FIND THE EXPLANATION
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P02 audit-trail repairs and remaining public CCSO procedure/rule gaps →Research access date: October 24, 2026, Pacific Official D.C. Code publication status: Current through October 22, 2026; last codified permanent law D.C. Law 26-190, effective October 14, 2026; last codified emergency law D.C. Act 26-784, effective October 22, 2026. Publication currency does not establish that every administrative rule, order, or operational form has been located. D.C. Law Library Mode/model: Regular Chat; GPT-5.6 Sol Pro; no Deep Research, Work, Chrome control, API use, contacts, applications, or named-provider investigation. Scope: Current affirmative legal framework for a commercial, consumer-retained debt-settlement or negotiation provider serving District residents. Disposition: PARTIAL — governing statute, regulator, and registration obligation established; current public filing instructions and CCSO-specific lookup pathway remain unresolved.
This is a focused patch to PASS-01. It does not replace or expand the remaining D.C. state, local, tribal, contract, litigation, remedies, limitations, secured-debt, or sector-specific passes.
The current affirmative framework is D.C. Code Title 28, Chapter 46, Consumer Credit Service Organizations, not the repealed debt-adjusting provision discussed in PASS-01.
Chapter 46 defines a “consumer credit service organization” broadly enough to include a compensated person who provides advice or assistance concerning a consumer’s personal, household, or family credit. A covered organization that “operates in the District” must register, file the Mayor-prescribed registration statement, pay a $300 initial registration fee, and pay a $200 annual fee. D.C. Law Library+2
Chapter 46 does not use the labels “debt settlement,” “debt negotiation,” or “debt relief.” The strongest textual hook is § 28-4601(2)(A)(iii), covering compensated advice or assistance concerning personal, household, or family credit.
That textual reading is reinforced by official D.C. enforcement records:
Those materials establish the District’s enforcement position. The complaint, consent judgment, and assurance are not controlling appellate decisions, and the Burlington defendants expressly denied liability. DC Attorney General+9
Qualified conclusion: A for-profit provider paid to negotiate, validate, dispute, resolve, or reduce a District consumer’s personal debts should be treated as a covered CCSO unless it can establish a precise statutory exclusion. This is a strong statutory and enforcement conclusion, not a holding from the D.C. Court of Appeals.
Implementation authority over Chapter 46 was transferred from DCRA to the financial-services regulator. Current statutes place administration of the D.C. Banking Code with the Department of Insurance, Securities, and Banking, acting through its Securities and Banking Bureau.
DISB’s current Banking Bureau and Divisions pages expressly state that its Licensing Division reviews applications for consumer credit service organizations and maintains the non-depository licensing database, identified on the Divisions page as NMLS. The statute calls the Chapter 46 authorization a registration; DISB’s operational pages use the broader phrase “license applications.” The agency terminology should not silently change the statutory authorization type. D.C. Law Library+5
The following are established:
The following were not authenticated from current public materials:
DISB’s current general NMLS compliance list and public verification page enumerate multiple non-depository categories but omit CCSOs. Its general licensing-and-registration forms page likewise does not surface a CCSO application. This omission is not proof that the registration program is inactive; it means the public operational route was not fully verified. Disb+2
Market-access disposition: D.C. should not be coded as “no license required.” It should be coded as:
Covered commercial debt-relief providers: Chapter 46 registration required; DISB administrator established; current public application and lookup completion pathway unresolved. Launch remains HOLD pending operational verification.
Chapter 46 establishes:
Chapter 46 does not itself state a percentage-of-debt, percentage-of-savings, per-account, monthly, setup, or aggregate consumer-service fee ceiling. No separate current D.C. amount cap was authenticated in this pass. That does not establish unlimited fees.
The independently applicable federal TSR conditions previously verified in PASS-01 remain separate. The earlier P1 federal-text retrieval hold was superseded by P1’s supplemental federal finding and is not an open PASS-02 issue.
| Authority and pinpoint | Operative rule and covered conduct | Authorization, exemption, or condition | Version/effectiveness and limits | Claims |
|---|---|---|---|---|
| D.C. Code § 28-4601(1) | “Consumer” is a person solicited to purchase or purchasing CCSO services. Consumer awareness and purchase or solicitation matter. | Establishes the protected customer relationship; it does not require that every payment come directly from the consumer. | Enacted effective March 8, 1991. No separate amendment shown for subsection (1). Chen applied this definition narrowly on unusual facts involving no consumer solicitation or awareness. D.C. Law Library+1 | C002, C022 |
| § 28-4601(2)(A)(i) | Paid services represented as improving a consumer’s credit record, history, or rating are directly covered. | Covered unless an exact subsection (D) exclusion applies. | Section last amended May 6, 2020. CROA applicability remains outside this pass. D.C. Law Library | C002, C016 |
| § 28-4601(2)(A)(ii) | Paid assistance obtaining an extension of credit for a consumer is covered. | Same exclusions. | “Extension of credit by others” limits the definition; Chen rejected coverage where the defendants obtained funds in their own names and then extended their own alleged credit. D.C. Law Library+2 | C002, C022 |
| § 28-4601(2)(A)(iii) | Paid advice or assistance concerning any matter related to personal, household, or family credit is covered. | Principal-reduction negotiation, debt validation, dispute assistance, DMP counseling, and similar services have a strong textual fit, subject to actual facts and exclusions. | The section does not say “debt settlement.” OAG’s debt-relief actions supply official enforcement support rather than binding appellate construction. D.C. Law Library+4 | C003, C004, C011, C012 |
| § 28-4601(2)(B)–(C) | Salespersons, agents, representatives, and independent agents who sell or attempt to sell CCSO services are included. | A seller cannot avoid coverage merely by being labeled an agent or independent marketer. | Pure lead generation that stops before selling, attempting to sell, advising, or assisting remains fact-dependent. D.C. Law Library | C015 |
| § 28-4601(2)(D)(i)–(viii) | Express exclusions cover specified regulated lenders, insured banks and certain subsidiaries, qualifying credit unions, § 501(c)(3) organizations, collection agencies operating under D.C. law, D.C.-licensed attorneys acting within their practice, broker-dealers acting within applicable federal law, and FCRA consumer reporting agencies. | Each exclusion is actor- and conduct-specific. Nonprofit branding, an attorney relationship, or institutional affiliation alone is insufficient. | The claimant bears the burden of proving an exception or exemption under § 28-4606(b). D.C. Law Library+1 | C017–C019 |
| § 28-4601(3) | “Extension of credit” concerns deferred debt primarily for personal, family, or household purposes. | Purely business-purpose credit falls outside this Chapter 46 definition. | Mixed-purpose, guarantor, sole-proprietor, and personally liable business-card facts require separate analysis. D.C. Law Library | C020 |
| § 28-4602(a)–(c) | A covered CCSO operating in D.C. must file the prescribed registration statement, pay $300 initially and $200 annually, report information changes within ten days, and supply additional requested information before acceptance. | Registration is mandatory; it is not created by the repealed § 22-1201. | Last amended October 3, 2001. “Operates in the District” is not defined in Chapter 46. D.C. Law Library | C005, C006 |
| § 28-4603(1) | A CCSO may not charge or receive consideration before completion unless it has the § 28-4604 bond or trust. | This is a state-law exception to the state prohibition, not federal TSR authorization. | “Completion” is not defined in the Chapter 46 definitions. No authenticated DCMR interpretation was located. D.C. Law Library+1 | C025, C028 |
| § 28-4603(2) | Prohibits charging solely for certain referrals to a retail seller where substantially similar credit is available to the public. | This is a narrow referral prohibition, not a general authorization for all compensated referrals. | Does not resolve pure lead generation, creditor-referral compensation, or affiliate marketing outside its terms. D.C. Law Library | C015 |
| § 28-4603(3)–(7) | Prohibits specified false or misleading credit statements, deceptive omissions or methods, misleading use of “repair,” waiver attempts, and noncompliance with the chapter or rules. | Applies independently of registration and fee timing. | Current codified section traces its latest listed amendment to April 9, 1997. D.C. Law Library | C016, C029 |
| § 28-4604(a)–(b) | A provider receiving money before completion must maintain a $25,000 surety bond or a $25,000 minimum trust at a qualifying District institution. Security may support cancellation refunds, assessed damages, and complaint settlements. | The trust is provider financial security. It is not the consumer’s dedicated settlement account. | Enacted effective March 8, 1991. No indexed adjustment language appears in the section. D.C. Law Library | C014, C025 |
| § 28-4605(a)–(c) | Requires pre-contract or pre-payment disclosures, retention of signed disclosures, a detailed description of services and total charges, and a written signed contract containing all payment terms, including payments to the provider or another person. | Applies to covered CCSOs regardless of whether money is paid directly to the provider. | Drafting contains substantial credit-report-repair terminology; application to debt settlement is supported by OAG enforcement but has not been comprehensively construed by an appellate court. D.C. Law Library+1 | C026, C029 |
| § 28-4605(d)–(e) | Contract must include a five-calendar-day cancellation right; reimbursement is due within ten days after receipt of the cancellation notice; required documents must be given to the consumer. | Exact treatment of already completed services, third-party charges, or consumer account funds is not comprehensively specified in the text reviewed. | Enacted effective March 8, 1991. No separate current rule was authenticated. D.C. Law Library | C026 |
| § 28-4606 | Registrations receive APA hearing protection; the person claiming an exemption carries the burden; rights under other D.C. and federal law remain enforceable. | A claimed nonprofit, attorney, lender, or other exclusion must be proved by the claimant. The chapter does not displace the federal TSR. | Enacted effective March 8, 1991. D.C. Law Library | C017–C019, C025 |
| § 28-4607 | Provides criminal, civil, and private remedies for Chapter 46 violations. | Confirms the registration and conduct rules are enforceable, not merely advisory. | Last listed amendment June 11, 2013. Full remedies analysis remains for a later pass. D.C. Law Library | C001, C029 |
| § 28-4608 | Directs the Mayor to issue implementing rules covering registration, sample disclosures, contract and cancellation forms, and civil fines. | The statute contemplates an implementation layer beyond the Code text. | No current operative CCSO-specific rule or adoption order was authenticated in this pass. D.C. Law Library | C009, C033 |
| D.C. Code § 26-551.03; §§ 31-101, 31-103 | Transfers and assigns Chapter 46 financial-regulation functions to the banking regulator now operating within DISB. | DISB, through its banking organization, is the administering regulator. | § 26-551.03’s editor’s note expressly identifies Title 28, Chapter 46 in the transferred functions. D.C. Law Library+3 | C007 |
| Current DISB Banking Bureau/Divisions pages | Licensing Division reviews CCSO applications and maintains the non-depository licensing database/NMLS. | Operationally confirms the active regulatory category. | Webpage statements as accessed October 24, 2026; not statutory effective dates and not a CCSO-specific filing checklist. Disb+1 | C008–C010 |
| Model or status | Chapter 46 result | Other possible category | Authorization or exemption result | Remaining condition or failure case |
|---|---|---|---|---|
| For-profit, noncustodial principal-reduction negotiation | Answered, qualified: strong CCSO coverage under § 28-4601(2)(A)(iii). OAG has applied the CCSOA to services intended to resolve or reduce consumer debts. D.C. Law Library+3 | No separate debt-settlement license chapter was authenticated. | Chapter 46 registration required if the provider operates in D.C. and lacks an exclusion. | No controlling D.C. appellate debt-settlement decision located; current filing mechanics unresolved. |
| Student-loan debt relief or repayment-plan assistance for compensation | Answered, qualified: official OAG complaint treated such a provider as a CCSO. DC Attorney General+3 | Student-loan-servicer licensing could be separate if the company actually services loans; not analyzed here. | CCSO registration and Chapter 46 conditions apply under OAG’s pleaded theory. | The Student Aid document is a complaint, not a merits judgment. |
| Paid DMP or credit counseling without custody | Partial: paid advice or assistance concerning personal credit fits § 28-4601(2)(A)(iii). | No separate D.C. DMP statute or current DCMR category was authenticated. | Registration unless an exact exclusion, particularly § 501(c)(3), applies. | Creditor concessions, payment administration, and provider compensation facts may affect classification. |
| Genuinely free counseling with no direct or indirect valuable consideration | Partial, likely outside Chapter 46: the definition requires money or other valuable consideration. | Other consumer-protection laws could still apply. | No Chapter 46 registration on the stated no-consideration facts. | Referral payments, affiliate revenue, creditor funding, data monetization, or bundled charges may constitute consideration. D.C. Law Library |
| Custodial DMP receiving consumer money and paying creditors | Partial: counseling or assistance remains CCSO conduct. | Possible money-transmitter licensing because D.C. defines money transmission to include receiving money for transmission and requires a license absent an exemption. D.C. Law Library+2 | Chapter 46 registration plus any independently applicable money-transmitter authorization. | Exact funds flow, ownership, agency, bank relationship, and receipt/control must be established. No debt-relief or agent-of-payee exemption appears in the inspected §§ 26-1001–1003, but a complete interpretive pass remains open. |
| Independent consumer-controlled dedicated account | Partial: using a dedicated account does not remove the provider’s advice or negotiation from Chapter 46. | Money-transmission treatment depends on whether the provider or affiliate receives, controls, or transmits the funds. | CCSO registration still required if otherwise covered. | Account agreement, payment instructions, provider access, affiliate status, and withdrawal control are essential. |
| Provider- or affiliate-controlled dedicated account | Partial, elevated money-transmission risk: receipt or transmission by the provider or affiliate may fit § 26-1001(10). | Money transmitter. | Separate authorization potentially required. | No conclusion without actual account and funds-flow documents. |
| § 28-4604 provider trust account | Answered: this is $25,000 provider security supporting refunds and liabilities. | Not a money-transmission classification by itself. | Necessary for the Chapter 46 state-law pre-completion-payment branch. | Must not be mislabeled as the consumer’s settlement savings account. D.C. Law Library |
| Sales agent or independent closer selling the program | Answered: expressly included as a CCSO. | Individual licensing was not separately found. | Covered through the organization definition. | Outsourcing sales does not remove Chapter 46 coverage. D.C. Law Library |
| Pure compensated lead generator or referral source | Unresolved: inclusion depends on whether it sells or attempts to sell CCSO services, advises the consumer, or otherwise acts as an agent or representative. | CPPA, advertising, telemarketing, and referral rules may separately apply. | No blanket broker exemption established. | Need scripts, compensation, handoff, representations, and degree of participation. |
| Credit-repair promises or representations | Answered: directly covered by § 28-4601(2)(A)(i), subject to exclusions. | Conditional federal TSR credit-repair rule and CROA may overlap. | Chapter 46 registration if covered. | CROA applicability remains held as directed; no universal federal or state exemption inferred. |
| Organization actually exempt under IRC § 501(c)(3) | Answered: expressly excluded from the CCSO definition. | Other laws may remain applicable. | No Chapter 46 registration if the entity actually satisfies the exact exemption. | “Nonprofit” branding, state incorporation, or pending tax status is not enough; claimant bears the burden. D.C. Law Library+1 |
| Other nonprofit organization | Answered: no categorical exclusion merely because the entity is nonprofit. | Same analysis as commercial provider unless another exclusion applies. | Registration required if covered. | Must establish actual § 501(c)(3) status or another precise exclusion. |
| D.C.-licensed attorney performing services within the practice of law | Answered: expressly excluded. | Attorney ethics, fee, trust-account, and unauthorized-practice rules remain separate. | No Chapter 46 registration on facts satisfying both elements. | Lawyer must be licensed in D.C.; services must be within the course and scope of practice. D.C. Law Library+1 |
| Attorney-owned, attorney-affiliated, or out-of-state attorney business | Partial: no automatic exclusion. | Corporate, unauthorized-practice, fee-sharing, and attorney-regulation issues remain open. | Chapter 46 registration required unless the exact attorney exclusion is proved. | Marketing through a lawyer or retaining counsel does not transform nonlegal commercial services into the exclusion. |
| Banks, supervised lenders, credit unions, collection agencies, broker-dealers, and CRAs | Answered only to the statutory categories and scope. | Their own regulatory laws continue to apply. | Excluded only when the actor and conduct satisfy § 28-4601(2)(D). | Institutional affiliation or an affiliate relationship not described by the text is not enough. D.C. Law Library |
| Original creditor negotiating its own debt | Partial, likely outside ordinary CCSO coverage: the service is not ordinarily sold to the consumer concerning credit “by others,” and the creditor is acting on its own account. | Collection and consumer-protection law may apply. | No affirmative Chapter 46 authorization needed on ordinary self-creditor facts. | Avoid universal conclusion where an affiliate separately sells paid advisory or negotiation services. Chen supports a narrow own-credit boundary on its facts. GovInfo+1 |
| Pure business-purpose debt negotiation | Answered for Chapter 46: outside the definition to the extent the underlying credit is not primarily personal, family, or household. | Commercial-law and professional-regulation issues remain open. | No Chapter 46 registration on pure business-credit facts. | Mixed-purpose cards, personally guaranteed business debts, and sole-proprietor obligations require purpose-specific analysis. D.C. Law Library |
| Remote out-of-District provider soliciting and serving D.C. residents | Partial but high enforcement risk: “operates in the District” is undefined, yet OAG applied the statute to Florida and Maryland entities marketing or selling debt-relief services to District consumers. DC Attorney General+3 | Foreign-entity registration and BBL may be separate. | Treat District-facing sales and service as triggering Chapter 46 unless a contrary controlling authority is established. | No controlling appellate territorial test located. Marketing, solicitation, contracting, consumer residence, and performance facts matter. |
| Consumer unaware of provider or third-party payer | Partial: Chen found no CCSO relationship where the consumers were not solicited, did not understand themselves to be purchasing the service, and payment came from another person without their awareness. | Fact-specific. | Potentially outside Chapter 46 on comparable facts. | Chen is a 2011 federal trial-court decision, not a controlling D.C. Court of Appeals decision. GovInfo |
The statutory registration is filed with the Mayor. The relevant functions were transferred to the D.C. banking regulator and are now administered by DISB. Current DISB materials place CCSO applications in the Banking Licensing Division. D.C. Law Library+3
Legal category: Consumer Credit Service Organization registration under D.C. Code § 28-4602.
Current administering agency: District of Columbia Department of Insurance, Securities, and Banking, Banking Bureau, Licensing Division.
Statutory government charges:
These are government registration charges, not consumer service-fee limits. D.C. Law Library
The statute requires a form prescribed by the Mayor. DISB says its Licensing Division reviews CCSO applications and maintains NMLS. However:
The evidence supports an inference that NMLS may be involved in the back-end or broader non-depository database, but it does not establish the complete current CCSO submission route. Disb+3
A historical DISB biennial report stated that DISB had moved to a coordinated NMLS process for non-depository licensees and registrants. Its specific list of NMLS-managed categories did not expressly name CCSOs, and its statistics table likewise omitted them. Because that document covers fiscal years 2017–2018, it is operational history, not sufficient current application instructions. Disb+1
DISB directs consumers to NMLS Consumer Access for listed non-depository entities. The page does not expressly list CCSOs among those categories. The direct NMLS Consumer Access route could not be opened through the research tool in this pass, and no CCSO-specific public record was tested.
Therefore:
Section 28-4608 directs rulemaking for registration requirements, disclosures, contracts, cancellation forms, and fines. Title 16’s current index displays Chapter 1, Consumer Retail Credit, and Chapter 37, DISB Infractions. The visible Chapter 1 sections concern retail sellers, finance companies, and related consumer-credit topics; no CCSO-specific heading appears in the displayed list.
The displayed 1/1/1900 Chapter 1 dates were not treated as reliable promulgation or legal effective dates. The direct Chapter 37 section-list route failed in the web tool. Exact official-domain searches did not surface a current CCSO-specific rule or adoption order.
This supports only an unresolved-rule finding, not a conclusion that no implementing rules were ever adopted. D.C. Law Library+3
D.C. defines money transmission to include engaging in the business of receiving money for transmission or transmitting money by any means. A person engaging in that business must obtain a money-transmitter license unless an exemption applies.
The inspected statutory exemptions cover governments, specified regulated financial institutions, government-benefit transfers, and authorized delegates of a licensed transmitter. They do not expressly mention debt settlement, DMPs, credit counseling, dedicated accounts, or an agent-of-payee exclusion. D.C. Law Library+2
Accordingly:
Money-transmitter application, bond, fees, and dedicated-account interpretations remain later-pass issues.
Current D.C. law broadly requires a person doing business in the District to maintain a Basic Business License. “Business” includes compensated services offered in D.C.; “general sales and services” is the residual category for services not covered by another BBL category. DLCP currently directs applicants to BOSS and offers a BBL verification route. D.C. Law Library+5
A covered CCSO with a D.C. business location likely has a parallel BBL obligation, probably under the general-business residual category unless DLCP assigns another endorsement. However:
If applicable, the current statutory BBL fee text lists $49 for six months, $99 for two years, and $198 for four years, with specified low-revenue fee relief. Those are government charges, not consumer debt-relief fees. Because remote-provider BBL applicability and the conflicting applicability notes were not fully reconciled, the amounts should not yet be incorporated into a final D.C. launch-cost model. D.C. Law Library+2
A foreign filing entity doing business in D.C. generally must register under Title 29. Title 29 excludes certain activities from its own “doing business” test, including some interstate-commerce activity and orders accepted outside D.C.
Crucially, § 29-105.05(b) states that those exclusions do not determine whether the entity is subject to regulation under other D.C. law. A company therefore cannot use a Title 29 foreign-qualification exclusion as a Chapter 46 CCSO exemption. D.C. Law Library+1
Foreign qualification remains a separate entity-law issue requiring the provider’s actual solicitation, contracting, office, employee, and performance facts.
| Issue | Verified D.C. result | Limit |
|---|---|---|
| Chapter 46 initial government fee | $300 | Provider-to-government registration fee. |
| Chapter 46 annual government fee | $200 before April 2 or regulatory date | No current alternative regulatory date authenticated. |
| Consumer service-fee amount cap | HOLD | No percentage, flat-dollar, monthly, per-debt, savings, or aggregate ceiling authenticated. Absence from Chapter 46 is not proof of unlimited fees. |
| Money before completion | Prohibited unless the provider has the § 28-4604 security | Applicable federal TSR restrictions remain independently controlling where covered. |
| Bond | $25,000 | Surety must be legally permitted to do business in D.C. |
| Provider trust alternative | $25,000 minimum | Must be at a federally insured bank or savings and loan association located in D.C.; this is provider security. |
| “Completion” | Undefined in authenticated Chapter 46 text | DCMR interpretation or case law remains unresolved. |
| Total-charge disclosure | Required before contract or payment | Disclosure must include detailed services and total amount charged. |
| Written agreement | Required | Must state all payment terms, including payments to the provider or another person, services, refund promises, timing, and business/agent information. |
| Cancellation | Five calendar days after signing | Exact interaction with completed services or third-party charges remains unresolved. |
| Reimbursement after cancellation | Within ten days after receipt of cancellation notice | Scope and calculation were not further defined in authenticated rules. |
| Consumer funds in dedicated account | No D.C.-specific Chapter 46 account formula established | Federal dedicated-account requirements were already handled in P1; D.C. money-transmission treatment depends on actual control and receipt. |
The statutory support for this table is §§ 28-4602 through 28-4605. D.C. Law Library+3
No fee example is supplied because no current D.C. consumer-service fee formula or amount ceiling was established.
| P1 cell | PASS-02 treatment | Result |
|---|---|---|
| S_DC-P1-C003 — custodial, noncustodial, DMP, and counseling classifications unresolved | Superseded in part by P2 C001–C022. Chapter 46 is the governing affirmative framework; noncustodial principal-reduction and paid counseling have strong CCSO coverage. Custody, money transmission, dedicated-account control, and some DMP conditions remain partial. | Partial → substantially answered, with enumerated sub-gaps |
| S_DC-P1-C004 — repeal does not establish licensing or fee permission | Preserved. Chapter 46, not repeal, supplies the current affirmative registration framework. | Confirmed and supplemented |
| S_DC-P1-C005 — DISB complaint material did not verify a debt-settlement license | Replaced in part. DISB is the current CCSO administrator, and registration is required under § 28-4602. Current prescribed form, submission route, and CCSO-specific public lookup remain unresolved. | Partial → regulator and legal category answered; procedure held |
| S_DC-P1-C006 — no current D.C. commercial consumer-fee ceiling authenticated | Preserved. P2 establishes registration fees, state pre-completion security, contract disclosures, cancellation, and reimbursement; it does not establish a consumer-service fee amount cap. | Still HOLD |
| S_DC-P1-C008 — D.C.-specific provider fee trigger unresolved | Partially superseded. Chapter 46 prohibits pre-completion receipt absent bond/trust, but “completion” and any finer D.C. earning milestones remain unresolved. | Partial |
| P1 early § 4 federal-text retrieval hold | Superseded by P1’s later supplemental federal finding and final self-check. | Closed before P2; not a current gap |
| S_DC-P1-C014 — no named provider authorization verified | Preserved only as “not investigated.” No named provider was checked in P2, and no adverse status inference is permitted. | Not investigated |
Issuer: Council of the District of Columbia, D.C. Law Library Literal URLs:
Pinpoints: §§ 28-4601(1)–(4), 28-4602(a)–(c), 28-4603(1)–(7), 28-4604(a)–(b), 28-4605(a)–(e), 28-4606(a)–(c), 28-4607, 28-4608. Status/version: Current codification read October 24, 2026. Individual section histories range from the 1991 enactment through the May 6, 2020 amendment to § 28-4601. Actual check: All operative sections directly opened and read. Limit: Does not itself supply a current public application form, detailed territorial definition, definition of “completion,” or consumer fee amount cap. D.C. Law Library+8
Issuer: Council of the District of Columbia Literal URL: https://code.dccouncil.gov/us/dc/council/laws/8-236 Pinpoint: Enacting law for the CCSOA; effective March 8, 1991, 38 DCR 306, as reflected in the codified section histories. Actual check: Law metadata and codification links identified; complete session-law HTML was not relied upon as independently read text. Limit: Current operative analysis is based on S001’s codified text.
Issuer: D.C. Law Library Literal URL: https://code.dccouncil.gov/us/dc/council/code Pinpoint: Publication-information block. Status: Current through October 22, 2026; last codified permanent and emergency measures identified above. Actual check: Directly opened and read. Limit: Publisher currency is not proof that every administrative rule or noncodified order was found. D.C. Law Library
Issuer: D.C. Law Library Literal URL: https://code.dccouncil.gov/us/dc/council/code/sections/26-551.03 Pinpoints: Subsections (b), (g); editor’s note quoting D.C. Law 14-28 § 802. Status: Current codification. Actual check: Directly read. Use: Administration of Banking Code; transfer of Title 28, Chapter 46 functions to the banking regulator. D.C. Law Library+1
Issuer: D.C. Law Library Literal URLs:
Pinpoints: § 31-101(2), (3), (5); § 31-103(a)(3). Actual check: Directly read. Use: Identifies DISB, the Commissioner, and administration through the Securities and Banking Bureau. D.C. Law Library+1
Issuer: DISB Literal URL: https://disb.dc.gov/page/banking-bureau Pinpoints: Licensing Division description, especially the bullets naming CCSOs and the non-depository licensing database. Actual check: Current page directly read October 24, 2026. Limit: Says “license applications” but does not supply the Chapter 46 form or identify the precise registration submission route. Disb
Issuer: DISB Literal URL: https://disb.dc.gov/page/divisions-1 Pinpoints: Banking Division, Licensing Division bullets. Actual check: Directly read. Use: Names CCSOs among reviewed applications and identifies NMLS as the maintained non-depository database. Limit: Does not expressly state that the Chapter 46 CCSO registration is currently filed through a particular NMLS license type. Disb
Issuer: DISB Literal URL: https://disb.dc.gov/page/compliance-requirements-banking Pinpoints: Non-depository licensing list and forms section. Actual check: Directly read. Limit: Current list omits CCSOs; omission is evidence of an operational gap, not statutory noncoverage. Disb
Issuer: DISB Literal URL: https://disb.dc.gov/page/non-depository-institutions-operating-dc Pinpoints: Lines directing users to NMLS Consumer Access and enumerating categories. Actual check: Directly read. Limit: CCSOs are not expressly included in the page’s enumeration. No named provider was checked. Disb
Issuer: DISB Literal URL: https://disb.dc.gov/page/licensing-and-registration-requirements Pinpoint: Forms and application listing. Actual check: Directly read. Limit: No current CCSO form or checklist surfaced. Disb
Issuer: Office of Documents and Administrative Issuances Literal URLs:
Pinpoints: Title 16 chapter list; Chapter 1 section list. Actual check: Title index and Chapter 1 list directly read; Chapter 37 route failed. Limit: No CCSO-specific operative rule or adoption order authenticated. The displayed 1/1/1900 dates were not accepted as actual rule effective dates. DCRegs+2
Issuer: D.C. Office of Attorney General Literal URL: https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc Date: May 25, 2016. Pinpoints: Description of Florida provider, District marketing, debt-relief services, and CCSOA advance-fee allegations. Actual check: Directly read. Limit: Press release summarizing allegations. DC Attorney General
Issuer: D.C. Office of Attorney General / D.C. Superior Court filing Literal URL: https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf Pinpoints: Complaint ¶¶ 3, 24, 29, 37–47; printed pages 2, 7–8, 11–12. Actual check: Parsed text read and printed pages 11–12 visually inspected. Limit: Allegations, not adjudicated findings. DC Attorney General+2
Issuer: D.C. Office of Attorney General Literal URL: https://oag.dc.gov/release/attorney-general-racine-obtains-settlement-against Date: May 23, 2017. Pinpoints: Maryland provider, District consumers, debt validation/reduction services, settlement terms. Actual check: Directly read. Limit: Agency summary of a consent resolution. DC Attorney General
Issuer: D.C. Superior Court / D.C. OAG Literal URL: https://oag.dc.gov/sites/default/files/2018-02/Release-May-23-2017-Burlington-Financial-Group-Consent-Judgment-and-Order.pdf Pinpoints: Printed pages 2–4, especially ¶¶ 2, 4, 6–8, 11, 18, and 22–23. Actual check: Relevant pages visually inspected. Limit: Party-specific consent judgment; defendants denied the alleged violations. DC Attorney General+2
Issuer: D.C. Office of Attorney General Literal URL: https://oag.dc.gov/sites/default/files/2018-02/Release-August-8-2017-YF-Solution-Assurance-of-Voluntary-Compliance.pdf Pinpoints: Printed pages 3–4, ¶¶ 8–14 and 18. Actual check: Relevant pages visually inspected. Limit: Assurance and stipulations, not a controlling judicial interpretation. DC Attorney General+1
Issuer: U.S. District Court for the District of Columbia Literal URL: https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf Citation/date: Civil Action No. 08-0999 (JDB), memorandum opinion filed March 8, 2011. Pinpoints: Printed pages 39–40. Actual check: Relevant pages visually inspected. Limit: Federal trial-court decision; unusual own-credit and consumer-awareness facts; not controlling D.C. appellate authority. GovInfo+1
Issuer: D.C. Law Library Literal URLs:
Pinpoints: §§ 26-1001(10), 26-1002(a), 26-1003(a)–(b), 26-1004. Actual check: Directly read. Limit: Full application, bonding, fees, interpretive decisions, and all funds-flow exceptions were not completed. D.C. Law Library+3
Issuer: D.C. Law Library Literal URLs:
Pinpoints: Definitions, license requirement, general-sales-and-services category, statutory fees, and retention of regulator eligibility judgments. Actual check: Directly read. Limit: Conflicting implementation notes and remote-provider/location application remain unresolved. D.C. Law Library+5
Issuer: Department of Licensing and Consumer Protection Literal URL: https://dlcp.dc.gov/service/business-licensing-division Pinpoints: Business definition, requirement, BOSS application route, General Business category, and BBL verification. Actual check: Directly read. Limit: Does not decide the DISB CCSO registration or remote/no-location application. DCRA+2
Issuer: D.C. Law Library Literal URLs:
Pinpoints: Registration duty; activities not constituting business under Title 29; savings clause for regulation under other D.C. law. Actual check: Directly read. D.C. Law Library+1
Issuer: DISB Literal URL: https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/Non_Dep_Initial_Lic_Instructions_051214.pdf Version: May 2014. Actual check: Text read and page 1 visually inspected. Limit: Historical; does not list CCSOs among the covered application categories; contains superseded addresses and paper-submission instructions; not used as current CCSO procedure. Disb+1
Issuer: DISB Literal URL: https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20(1).pdf Pinpoint: Printed page 14, licensing-system discussion. Actual check: Text read and page visually inspected. Limit: Historical operational context; not current filing instructions. Disb+1
| Claim ID | Precise assertion | Sources/pinpoints | Conditions and confidence limit |
|---|---|---|---|
| S_DC-P2-C001 | D.C. Code Title 28, Chapter 46 is the current affirmative consumer-credit-service-organization framework. | S001, Chapter heading and §§ 4601–4608 | High; does not by itself resolve every debt-relief fact pattern. |
| C002 | Paid advice or assistance concerning personal, household, or family credit is within the CCSO definition. | S001, § 28-4601(2)(A)(iii) | High as statutory text. |
| C003 | A paid noncustodial provider negotiating reduction or resolution of personal debts has a strong textual fit under § 28-4601(2)(A)(iii). | S001; S013; S015; S016 | Strong qualified conclusion; statute does not use the words “debt settlement.” |
| C004 | D.C. OAG has applied the CCSOA to student-debt relief and services intended to validate, dispute, resolve, or reduce consumer debts. | S012–S016 | High as enforcement position; complaints and settlements are not controlling appellate holdings. |
| C005 | A covered CCSO operating in D.C. must register and pay $300 initially and $200 annually. | S001, § 28-4602(a) | High. |
| C006 | Chapter 46 does not define “operates in the District”; OAG has pursued out-of-state entities serving District consumers. | S001, § 28-4602; S013, complaint ¶ 3; S015, pp. 2–3 | High for text and enforcement facts; controlling territorial test unresolved. |
| C007 | DISB is the current administering regulator for Chapter 46. | S004–S007 | High. |
| C008 | DISB’s Licensing Division currently identifies CCSOs as an application category and maintains the non-depository/NMLS database. | S006–S007 | High as agency operational statement. |
| C009 | No current CCSO-specific prescribed form, checklist, or complete submission route was authenticated. | S008–S011; S022–S023 | Research-result limitation, not proof that no form exists. |
| C010 | A CCSO-specific public-registration lookup pathway was not verified. | S009; failed NMLS route | No named provider was checked. |
| C011 | Noncustodial debt negotiation does not require custody to fit the CCSO advice/assistance definition. | S001, § 28-4601(2)(A)(iii) | Strong textual conclusion. |
| C012 | Paid DMP or credit counseling can fit Chapter 46 even without principal reduction. | S001, § 28-4601(2)(A)(iii) | Actual services and consideration matter. |
| C013 | A provider or affiliate receiving consumer money for onward transmission may separately require a money-transmitter license. | S018, §§ 26-1001(10), 26-1002, 26-1003 | Conditional; actual funds flow and interpretations unresolved. |
| C014 | The § 28-4604 trust is provider security and is not the consumer’s dedicated settlement account. | S001, § 28-4604 | High. |
| C015 | Agents and independent persons who sell or attempt to sell CCSO services are included; pure lead generation remains fact-dependent. | S001, § 28-4601(2)(B)–(C) | High for sellers; unresolved for passive referrals. |
| C016 | Paid credit-repair representations are directly within § 28-4601(2)(A)(i). | S001 | High; CROA overlap held. |
| C017 | Only an actual § 501(c)(3) organization receives the listed nonprofit exclusion. | S001, § 28-4601(2)(D)(iv); § 28-4606(b) | High; claimant bears burden. |
| C018 | Attorney exclusion requires D.C. licensure and services within the course and scope of practice. | S001, § 28-4601(2)(D)(vi); § 28-4606(b) | High; affiliation alone insufficient. |
| C019 | Other institutional exclusions are actor- and conduct-specific and do not create a general affiliate exemption. | S001, § 28-4601(2)(D) | High as limited reading. |
| C020 | Pure business-purpose debt is outside Chapter 46’s consumer-credit definition. | S001, § 28-4601(3) | High; mixed-purpose treatment unresolved. |
| C021 | A genuinely free service with no valuable consideration is outside the CCSO definition. | S001, § 28-4601(2)(A) | Qualified; indirect compensation may alter result. |
| C022 | Own-credit and consumer-unaware transactions can fall outside Chapter 46; Chen supports this only on its facts. | S017, pp. 39–40 | Moderate; federal trial-court authority only. |
| C023 | A parallel BBL likely applies to a CCSO doing business from a D.C. location; remote/no-location treatment is unresolved. | S019–S020 | Partial due statutory location language and applicability-note conflict. |
| C024 | Title 29 foreign-entity exclusions do not determine Chapter 46 regulatory coverage. | S021, § 29-105.05(b) | High. |
| C025 | Chapter 46 bars pre-completion receipt absent the $25,000 bond or trust. | S001, §§ 28-4603(1), 28-4604 | High as state rule; no federal authorization inferred. |
| C026 | Chapter 46 requires pre-contract disclosures, a written contract, five-day cancellation, and reimbursement within ten days. | S001, § 28-4605 | High as statutory text. |
| C027 | No current D.C. consumer-service fee amount ceiling was authenticated. | Complete S001 review; S011 rule search | Evidence gap, not proof of no cap or unlimited fees. |
| C028 | “Completion” is not defined in authenticated Chapter 46 text. | S001, §§ 28-4601–4608 | High for the chapter; rule or case interpretation unresolved. |
| C029 | OAG pleadings and resolutions support coverage but do not replace controlling judicial construction. | S012–S016 | High methodological qualification. |
| C030 | No named provider’s registration or authorization was checked. | Scope limitation | Not an adverse status finding. |
| C031 | Public-source evidence is insufficient to mark D.C. operationally launch-ready because the current filing and lookup mechanics remain incomplete. | C005, C007–C010 | Operational conclusion, not denial of legal registration availability. |
| C032 | P1’s early federal-text hold was superseded by P1’s later verified TSR finding. | P1 internal record supplied in prompt | Closed P1 issue; federal overview not repeated. |
| C033 | No current operative CCSO-specific DCMR rule or adoption order was authenticated. | S001 § 28-4608; S011 | Search limitation, not exhaustive absence claim. |
| Model or legal category | Status | Claims | Exact missing evidence and next investigation |
|---|---|---|---|
| Affirmative governing statute | Answered | C001–C005 | Preserve Chapter 46 as controlling starting point. |
| For-profit noncustodial principal reduction | Answered, qualified | C003–C004, C011 | Target controlling D.C. appellate authority or a final administrative decision directly construing debt settlement. |
| Remote provider nexus | Partial | C006 | Search D.C. Court of Appeals, Superior Court orders, DISB decisions, and rulemaking for “operates in the District”; test solicitation, contracting, and performance factors. |
| Issuing regulator | Answered | C007–C008 | None for agency identity. |
| Current application form/checklist | Unresolved | C009 | Locate the current Mayor/DISB-prescribed CCSO registration statement, state checklist, renewal form, and submission method from DISB, NMLS state-resource materials, D.C. Register notices, or archived agency rulemaking. |
| Current public lookup | Unresolved | C010 | Establish whether CCSOs appear in NMLS Consumer Access, a separate DISB database, or another public roster; do not test a named provider until the category is identified. |
| Operative DCMR registration rules | Unresolved | C033 | Retrieve complete Chapter 37 text, search D.C. Register rulemaking history, and locate any final Chapter 46 registration/disclosure/cancellation rules and Council review records. |
| Noncustodial DMP or credit counseling | Partial | C012 | Obtain D.C. administrative or judicial classification and review actual compensation and services. |
| Custodial DMP | Partial | C013 | Map funds from consumer through each account and entity; complete money-transmission licensing and exemption pass. |
| Consumer-controlled dedicated account | Partial | C013–C014 | Review account contract, consumer ownership, provider access, payment direction, withdrawal, and affiliate roles. |
| Provider- or affiliate-controlled account | Partial | C013 | Complete money-transmitter authorization, delegate, bond, permissible-investment, and application review. |
| Provider § 28-4604 trust | Answered | C014, C025 | Later pass should confirm approved trust form, depository evidence, and regulator filing treatment. |
| Compensated sales agents | Answered | C015 | Later pass may inspect individual liability and registration practices. |
| Passive lead generators and referrals | Unresolved | C015 | Review scripts, handoff, sale attempts, compensation, branding, data transfer, and creditor/referral relationships. |
| Credit-repair representations | Answered for D.C.; federal overlap partial | C016 | Complete conditional CROA applicability and any separate D.C. credit-reporting interpretations. |
| § 501(c)(3) exclusion | Answered | C017 | Verify actual IRS status and operating entity identity for any provider claiming it. |
| Attorney exclusion | Answered in text; factual use partial | C018 | Verify D.C. bar status, engagement structure, legal work, nonlawyer affiliate conduct, fee sharing, and scope of practice. |
| Institutional exclusions | Answered in text | C019 | Match actual entity and conduct to each clause; do not extend exclusions by analogy. |
| Business-purpose obligations | Answered for pure business debt | C020 | Develop mixed-purpose and sole-proprietor allocation rules if needed. |
| Free counseling | Partial | C021 | Investigate indirect or third-party consideration. |
| Original creditor/self-creditor | Partial | C022 | Search controlling D.C. authority; distinguish self-creditor activity from separately sold advisory services. |
| Money transmission | Partial | C013 | Complete full statute, DCMR, DISB checklist, exemptions, interpretive orders, and account-flow analysis. |
| BBL | Partial | C023 | Reconcile conflicting implementation notes and determine remote/no-premises treatment and correct endorsement. |
| Foreign-entity qualification | Partial | C024 | Apply Title 29 to actual solicitation, contracting, employees, offices, and transaction pattern. |
| State pre-completion rule | Answered in text | C025, C028 | Locate any rule or case defining completion; keep federal TSR independent. |
| Consumer fee amount cap | Unresolved | C027 | Search final Chapter 46 regulations, DISB orders, D.C. Register, fee bulletins, and controlling cases. No CPI or borrowed model-act calculation. |
| Contract, cancellation, reimbursement | Answered at statutory level; implementation partial | C026 | Obtain any mandatory forms or implementing rules and later analyze cancellation calculations. |
| Named provider authorization | Not investigated | C030 | Only after the correct registry/category and lookup methodology are verified. |
| Market launch readiness | HOLD | C031 | Verify current registration filing pathway and public or official confirmation mechanism before operational approval. |
| Agreement, full funds handling, bond forms, remedies, limitations, exemptions, secured debt, sector, local, tribal, contract, and full case law | Outside P2 except intersections above | — | Preserve for later passes; no acceptance by implication. |
| Log ID | Route or query checked | Result | Evidentiary treatment |
|---|---|---|---|
| F001 | Full official Chapter 46 section sequence, §§ 28-4601–4608 | All sections opened and read | Primary controlling text |
| F002 | Official D.C. Code searches for debt settlement, debt management, credit counseling, and debt adjusting | No separate current provider chapter surfaced beyond Chapter 46 and unrelated provisions | Documented search coverage only; not proof of absence |
| F003 | https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16 | Title 16 index read; Chapters 1 and 37 identified | Primary index |
| F004 | https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-1 | Consumer Retail Credit section list read; no CCSO heading displayed | Does not establish absence from other chapters or register notices |
| F005 | https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-37 | Web tool returned non-retryable open failure | Chapter 37 operative text remains unread |
| F006 | Official-domain D.C. Register searches for “consumer credit service organization,” “debt settlement,” “debt management,” “credit counseling,” and “28-4608” | No matching current CCSO implementation rule was authenticated | Search limitation; no exhaustive absence claim |
| F007 | Current DISB Banking Bureau and Divisions pages | CCSO application category and Licensing Division established | Current operational support |
| F008 | Current DISB banking compliance, verification, and forms pages | CCSO-specific checklist/form/category not displayed | Public procedure remains unresolved |
| F009 | https://www.nmlsconsumeraccess.org through the research tool | Direct route could not be opened | No provider or category lookup performed |
| F010 | Current NMLS/official-domain searches for a D.C. CCSO state checklist | No current D.C. CCSO-specific checklist authenticated | Does not establish that NMLS cannot process the category |
| F011 | May 2014 DISB initial non-depository instructions | Document read and visually inspected; categories omitted CCSO and instructions are historical | Excluded as current procedure |
| F012 | DISB FY 2017–2018 report | Historical NMLS transition discussion read and visually inspected | Historical context only |
| F013 | Student Aid Center complaint PDF | Parsed text read; relevant pages visually inspected | Allegations, not adjudication |
| F014 | Burlington consent judgment PDF | Relevant pages visually inspected | Party-specific consent; defendants denied violations |
| F015 | YF assurance PDF | Relevant pages visually inspected | Assurance and stipulations, not precedent |
| F016 | Chen opinion PDF | Relevant pages visually inspected | Federal trial-court boundary authority |
| F017 | Targeted D.C. and federal case searches for CCSOA and debt-relief construction | Chen located; no controlling D.C. Court of Appeals debt-settlement decision located | Targeted result only, not exhaustive case-law absence finding |
| F018 | Money-transmission §§ 26-1001–1004 | Directly read | Preliminary parallel-category analysis only |
| F019 | BBL and foreign-entity provisions | Directly read | Parallel-category analysis; remote application unresolved |
| F020 | Named provider lookup | Deliberately not performed | No provider-status claim |
The decisive PASS-01 gap is partly closed:
This is a focused same-coordinator follow-up, not independent review, qualified legal approval, publication readiness, state acceptance, or A066 acceptance.
PASS-02 status: AFFIRMATIVE FRAMEWORK ESTABLISHED; OPERATIONAL REGISTRATION PATH AND CONSUMER FEE AMOUNTS REMAIN PARTIAL/HOLD.
END S_DC PASS-02.
Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
These components repair their stated scope. They do not replace every other finding in this research series.
P02 audit-trail repairs and remaining public CCSO procedure/rule gaps →Authority and pinpoint · Operative rule and covered conduct · Authorization, exemption, or condition · 19 data rows
| Authority and pinpoint | Operative rule and covered conduct | Authorization, exemption, or condition | Version/effectiveness and limits | Claims |
|---|---|---|---|---|
| D.C. Code § 28-4601(1) | “Consumer” is a person solicited to purchase or purchasing CCSO services. Consumer awareness and purchase or solicitation matter. | Establishes the protected customer relationship; it does not require that every payment come directly from the consumer. | Enacted effective March 8, 1991. No separate amendment shown for subsection (1). Chen applied this definition narrowly on unusual facts involving no consumer solicitation or awareness. D.C. Law Library +1 | C002, C022 |
| § 28-4601(2)(A)(i) | Paid services represented as improving a consumer’s credit record, history, or rating are directly covered. | Covered unless an exact subsection (D) exclusion applies. | Section last amended May 6, 2020. CROA applicability remains outside this pass. D.C. Law Library | C002, C016 |
| § 28-4601(2)(A)(ii) | Paid assistance obtaining an extension of credit for a consumer is covered. | Same exclusions. | “Extension of credit by others” limits the definition; Chen rejected coverage where the defendants obtained funds in their own names and then extended their own alleged credit. D.C. Law Library +2 | C002, C022 |
| § 28-4601(2)(A)(iii) | Paid advice or assistance concerning any matter related to personal, household, or family credit is covered. | Principal-reduction negotiation, debt validation, dispute assistance, DMP counseling, and similar services have a strong textual fit, subject to actual facts and exclusions. | The section does not say “debt settlement.” OAG’s debt-relief actions supply official enforcement support rather than binding appellate construction. D.C. Law Library +4 | C003, C004, C011, C012 |
| § 28-4601(2)(B)–(C) | Salespersons, agents, representatives, and independent agents who sell or attempt to sell CCSO services are included. | A seller cannot avoid coverage merely by being labeled an agent or independent marketer. | Pure lead generation that stops before selling, attempting to sell, advising, or assisting remains fact-dependent. D.C. Law Library | C015 |
| § 28-4601(2)(D)(i)–(viii) | Express exclusions cover specified regulated lenders, insured banks and certain subsidiaries, qualifying credit unions, § 501(c)(3) organizations, collection agencies operating under D.C. law, D.C.-licensed attorneys acting within their practice, broker-dealers acting within applicable federal law, and FCRA consumer reporting agencies. | Each exclusion is actor- and conduct-specific. Nonprofit branding, an attorney relationship, or institutional affiliation alone is insufficient. | The claimant bears the burden of proving an exception or exemption under § 28-4606(b). D.C. Law Library +1 | C017–C019 |
| § 28-4601(3) | “Extension of credit” concerns deferred debt primarily for personal, family, or household purposes. | Purely business-purpose credit falls outside this Chapter 46 definition. | Mixed-purpose, guarantor, sole-proprietor, and personally liable business-card facts require separate analysis. D.C. Law Library | C020 |
| § 28-4602(a)–(c) | A covered CCSO operating in D.C. must file the prescribed registration statement, pay $300 initially and $200 annually, report information changes within ten days, and supply additional requested information before acceptance. | Registration is mandatory; it is not created by the repealed § 22-1201. | Last amended October 3, 2001. “Operates in the District” is not defined in Chapter 46. D.C. Law Library | C005, C006 |
| § 28-4603(1) | A CCSO may not charge or receive consideration before completion unless it has the § 28-4604 bond or trust. | This is a state-law exception to the state prohibition, not federal TSR authorization. | “Completion” is not defined in the Chapter 46 definitions. No authenticated DCMR interpretation was located. D.C. Law Library +1 | C025, C028 |
| § 28-4603(2) | Prohibits charging solely for certain referrals to a retail seller where substantially similar credit is available to the public. | This is a narrow referral prohibition, not a general authorization for all compensated referrals. | Does not resolve pure lead generation, creditor-referral compensation, or affiliate marketing outside its terms. D.C. Law Library | C015 |
| § 28-4603(3)–(7) | Prohibits specified false or misleading credit statements, deceptive omissions or methods, misleading use of “repair,” waiver attempts, and noncompliance with the chapter or rules. | Applies independently of registration and fee timing. | Current codified section traces its latest listed amendment to April 9, 1997. D.C. Law Library | C016, C029 |
| § 28-4604(a)–(b) | A provider receiving money before completion must maintain a $25,000 surety bond or a $25,000 minimum trust at a qualifying District institution. Security may support cancellation refunds, assessed damages, and complaint settlements. | The trust is provider financial security. It is not the consumer’s dedicated settlement account. | Enacted effective March 8, 1991. No indexed adjustment language appears in the section. D.C. Law Library | C014, C025 |
| § 28-4605(a)–(c) | Requires pre-contract or pre-payment disclosures, retention of signed disclosures, a detailed description of services and total charges, and a written signed contract containing all payment terms, including payments to the provider or another person. | Applies to covered CCSOs regardless of whether money is paid directly to the provider. | Drafting contains substantial credit-report-repair terminology; application to debt settlement is supported by OAG enforcement but has not been comprehensively construed by an appellate court. D.C. Law Library +1 | C026, C029 |
| § 28-4605(d)–(e) | Contract must include a five-calendar-day cancellation right; reimbursement is due within ten days after receipt of the cancellation notice; required documents must be given to the consumer. | Exact treatment of already completed services, third-party charges, or consumer account funds is not comprehensively specified in the text reviewed. | Enacted effective March 8, 1991. No separate current rule was authenticated. D.C. Law Library | C026 |
| § 28-4606 | Registrations receive APA hearing protection; the person claiming an exemption carries the burden; rights under other D.C. and federal law remain enforceable. | A claimed nonprofit, attorney, lender, or other exclusion must be proved by the claimant. The chapter does not displace the federal TSR. | Enacted effective March 8, 1991. D.C. Law Library | C017–C019, C025 |
| § 28-4607 | Provides criminal, civil, and private remedies for Chapter 46 violations. | Confirms the registration and conduct rules are enforceable, not merely advisory. | Last listed amendment June 11, 2013. Full remedies analysis remains for a later pass. D.C. Law Library | C001, C029 |
| § 28-4608 | Directs the Mayor to issue implementing rules covering registration, sample disclosures, contract and cancellation forms, and civil fines. | The statute contemplates an implementation layer beyond the Code text. | No current operative CCSO-specific rule or adoption order was authenticated in this pass. D.C. Law Library | C009, C033 |
| D.C. Code § 26-551.03; §§ 31-101, 31-103 | Transfers and assigns Chapter 46 financial-regulation functions to the banking regulator now operating within DISB. | DISB, through its banking organization, is the administering regulator. | § 26-551.03’s editor’s note expressly identifies Title 28, Chapter 46 in the transferred functions. D.C. Law Library +3 | C007 |
| Current DISB Banking Bureau/Divisions pages | Licensing Division reviews CCSO applications and maintains the non-depository licensing database/NMLS. | Operationally confirms the active regulatory category. | Webpage statements as accessed October 24, 2026; not statutory effective dates and not a CCSO-specific filing checklist. Disb +1 | C008–C010 |
Model or status · Chapter 46 result · Other possible category · 20 data rows
| Model or status | Chapter 46 result | Other possible category | Authorization or exemption result | Remaining condition or failure case |
|---|---|---|---|---|
| For-profit, noncustodial principal-reduction negotiation | Answered, qualified: strong CCSO coverage under § 28-4601(2)(A)(iii). OAG has applied the CCSOA to services intended to resolve or reduce consumer debts. D.C. Law Library +3 | No separate debt-settlement license chapter was authenticated. | Chapter 46 registration required if the provider operates in D.C. and lacks an exclusion. | No controlling D.C. appellate debt-settlement decision located; current filing mechanics unresolved. |
| Student-loan debt relief or repayment-plan assistance for compensation | Answered, qualified: official OAG complaint treated such a provider as a CCSO. DC Attorney General +3 | Student-loan-servicer licensing could be separate if the company actually services loans; not analyzed here. | CCSO registration and Chapter 46 conditions apply under OAG’s pleaded theory. | The Student Aid document is a complaint, not a merits judgment. |
| Paid DMP or credit counseling without custody | Partial: paid advice or assistance concerning personal credit fits § 28-4601(2)(A)(iii). | No separate D.C. DMP statute or current DCMR category was authenticated. | Registration unless an exact exclusion, particularly § 501(c)(3), applies. | Creditor concessions, payment administration, and provider compensation facts may affect classification. |
| Genuinely free counseling with no direct or indirect valuable consideration | Partial, likely outside Chapter 46: the definition requires money or other valuable consideration. | Other consumer-protection laws could still apply. | No Chapter 46 registration on the stated no-consideration facts. | Referral payments, affiliate revenue, creditor funding, data monetization, or bundled charges may constitute consideration. D.C. Law Library |
| Custodial DMP receiving consumer money and paying creditors | Partial: counseling or assistance remains CCSO conduct. | Possible money-transmitter licensing because D.C. defines money transmission to include receiving money for transmission and requires a license absent an exemption. D.C. Law Library +2 | Chapter 46 registration plus any independently applicable money-transmitter authorization. | Exact funds flow, ownership, agency, bank relationship, and receipt/control must be established. No debt-relief or agent-of-payee exemption appears in the inspected §§ 26-1001–1003, but a complete interpretive pass remains open. |
| Independent consumer-controlled dedicated account | Partial: using a dedicated account does not remove the provider’s advice or negotiation from Chapter 46. | Money-transmission treatment depends on whether the provider or affiliate receives, controls, or transmits the funds. | CCSO registration still required if otherwise covered. | Account agreement, payment instructions, provider access, affiliate status, and withdrawal control are essential. |
| Provider- or affiliate-controlled dedicated account | Partial, elevated money-transmission risk: receipt or transmission by the provider or affiliate may fit § 26-1001(10). | Money transmitter. | Separate authorization potentially required. | No conclusion without actual account and funds-flow documents. |
| § 28-4604 provider trust account | Answered: this is $25,000 provider security supporting refunds and liabilities. | Not a money-transmission classification by itself. | Necessary for the Chapter 46 state-law pre-completion-payment branch. | Must not be mislabeled as the consumer’s settlement savings account. D.C. Law Library |
| Sales agent or independent closer selling the program | Answered: expressly included as a CCSO. | Individual licensing was not separately found. | Covered through the organization definition. | Outsourcing sales does not remove Chapter 46 coverage. D.C. Law Library |
| Pure compensated lead generator or referral source | Unresolved: inclusion depends on whether it sells or attempts to sell CCSO services, advises the consumer, or otherwise acts as an agent or representative. | CPPA, advertising, telemarketing, and referral rules may separately apply. | No blanket broker exemption established. | Need scripts, compensation, handoff, representations, and degree of participation. |
| Credit-repair promises or representations | Answered: directly covered by § 28-4601(2)(A)(i), subject to exclusions. | Conditional federal TSR credit-repair rule and CROA may overlap. | Chapter 46 registration if covered. | CROA applicability remains held as directed; no universal federal or state exemption inferred. |
| Organization actually exempt under IRC § 501(c)(3) | Answered: expressly excluded from the CCSO definition. | Other laws may remain applicable. | No Chapter 46 registration if the entity actually satisfies the exact exemption. | “Nonprofit” branding, state incorporation, or pending tax status is not enough; claimant bears the burden. D.C. Law Library +1 |
| Other nonprofit organization | Answered: no categorical exclusion merely because the entity is nonprofit. | Same analysis as commercial provider unless another exclusion applies. | Registration required if covered. | Must establish actual § 501(c)(3) status or another precise exclusion. |
| D.C.-licensed attorney performing services within the practice of law | Answered: expressly excluded. | Attorney ethics, fee, trust-account, and unauthorized-practice rules remain separate. | No Chapter 46 registration on facts satisfying both elements. | Lawyer must be licensed in D.C.; services must be within the course and scope of practice. D.C. Law Library +1 |
| Attorney-owned, attorney-affiliated, or out-of-state attorney business | Partial: no automatic exclusion. | Corporate, unauthorized-practice, fee-sharing, and attorney-regulation issues remain open. | Chapter 46 registration required unless the exact attorney exclusion is proved. | Marketing through a lawyer or retaining counsel does not transform nonlegal commercial services into the exclusion. |
| Banks, supervised lenders, credit unions, collection agencies, broker-dealers, and CRAs | Answered only to the statutory categories and scope. | Their own regulatory laws continue to apply. | Excluded only when the actor and conduct satisfy § 28-4601(2)(D). | Institutional affiliation or an affiliate relationship not described by the text is not enough. D.C. Law Library |
| Original creditor negotiating its own debt | Partial, likely outside ordinary CCSO coverage: the service is not ordinarily sold to the consumer concerning credit “by others,” and the creditor is acting on its own account. | Collection and consumer-protection law may apply. | No affirmative Chapter 46 authorization needed on ordinary self-creditor facts. | Avoid universal conclusion where an affiliate separately sells paid advisory or negotiation services. Chen supports a narrow own-credit boundary on its facts. GovInfo +1 |
| Pure business-purpose debt negotiation | Answered for Chapter 46: outside the definition to the extent the underlying credit is not primarily personal, family, or household. | Commercial-law and professional-regulation issues remain open. | No Chapter 46 registration on pure business-credit facts. | Mixed-purpose cards, personally guaranteed business debts, and sole-proprietor obligations require purpose-specific analysis. D.C. Law Library |
| Remote out-of-District provider soliciting and serving D.C. residents | Partial but high enforcement risk: “operates in the District” is undefined, yet OAG applied the statute to Florida and Maryland entities marketing or selling debt-relief services to District consumers. DC Attorney General +3 | Foreign-entity registration and BBL may be separate. | Treat District-facing sales and service as triggering Chapter 46 unless a contrary controlling authority is established. | No controlling appellate territorial test located. Marketing, solicitation, contracting, consumer residence, and performance facts matter. |
| Consumer unaware of provider or third-party payer | Partial: Chen found no CCSO relationship where the consumers were not solicited, did not understand themselves to be purchasing the service, and payment came from another person without their awareness. | Fact-specific. | Potentially outside Chapter 46 on comparable facts. | Chen is a 2011 federal trial-court decision, not a controlling D.C. Court of Appeals decision. GovInfo |
Issue · Verified D.C. result · Limit · 12 data rows
| Issue | Verified D.C. result | Limit |
|---|---|---|
| Chapter 46 initial government fee | $300 | Provider-to-government registration fee. |
| Chapter 46 annual government fee | $200 before April 2 or regulatory date | No current alternative regulatory date authenticated. |
| Consumer service-fee amount cap | HOLD | No percentage, flat-dollar, monthly, per-debt, savings, or aggregate ceiling authenticated. Absence from Chapter 46 is not proof of unlimited fees. |
| Money before completion | Prohibited unless the provider has the § 28-4604 security | Applicable federal TSR restrictions remain independently controlling where covered. |
| Bond | $25,000 | Surety must be legally permitted to do business in D.C. |
| Provider trust alternative | $25,000 minimum | Must be at a federally insured bank or savings and loan association located in D.C.; this is provider security. |
| “Completion” | Undefined in authenticated Chapter 46 text | DCMR interpretation or case law remains unresolved. |
| Total-charge disclosure | Required before contract or payment | Disclosure must include detailed services and total amount charged. |
| Written agreement | Required | Must state all payment terms, including payments to the provider or another person, services, refund promises, timing, and business/agent information. |
| Cancellation | Five calendar days after signing | Exact interaction with completed services or third-party charges remains unresolved. |
| Reimbursement after cancellation | Within ten days after receipt of cancellation notice | Scope and calculation were not further defined in authenticated rules. |
| Consumer funds in dedicated account | No D.C.-specific Chapter 46 account formula established | Federal dedicated-account requirements were already handled in P1; D.C. money-transmission treatment depends on actual control and receipt. |
P1 cell · PASS-02 treatment · Result · 7 data rows
| P1 cell | PASS-02 treatment | Result |
|---|---|---|
| S_DC-P1-C003 — custodial, noncustodial, DMP, and counseling classifications unresolved | Superseded in part by P2 C001–C022. Chapter 46 is the governing affirmative framework; noncustodial principal-reduction and paid counseling have strong CCSO coverage. Custody, money transmission, dedicated-account control, and some DMP conditions remain partial. | Partial → substantially answered, with enumerated sub-gaps |
| S_DC-P1-C004 — repeal does not establish licensing or fee permission | Preserved. Chapter 46, not repeal, supplies the current affirmative registration framework. | Confirmed and supplemented |
| S_DC-P1-C005 — DISB complaint material did not verify a debt-settlement license | Replaced in part. DISB is the current CCSO administrator, and registration is required under § 28-4602. Current prescribed form, submission route, and CCSO-specific public lookup remain unresolved. | Partial → regulator and legal category answered; procedure held |
| S_DC-P1-C006 — no current D.C. commercial consumer-fee ceiling authenticated | Preserved. P2 establishes registration fees, state pre-completion security, contract disclosures, cancellation, and reimbursement; it does not establish a consumer-service fee amount cap. | Still HOLD |
| S_DC-P1-C008 — D.C.-specific provider fee trigger unresolved | Partially superseded. Chapter 46 prohibits pre-completion receipt absent bond/trust, but “completion” and any finer D.C. earning milestones remain unresolved. | Partial |
| P1 early § 4 federal-text retrieval hold | Superseded by P1’s later supplemental federal finding and final self-check. | Closed before P2; not a current gap |
| S_DC-P1-C014 — no named provider authorization verified | Preserved only as “not investigated.” No named provider was checked in P2, and no adverse status inference is permitted. | Not investigated |
Claim ID · Precise assertion · Sources/pinpoints · 33 data rows
| Claim ID | Precise assertion | Sources/pinpoints | Conditions and confidence limit |
|---|---|---|---|
| S_DC-P2-C001 | D.C. Code Title 28, Chapter 46 is the current affirmative consumer-credit-service-organization framework. | S001, Chapter heading and §§ 4601–4608 | High; does not by itself resolve every debt-relief fact pattern. |
| C002 | Paid advice or assistance concerning personal, household, or family credit is within the CCSO definition. | S001, § 28-4601(2)(A)(iii) | High as statutory text. |
| C003 | A paid noncustodial provider negotiating reduction or resolution of personal debts has a strong textual fit under § 28-4601(2)(A)(iii). | S001; S013; S015; S016 | Strong qualified conclusion; statute does not use the words “debt settlement.” |
| C004 | D.C. OAG has applied the CCSOA to student-debt relief and services intended to validate, dispute, resolve, or reduce consumer debts. | S012–S016 | High as enforcement position; complaints and settlements are not controlling appellate holdings. |
| C005 | A covered CCSO operating in D.C. must register and pay $300 initially and $200 annually. | S001, § 28-4602(a) | High. |
| C006 | Chapter 46 does not define “operates in the District”; OAG has pursued out-of-state entities serving District consumers. | S001, § 28-4602; S013, complaint ¶ 3; S015, pp. 2–3 | High for text and enforcement facts; controlling territorial test unresolved. |
| C007 | DISB is the current administering regulator for Chapter 46. | S004–S007 | High. |
| C008 | DISB’s Licensing Division currently identifies CCSOs as an application category and maintains the non-depository/NMLS database. | S006–S007 | High as agency operational statement. |
| C009 | No current CCSO-specific prescribed form, checklist, or complete submission route was authenticated. | S008–S011; S022–S023 | Research-result limitation, not proof that no form exists. |
| C010 | A CCSO-specific public-registration lookup pathway was not verified. | S009; failed NMLS route | No named provider was checked. |
| C011 | Noncustodial debt negotiation does not require custody to fit the CCSO advice/assistance definition. | S001, § 28-4601(2)(A)(iii) | Strong textual conclusion. |
| C012 | Paid DMP or credit counseling can fit Chapter 46 even without principal reduction. | S001, § 28-4601(2)(A)(iii) | Actual services and consideration matter. |
| C013 | A provider or affiliate receiving consumer money for onward transmission may separately require a money-transmitter license. | S018, §§ 26-1001(10), 26-1002, 26-1003 | Conditional; actual funds flow and interpretations unresolved. |
| C014 | The § 28-4604 trust is provider security and is not the consumer’s dedicated settlement account. | S001, § 28-4604 | High. |
| C015 | Agents and independent persons who sell or attempt to sell CCSO services are included; pure lead generation remains fact-dependent. | S001, § 28-4601(2)(B)–(C) | High for sellers; unresolved for passive referrals. |
| C016 | Paid credit-repair representations are directly within § 28-4601(2)(A)(i). | S001 | High; CROA overlap held. |
| C017 | Only an actual § 501(c)(3) organization receives the listed nonprofit exclusion. | S001, § 28-4601(2)(D)(iv); § 28-4606(b) | High; claimant bears burden. |
| C018 | Attorney exclusion requires D.C. licensure and services within the course and scope of practice. | S001, § 28-4601(2)(D)(vi); § 28-4606(b) | High; affiliation alone insufficient. |
| C019 | Other institutional exclusions are actor- and conduct-specific and do not create a general affiliate exemption. | S001, § 28-4601(2)(D) | High as limited reading. |
| C020 | Pure business-purpose debt is outside Chapter 46’s consumer-credit definition. | S001, § 28-4601(3) | High; mixed-purpose treatment unresolved. |
| C021 | A genuinely free service with no valuable consideration is outside the CCSO definition. | S001, § 28-4601(2)(A) | Qualified; indirect compensation may alter result. |
| C022 | Own-credit and consumer-unaware transactions can fall outside Chapter 46; Chen supports this only on its facts. | S017, pp. 39–40 | Moderate; federal trial-court authority only. |
| C023 | A parallel BBL likely applies to a CCSO doing business from a D.C. location; remote/no-location treatment is unresolved. | S019–S020 | Partial due statutory location language and applicability-note conflict. |
| C024 | Title 29 foreign-entity exclusions do not determine Chapter 46 regulatory coverage. | S021, § 29-105.05(b) | High. |
| C025 | Chapter 46 bars pre-completion receipt absent the $25,000 bond or trust. | S001, §§ 28-4603(1), 28-4604 | High as state rule; no federal authorization inferred. |
| C026 | Chapter 46 requires pre-contract disclosures, a written contract, five-day cancellation, and reimbursement within ten days. | S001, § 28-4605 | High as statutory text. |
| C027 | No current D.C. consumer-service fee amount ceiling was authenticated. | Complete S001 review; S011 rule search | Evidence gap, not proof of no cap or unlimited fees. |
| C028 | “Completion” is not defined in authenticated Chapter 46 text. | S001, §§ 28-4601–4608 | High for the chapter; rule or case interpretation unresolved. |
| C029 | OAG pleadings and resolutions support coverage but do not replace controlling judicial construction. | S012–S016 | High methodological qualification. |
| C030 | No named provider’s registration or authorization was checked. | Scope limitation | Not an adverse status finding. |
| C031 | Public-source evidence is insufficient to mark D.C. operationally launch-ready because the current filing and lookup mechanics remain incomplete. | C005, C007–C010 | Operational conclusion, not denial of legal registration availability. |
| C032 | P1’s early federal-text hold was superseded by P1’s later verified TSR finding. | P1 internal record supplied in prompt | Closed P1 issue; federal overview not repeated. |
| C033 | No current operative CCSO-specific DCMR rule or adoption order was authenticated. | S001 § 28-4608; S011 | Search limitation, not exhaustive absence claim. |
Model or legal category · Status · Claims · 30 data rows
| Model or legal category | Status | Claims | Exact missing evidence and next investigation |
|---|---|---|---|
| Affirmative governing statute | Answered | C001–C005 | Preserve Chapter 46 as controlling starting point. |
| For-profit noncustodial principal reduction | Answered, qualified | C003–C004, C011 | Target controlling D.C. appellate authority or a final administrative decision directly construing debt settlement. |
| Remote provider nexus | Partial | C006 | Search D.C. Court of Appeals, Superior Court orders, DISB decisions, and rulemaking for “operates in the District”; test solicitation, contracting, and performance factors. |
| Issuing regulator | Answered | C007–C008 | None for agency identity. |
| Current application form/checklist | Unresolved | C009 | Locate the current Mayor/DISB-prescribed CCSO registration statement, state checklist, renewal form, and submission method from DISB, NMLS state-resource materials, D.C. Register notices, or archived agency rulemaking. |
| Current public lookup | Unresolved | C010 | Establish whether CCSOs appear in NMLS Consumer Access, a separate DISB database, or another public roster; do not test a named provider until the category is identified. |
| Operative DCMR registration rules | Unresolved | C033 | Retrieve complete Chapter 37 text, search D.C. Register rulemaking history, and locate any final Chapter 46 registration/disclosure/cancellation rules and Council review records. |
| Noncustodial DMP or credit counseling | Partial | C012 | Obtain D.C. administrative or judicial classification and review actual compensation and services. |
| Custodial DMP | Partial | C013 | Map funds from consumer through each account and entity; complete money-transmission licensing and exemption pass. |
| Consumer-controlled dedicated account | Partial | C013–C014 | Review account contract, consumer ownership, provider access, payment direction, withdrawal, and affiliate roles. |
| Provider- or affiliate-controlled account | Partial | C013 | Complete money-transmitter authorization, delegate, bond, permissible-investment, and application review. |
| Provider § 28-4604 trust | Answered | C014, C025 | Later pass should confirm approved trust form, depository evidence, and regulator filing treatment. |
| Compensated sales agents | Answered | C015 | Later pass may inspect individual liability and registration practices. |
| Passive lead generators and referrals | Unresolved | C015 | Review scripts, handoff, sale attempts, compensation, branding, data transfer, and creditor/referral relationships. |
| Credit-repair representations | Answered for D.C.; federal overlap partial | C016 | Complete conditional CROA applicability and any separate D.C. credit-reporting interpretations. |
| § 501(c)(3) exclusion | Answered | C017 | Verify actual IRS status and operating entity identity for any provider claiming it. |
| Attorney exclusion | Answered in text; factual use partial | C018 | Verify D.C. bar status, engagement structure, legal work, nonlawyer affiliate conduct, fee sharing, and scope of practice. |
| Institutional exclusions | Answered in text | C019 | Match actual entity and conduct to each clause; do not extend exclusions by analogy. |
| Business-purpose obligations | Answered for pure business debt | C020 | Develop mixed-purpose and sole-proprietor allocation rules if needed. |
| Free counseling | Partial | C021 | Investigate indirect or third-party consideration. |
| Original creditor/self-creditor | Partial | C022 | Search controlling D.C. authority; distinguish self-creditor activity from separately sold advisory services. |
| Money transmission | Partial | C013 | Complete full statute, DCMR, DISB checklist, exemptions, interpretive orders, and account-flow analysis. |
| BBL | Partial | C023 | Reconcile conflicting implementation notes and determine remote/no-premises treatment and correct endorsement. |
| Foreign-entity qualification | Partial | C024 | Apply Title 29 to actual solicitation, contracting, employees, offices, and transaction pattern. |
| State pre-completion rule | Answered in text | C025, C028 | Locate any rule or case defining completion; keep federal TSR independent. |
| Consumer fee amount cap | Unresolved | C027 | Search final Chapter 46 regulations, DISB orders, D.C. Register, fee bulletins, and controlling cases. No CPI or borrowed model-act calculation. |
| Contract, cancellation, reimbursement | Answered at statutory level; implementation partial | C026 | Obtain any mandatory forms or implementing rules and later analyze cancellation calculations. |
| Named provider authorization | Not investigated | C030 | Only after the correct registry/category and lookup methodology are verified. |
| Market launch readiness | HOLD | C031 | Verify current registration filing pathway and public or official confirmation mechanism before operational approval. |
| Agreement, full funds handling, bond forms, remedies, limitations, exemptions, secured debt, sector, local, tribal, contract, and full case law | Outside P2 except intersections above | — | Preserve for later passes; no acceptance by implication. |
Log ID · Route or query checked · Result · 20 data rows
| Log ID | Route or query checked | Result | Evidentiary treatment |
|---|---|---|---|
| F001 | Full official Chapter 46 section sequence, §§ 28-4601–4608 | All sections opened and read | Primary controlling text |
| F002 | Official D.C. Code searches for debt settlement, debt management, credit counseling, and debt adjusting | No separate current provider chapter surfaced beyond Chapter 46 and unrelated provisions | Documented search coverage only; not proof of absence |
| F003 | https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16 | Title 16 index read; Chapters 1 and 37 identified | Primary index |
| F004 | https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-1 | Consumer Retail Credit section list read; no CCSO heading displayed | Does not establish absence from other chapters or register notices |
| F005 | https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-37 | Web tool returned non-retryable open failure | Chapter 37 operative text remains unread |
| F006 | Official-domain D.C. Register searches for “consumer credit service organization,” “debt settlement,” “debt management,” “credit counseling,” and “28-4608” | No matching current CCSO implementation rule was authenticated | Search limitation; no exhaustive absence claim |
| F007 | Current DISB Banking Bureau and Divisions pages | CCSO application category and Licensing Division established | Current operational support |
| F008 | Current DISB banking compliance, verification, and forms pages | CCSO-specific checklist/form/category not displayed | Public procedure remains unresolved |
| F009 | https://www.nmlsconsumeraccess.org through the research tool | Direct route could not be opened | No provider or category lookup performed |
| F010 | Current NMLS/official-domain searches for a D.C. CCSO state checklist | No current D.C. CCSO-specific checklist authenticated | Does not establish that NMLS cannot process the category |
| F011 | May 2014 DISB initial non-depository instructions | Document read and visually inspected; categories omitted CCSO and instructions are historical | Excluded as current procedure |
| F012 | DISB FY 2017–2018 report | Historical NMLS transition discussion read and visually inspected | Historical context only |
| F013 | Student Aid Center complaint PDF | Parsed text read; relevant pages visually inspected | Allegations, not adjudication |
| F014 | Burlington consent judgment PDF | Relevant pages visually inspected | Party-specific consent; defendants denied violations |
| F015 | YF assurance PDF | Relevant pages visually inspected | Assurance and stipulations, not precedent |
| F016 | Chen opinion PDF | Relevant pages visually inspected | Federal trial-court boundary authority |
| F017 | Targeted D.C. and federal case searches for CCSOA and debt-relief construction | Chen located; no controlling D.C. Court of Appeals debt-settlement decision located | Targeted result only, not exhaustive case-law absence finding |
| F018 | Money-transmission §§ 26-1001–1004 | Directly read | Preliminary parallel-category analysis only |
| F019 | BBL and foreign-entity provisions | Directly read | Parallel-category analysis; remote application unresolved |
| F020 | Named provider lookup | Deliberately not performed | No provider-status claim |
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
These components repair their stated scope. They do not replace every other finding in this research series.
P02 audit-trail repairs and remaining public CCSO procedure/rule gaps →Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
Recorded check status: scoped review complete with limits and bounded correction required
The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.
scoped review complete requires bounded correction
Inside: Initial controlling findings · 1. Definitions and business-model classification · 2. Prohibition, licensing, registration, and exemptions
Inside: P02 audit-trail repairs and remaining public CCSO procedure/rule gaps · 1.1 Before-and-after correction map · A. Current CCSO statement, checklist, renewal form, and submission instructions
Inside: Provider agreements, disclosures, consumer authority, electronic delivery, cancellation, and contract failure · 2.1 The governing sequence · Mandatory Chapter 46 document checks
Original saved Markdown SHA-256: 7007976291cbb549b2a9584a353f35a0e1939cf111679d37afeb18bc14d21969. Public formatting, private-reference removal and correction annotations are separate from that immutable original.