Check a debt-help provider’s evidence

S_DC — District of Columbia

PASS-01: Debt-relief provider market access and consumer fees

SettleADebt.com | Research date: October 24, 2026 (Pacific) | Baseline: October 22, 2026 | Scope: provider classification, legal authorization, fees, and fee timing

Research status: PARTIALLY VERIFIED — MARKET ACCESS AND FEE AUTHORIZATION HELD

The most important finding is that the District of Columbia's former criminal debt-adjusting prohibition, D.C. Code § 22-1201, is expressly repealed. That is a significant distinction from jurisdictions retaining a categorical debt-adjusting prohibition.

However, repeal alone does not establish that a commercial debt-settlement company may operate in D.C. without a license, charge any particular fee, or collect compensation under any particular schedule.

The official D.C. Code also contains consumer-debt collection protections that must not be confused with the regulatory requirements governing a consumer's own debt-settlement representative.

Initial controlling findings

The official D.C. Code publication identifies its compilation as current through October 14, 2026, with D.C. Law 26-190 as the last codified permanent law. This is the publisher's stated currency, not a guarantee that every potentially applicable administrative rule or federal provision has been checked. D.C. Law Library+2

Operational consequence: SettleADebt.com should not currently mark D.C. as an approved commercial debt-settlement market, assign it a fee cap, or claim that a license is unnecessary on the basis of this pass.

A. Substantive findings by scope question

1. Definitions and business-model classification

S_DC-P1-C001 — Former debt-adjusting statute repealed.

The official codification of D.C. Code § 22-1201 states that the provision was repealed, citing D.C. Law 15-154, § 6, effective April 29, 2004. The former title refers to debt adjusting, prohibitions, exceptions, penalties, and prosecutions.

This verifies the repeal of that provision. It does not establish what replacement or independently applicable laws regulate the same conduct today. D.C. Law Library

S_DC-P1-C002 — Debt collection is separately defined.

D.C. Code § 28-3814(b)(2)–(5) defines consumer debt, debt collection, debt buyers, and debt collectors. Under this provision, consumer debt generally involves a qualifying personal, family, medical, or household obligation more than 30 days overdue, subject to the statutory qualifications and exclusions.

The definition of debt collection concerns conduct undertaken to collect consumer debt. It does not, by itself, classify a consumer-retained negotiator as a debt collector simply because that negotiator communicates with creditors. D.C. Law Library

S_DC-P1-C003 — Model-specific classifications remain open.

The distinction matters: a noncustodial negotiator, an organization distributing monthly payments, and a creditor collecting its own account can perform economically related activities while falling under different legal rules.

No inference is made from a provider's marketing label, nonprofit status, or attorney affiliation.

2. Prohibition, licensing, registration, and exemptions

S_DC-P1-C004 — The historical prohibition is not a current authorization framework.

The repeal of § 22-1201 eliminates that provision as a current statutory basis for prohibiting debt adjusting. It does not create an affirmative license, establish a fee schedule, or resolve other consumer-protection statutes.

S_DC-P1-C005 — Current provider licensing remains unresolved.

The reviewed DISB Consumer Services material confirms that the agency handles matters involving financial institutions and professionals regulated in D.C. It does not provide, in the inspected passage, a debt-settlement-specific license category, governing statute, application, or provider registry.

Accordingly, the investigation has not established either that a D.C. debt-settlement license is required or that no such license is required. disb

The issuing regulator, any separate business-license obligations, institutional exclusions, attorney conditions, nonprofit qualifications, and remote-provider treatment remain open.

3. Consumer fees, ceilings, indexing, and refunds

S_DC-P1-C006 — No current D.C. commercial settlement-fee ceiling verified.

No primary text inspected in this pass establishes a current percentage-of-enrolled-debt cap, percentage-of-savings cap, per-account cap, dollar setup cap, or aggregate commercial debt-settlement fee limit.

This is a verification failure, not a finding that fees are unlimited.

No CPI adjustment, historical fee table, or model-act amount has been substituted for an enacted D.C. requirement.

S_DC-P1-C007 — Debt-collector charges are not provider compensation.

D.C. Code § 28-3814(g)(3)–(4) addresses collection of debt-collector fees and incidental charges, including legal or contractual authorization requirements.

Those provisions must not be treated as permission for a consumer's debt-settlement provider to impose the same charges. D.C. Law Library

4. Fee timing and performance conditions

S_DC-P1-C008 — No D.C.-specific settlement-provider fee trigger verified.

This pass has not established a District-specific rule allowing or prohibiting payment at enrollment, after creditor acceptance, after consumer payment, or after completion of a settlement.

The independently applicable federal Telemarketing Sales Rule must be analyzed separately. In particular, 16 C.F.R. § 310.4(a)(5) is the relevant federal debt-relief advance-fee provision.

The controlling federal text was not successfully retrieved in this research pass. Its precise application, including covered telemarketing activity, exceptions, proportional allocation, and performance conditions, therefore remains a primary-source verification hold rather than a fully authenticated legal conclusion.

S_DC-P1-C009 — Creditor-side settlement documentation is a separate issue.

D.C. Code § 28-3814(n), as displayed in the official codification, requires a debt collector entering a qualifying payment schedule or settlement agreement to provide the consumer a written copy within seven days, with additional rules concerning payments before delivery of the agreement.

This provision regulates the debt-collector-side arrangement; it does not establish when a consumer-retained settlement company earns its service fee. D.C. Law Library

5. Regulator permission, applications, and provider lookup

No current debt-settlement-specific application, license instruction, operative licensing rule, or named-provider registry entry was authenticated.

Two official operational sources were located:

• DISB Consumer Services Division — explains financial-services complaint handling and the agency's jurisdictional limits.
• D.C. Office of the Attorney General consumer resources — identifies consumer assistance and legal representation resources, not commercial debt-settlement authorization.

Neither source is evidence that SettleADebt.com or any other named company is authorized to sell debt-settlement services in D.C.

6. Worked fee and boundary examples

Because no current D.C.-specific lawful commercial fee pathway has been established, the following are classification and arithmetic checks only, not proposed chargeable fees.

Example E01 — Partial settlement with an unverified percentage fee

Hypothetical inputs; no established legal fee authority

• Enrolled balance: $10,000.00
• Settlement amount: $6,000.00
• Reduction: $10,000.00 − $6,000.00 = $4,000.00
• Hypothetical 20% enrolled-balance fee: $10,000.00 × 0.20 = $2,000.00
• Hypothetical 20% savings fee: $4,000.00 × 0.20 = $800.00

These are mathematically different bases. Neither $2,000 nor $800 is verified as a lawful D.C. fee. Both are held.

Example E02 — Low-balance account

• Enrolled balance: $800.00
• Proposed settlement: $500.00
• Savings: $300.00
• Hypothetical 20% savings fee: $60.00
• Hypothetical $100 flat fee: $100.00

A flat-fee minimum, low-debt exception, and any aggregate limitation remain unverified. The example does not authorize either charge.

Example E03 — Earlier fees and proportional allocation

Assume three enrolled debts of $5,000.00, $10,000.00, and $15,000.00, totaling $30,000.00, with a hypothetical contracted aggregate fee of $6,000.00.

If a proportional allocation method is legally applicable and properly contracted, the mathematical allocations would be:

If Debt A alone is settled, the calculation does not make all $6,000 earned. Nor does it establish that the $1,000 allocated to A is currently collectible.

Earlier earnings are assumed to be $0.00 for this hypothetical. No previous payment is invented. Any actual earning must independently satisfy applicable state law, contract conditions, and federal timing requirements.

Example E04 — Cancellation before a settlement

• Enrolled balance: $12,000.00
• Consumer contributions: $1,200.00
• Settled debts: zero
• Provider fees previously charged: $0.00
• Hypothetical cancellation date: day 45

The $1,200.00 represents consumer contributions, not earned provider compensation.

The refund, withdrawal, account-ownership, and cancellation requirements cannot be calculated from the D.C. provisions verified here. Those outcomes remain held pending the controlling contract, funds-handling law, and applicable federal provisions.

All currency calculations above use U.S. dollars and two decimal places. No intermediate rounding affects these results. Numeric accuracy is established; legal collectibility is not.

Supplemental verified federal finding

The official eCFR text was successfully opened after the initial federal retrieval attempt. This resolves the earlier federal-text access hold, but not the unresolved D.C. licensing or fee-ceiling questions.

S_DC-P1-C010 — Federal debt-relief performance conditions.

Under 16 C.F.R. § 310.4(a)(5)(i)(A)–(C), where the Telemarketing Sales Rule applies, the seller or telemarketer cannot request or receive a debt-relief service fee until all three conditions are satisfied:

1. At least one enrolled debt has been renegotiated, settled, reduced, or otherwise altered under a qualifying customer-executed agreement.
2. The customer has made at least one payment pursuant to that agreement.
3. For individually resolved debts, the fee follows the prescribed proportional-enrolled-balance allocation or a consistent percentage-of-savings method.

Section 310.4(a)(5)(ii)(A)–(E) separately provides conditions for qualifying customer-controlled accounts, including withdrawal and return of funds within seven business days, excluding properly earned fees.

These rules are federal performance restrictions, not authorization to charge fees under D.C. law. The eCFR identifies Title 16 as current through October 22, 2026. eCFR

S_DC-P1-C011 — Federal credit-repair representations.

Section 310.4(a)(2) contains a distinct advance-fee restriction for covered services represented as improving or removing derogatory credit information. This may matter when debt-settlement marketing promises credit improvement.

Whether a particular service also falls under CROA, 15 U.S.C. §§ 1679–1679j, requires a separate applicability analysis. The CROA statutory text was not independently verified in this pass. eCFR

B. Source register

All source-access dates below are October 24, 2026. "Read" means relevant text was actually returned by the public web tool; it does not mean every linked authority or historical version was authenticated.

The search also surfaced Colorado and Maryland debt-management licensing materials. Those were excluded from the D.C. authority register because another jurisdiction's licensing scheme cannot establish District law.

No D.C. administrative rule, adoption order, current license application, judicial decision, or named-provider registry record was sufficiently authenticated to add as a controlling source.

C. Claim register

The claim IDs above use the full S_DC-P1-C### prefix. No unresolved claim should be promoted to an affirmative legal conclusion merely because a related federal provision was verified.

D. Component coverage and gap register

Priority for the next D.C. investigation

The next investigation must first establish the current affirmative legal framework for commercial consumer debt-settlement providers, including whether a separate licensing regime exists. That finding controls the interpretation of nearly every unresolved fee and market-access question.

Second, the operative DCMR provisions and relevant rulemaking/adoption history must be inspected in full. Third, current licensing instructions and registry procedures must be matched to the actual regulated business model. Only then should the current D.C. fee ceilings, exceptions, adjustments, and refund obligations be calculated.

The present evidence does not justify an operational D.C. fee schedule.

E. Researcher self-check

What was actually completed

The investigation used regular Chat public web research on October 24, 2026. It directly opened the official repealed debt-adjusting provision, the current D.C. debt-collection provision, and the federal TSR fee-timing provision. Additional official D.C. materials were inspected through returned search-rendered text.

The relevant federal TSR text was ultimately obtained, so its performance and dedicated-account provisions are supported by actual retrieved primary text.

What was not completed

No exhaustive D.C. Code or DCMR search, complete administrative-rule review, adoption-order reconstruction, controlling-case-law survey, current provider-license verification, fee-adjustment notice reconciliation, or named-provider lookup was completed.

Search results that failed to identify a license or fee provision are not proof that no such provision exists. A regulator's complaint page is not a license registry. No full commercial fee pathway was authenticated.

No external applications, contacts, account changes, Chrome-control operations, other chats, purchases, local writes, or publication actions were performed. This is a single researcher pass, not independent legal review, and it is not publication-ready or an A066 acceptance determination.

Final disposition: S_DC PASS-01 remains open. The historical repeal, separate collector-side framework, and federal TSR timing text are supported. The decisive D.C. provider-authorization and commercial-fee questions remain unresolved, and all other state-dossier categories remain expressly required.

END S_DC PASS-01