General Assembly

This is deliberately not a fixed number of days.

Historically, the statute formerly required remittance within ten days; P.A.79-160 replaced that with “within a reasonable time.” A researcher should not resurrect the former ten-day rule as current law. [S_CT-P3-C024] Connecticut General Assembly

The unresolved DMP numerical-fee ceiling makes the phrase “less prorated fees and costs” especially important: it does not itself establish how much may lawfully be deducted.

C2. Noncustodial debt negotiation

Sections 36a-671 through 36a-671f do not contain a counterpart to §36a-659 requiring every debt negotiator to maintain a debtor-benefit bank account.

That makes the actual money flow decisive. A company cannot avoid the adjustment rules by calling a program “settlement” if it actually receives consumer money as the debtor’s agent for later creditor distribution. [S_CT-P3-C001, C025] Connecticut General Assembly

Section 36a-671f still independently prohibits a covered negotiator from failing to truthfully account for money belonging to a debtor or mortgagor. But that accounting prohibition is not affirmative statutory authorization for a negotiator to take custody in the first place. [S_CT-P3-C026] Connecticut General Assembly

2026 Connecticut enforcement confirms the functional distinction

In August 2026, the Banking Commissioner alleged that CDS Debt Relief offered debt negotiation but also withdrew Connecticut consumers’ payments intended for debts, deposited them into its own account, and used them for operating/personal expenses. The Department separately alleged:

• unlicensed debt negotiation;
• unlicensed debt adjustment;
• violation of §36a-659 because creditor-benefit debtor payments went into the company’s general operating account rather than the required separate debtor-benefit account; and
• unlicensed money transmission because the firm received money to hold and later transmit to creditors.

This is useful evidence that Connecticut regulators classify the actual funds flow, not merely the marketing label. [S_CT-P3-C027] CT.gov

But evidentiary status matters: the August bulletin describes allegations and a temporary order, not a contested judicial holding. The direct October 6, 2026 final-order PDF that PASS-01 had retrieved was inaccessible through the public-web route on this PASS-03 attempt. I therefore do not use that inaccessible PDF here to upgrade every August allegation into a litigated precedent. [S_CT-P3-C028]

C3. Money-transmission overlay

Current §36a-596 defines money transmission broadly to include receiving money or monetary value for current or future transmission. [S_CT-P3-C034] Connecticut General Assembly

The Department’s formal 2016 Debt Adjustment and Money Transmission memorandum states its interpretation that a person receiving consumer funds for future transmission to creditors can be conducting money transmission as well as debt adjustment. The Department said dual licensing is required where both definitions are met unless an exemption applies. It also stated a limited processor position: it would not require debt-adjuster licensure of a Connecticut-licensed money transmitter transmitting funds solely for duly licensed or exempt debt-adjustment/debt-negotiation providers. That is an agency interpretation/policy memorandum, not statutory text or a judicial holding. [S_CT-P3-C035]

Where the current money-transmission law independently applies, additional money duties include:

• maintaining permissible investments at least equal to aggregate outstanding Connecticut money transmissions;
• treating those permissible investments, even if commingled, as claimant property interests and as held in trust by operation of law for claimants in the specified bankruptcy context;
• truthfully accounting for transaction-party money;
• performing written agreements;
• remitting money/value received for transmission to the purchaser-designated person not later than seven calendar days from receipt, unless the purchaser directs otherwise;
• retaining specified records for at least five years, including a general ledger posted at least monthly, bank statements and reconciliation records, outstanding-transmission records, and authorized-delegate information.

[S_CT-P3-C036–C039] Connecticut General Assembly+2

Those rules should not be rewritten as “the DMP trust-account rule.” They are a distinct statutory regime triggered only when the transaction independently meets the money-transmission requirements.

Authorized delegates / third parties

A current money-transmitter may act through properly designated authorized delegates. From the moment of receipt, an authorized delegate holds proceeds in trust for the licensee; the licensee remains liable for specified loss caused by the delegate’s failure to forward funds, must have a compliance contract with the delegate, and the delegate must remit according to that contract. [S_CT-P3-C040] Connecticut General Assembly

This differs from §36a-659’s “separate bank account for the benefit of debtors.” They are not interchangeable account concepts.

The money-transmission statute also now sharply limits FDIC representations: solicitation/advertising generally cannot claim deposited funds are FDIC-eligible unless funds are actually placed with an FDIC-insured depository in a qualifying manner and the representation accurately describes the institution, extent, and conditions of coverage. [S_CT-P3-C041] Connecticut General Assembly

Therefore, neither a debt-adjustment license nor a third-party “dedicated account” marketing phrase proves that a particular account is insured, segregated as required, legally controlled by the consumer, or permissible for the proposed flow.

4. Bounded examples

Example 1 — negotiation cancellation: exact statutory counting

Facts: Consumer signs a covered negotiation contract on Friday, October 23, 2026. Assume none of the next counted days is one of §36a-671b’s listed holidays.

Base: signing date = Friday October 23.

Operator: count calendar days after signing except Sunday and the nine statutory holidays.

• Saturday October 24 = business day 1.
• Sunday October 25 = excluded.
• Monday October 26 = business day 2.
• Tuesday October 27 = business day 3.

Result: under the mandated contractual wording, qualifying written cancellation notice must be delivered or mailed before midnight Tuesday, October 27, 2026.

Units: days/calendar date. Rounding: none.

The contract must instruct use of certified or registered mail. This example does not create a refund deadline after cancellation. [S_CT-P3-C030–C032] Connecticut General Assembly

Example 2 — custodial DMP deposit requirement without inventing the fee

Facts: A Connecticut-resident debtor pays $1,000.00 to a covered debt adjuster, and the entire $1,000 payment is received for the benefit of creditors.

Base: creditor-benefit debtor funds = $1,000.00.

Deposit operator: §36a-659 applies to all payments received from Connecticut debtors for creditors.

Required separate-account deposit: $1,000.00 × 100% = $1,000.00.

Suppose the written agreement also mentions some provider fee F.

The current remittance structure can be written:

creditor remittance = $1,000.00 − lawful prorated fee/cost F

But PASS-02 did not establish the complete numerical DMP-fee ceiling, so F cannot responsibly be replaced with an assumed dollar amount or percentage.

Result: separate-account deposit = $1,000.00; exact lawful net remittance = HOLD pending lawful F and timing facts.

No double deduction is made. [S_CT-P3-C019, C023] Connecticut General Assembly+1

Example 3 — operating account is the wrong account for creditor-benefit DMP money

Facts: Same $1,000 payment, but provider deposits it directly into its general operating account.

Base: creditor-benefit Connecticut debtor funds = $1,000.

Operator: compare destination against §36a-659.

Required destination = separate bank account for benefit of debtors. Actual destination = general operating account.

Result: $1,000 is placed outside the account destination required by §36a-659 on the assumed covered-adjuster facts.

No fee issue needs to be resolved to reach that account-location conclusion. The 2026 CDS enforcement allegations use the same statutory theory. [S_CT-P3-C019, C027] Connecticut General Assembly+1

Example 4 — DMP voidability for an undisclosed charge

Facts: Written agreement identifies $80 of total provider charges. The provider later imposes an additional $25 charge not specified in that agreement.

Base: disclosed charges = $80. Actual charges imposed: $105. Undisclosed difference: $105 − $80 = $25.

Legal operator: §36a-661a(a), not an assumed fee ceiling.

Result: because a charge was imposed that was not specified in the written agreement, the debtor has the statutory right to void the agreement and recover fees paid.

The statute does not state in this clause an exact number of days for paying that recovery. It also does not answer whether the $80 disclosed amount was independently lawful; that remains subject to the PASS-02 fee hold. [S_CT-P3-C018] Connecticut General Assembly

Example 5 — creditor does not agree to proposed DMP payment

Facts: DMP proposal assumes Creditor A will accept $150/month. Provider contacts A as §36a-660(4) requires; A refuses.

Input: contemplated payment = $150/month. Creditor response: refuses.

Operator: statutory requirement is actual creditor contact to determine whether the creditor accepts the contemplated payment.

Result: the provider cannot treat the agreement itself as proof that A agreed to $150/month. The consumer’s payment schedule/service promise must be reassessed against the actual creditor response.

No settlement percentage or fee is fabricated. [S_CT-P3-C016] Connecticut General Assembly

Example 6 — money-transmission seven-calendar-day rule: endpoint deliberately held

Facts: A transaction independently qualifies as money transmission. Provider receives $600.00 for transmission to the purchaser-designated creditor on October 26, 2026; purchaser gives no contrary direction.

Base: $600.00 received for transmission.

Operator: §36a-607(d) requires transmission to the designated person no later than seven calendar days from receipt unless purchaser directs otherwise.

Amount result: $600.00 remains subject to the remittance obligation; no fee is subtracted merely from this statute.

Calendar endpoint: HOLD in this report.

Reason: although the statute supplies the seven-calendar-day period, I did not retrieve a generally applicable Connecticut time-computation provision that conclusively answers whether the date of receipt is counted as day zero or day one for this particular provision. The user required a legal counting rule before converting a statutory period into an exact date, so I do not invent one. [S_CT-P3-C038] Connecticut General Assembly

5. Currentness, enactment status, and regulations

Relevant Chapter 669 currentness

The posted 2025 Chapter 669 itself tells readers to consult the 2026 Supplement for provisions changed in the 2025 legislative sessions. I did so. [S_CT-P3-C042] Connecticut General Assembly

Most importantly, §36a-671b appears in the 2026 Supplement, and its history expressly records that P.A.25-111 §37 changed the “business day” definition effective July 1, 2025. The three-day cancellation analysis above therefore uses the supplement text rather than stale base-code language. [S_CT-P3-C031, C042] Connecticut General Assembly

Chapter 668’s relevant money-transmission provisions also appear in the 2026 Supplement. That text incorporates P.A.25-66 amendments to §§36a-596, 36a-603, 36a-607, and 36a-611. The amendments reflected there include the current claimant-property/trust language and current FDIC-advertising language. [S_CT-P3-C043] Connecticut General Assembly+2

I did not independently extract the effective-date clause of every provision of P.A.25-66. The statements here rely on the statute as printed in the January 1, 2026 supplement and therefore should not be repurposed as a detailed P.A.25-66 enactment-history report.

Later 2026 acts

I freshly checked the General Assembly’s official Public and Special Acts index, which displayed “All Acts as of 10/24/2026 9:26:58 am” and listed the 2026 Regular Session acts. I also ran targeted searches for the consequential sections in this pass. No 2026 enactment amending §§36a-659, 36a-660, 36a-661a, 36a-671b, or the relevant §36a-607 remittance rule surfaced. [S_CT-P3-C044] Connecticut General Assembly

That is a meaningful later-enactment check, but I preserve the earlier overarching qualification: I did not obtain an official 2026 section-by-section amended-statutes crosswalk proving exhaustively that no 2026 act touched any conceivable related provision. This is therefore current on the codification-plus-targeted-enactment record, not an assertion of exhaustive legislative-history perfection.

Regulations

The official Secretary of the State eRegulations public route remained incomplete for this subject. Targeted ordinary-public searches did not retrieve a debt-adjustment or debt-negotiation RCSA rule adding contract, cancellation, bank-account, reconciliation, or refund duties to the statutes analyzed here.

Therefore:

• I do not claim that no such regulation has ever existed;
• I do not use an inaccessible regulation as authority;
• I do not declare PASS-02’s administrative-history hold resolved;
• no regulation-derived numerical DMP fee or extra money-flow requirement is added in this PASS-03.

[S_CT-P3-C045]

B. Source table

C. Material claim table

D. Additional agreement/money-flow holds

Several questions cannot responsibly be converted into operational rules from the evidence retrieved:

1. No general DMP cooling-off period was found in §§36a-659–661a. Do not copy the negotiation three-day rule into DMP contracts.
2. No universal state cancellation-refund deadline was established for negotiation or adjustment.
3. No current numerical DMP fee ceiling is resolved. “Less prorated fees and costs” in §660(6) does not determine the amount.
4. No individual-subaccount mandate was found in §659. The express rule is one separate bank account for the benefit of debtors containing covered Connecticut creditor-benefit payments.
5. No §659 FDIC requirement was found. Money-transmission FDIC representation law is separate.
6. No fixed DMP creditor-remittance day count exists in current §660(6); current text uses “reasonable time.”
7. No exact seven-calendar-day money-transmission endpoint is calculated here without a verified generally applicable counting rule.
8. No email-only negotiation cancellation procedure is established. UETA preserves statutory specified methods.
9. No third-party dedicated-account structure is cleared merely because a third party is used. Actual receipt/control, money-transmitter status, authorized-delegate status, provider classification, contractual control, and account ownership remain factual/legal prerequisites.
10. No nonprofit or attorney label automatically removes all duties. The two statutory regimes have different exclusions.

E. Component coverage / gaps

F. Researcher self-check

I freshly read the operative Connecticut statutory passages for:

• debt-adjustment bank-account and records requirements;
• debt-adjustment written agreements, creditor contact, remittance, statements, and seven-year records;
• adjustment prohibited acts and statutory voidability;
• debt-adjustment exemptions;
• current 2026-supplement debt-negotiation contract/cancellation language;
• Connecticut UETA electronic-consent, electronic-writing/signature, retainability, and specified-method rules;
• current 2026-supplement money-transmission definitions, reserve/trust treatment, authorized-delegate duties, seven-calendar-day remittance, and five-year records;
• the official 2026 public-acts index through October 24, 2026.

I also used the DOB 2016 dual-licensing memorandum as agency interpretation and the August 2026 CDS bulletin only for the status it actually has: a description of administrative allegations. The CDS final-order PDF was attempted through a fresh public route but was inaccessible in this pass, so I did not pretend to reread it or convert the bulletin’s allegations into a contested judicial holding.

The official Judicial Branch Persels PDF was blocked during the fresh check; a readable judicial-opinion reproduction and the 2025 Supreme Court treatment were used, with that limitation disclosed.

The current public eRegulations route did not produce a complete operative debt-adjustment/debt-negotiation regulation/adoption history. That remains an evidence gap, alongside PASS-02’s DMP numerical-fee hold. I have not inferred unlimited DMP fees from that gap.

I did not use Deep Research, Work, Codex, APIs, another Chat, private borrower data, contacts, filings, purchases, account changes, or publication actions. I make no claim of independent review, local file saving, named-provider authorization, full Connecticut completion, A066 acceptance, or publication readiness.

END S_CT PASS-03.