S_DC — PASS-03
P02 audit-trail repairs and remaining public CCSO procedure/rule gaps
Fresh research date: October 27, 2026, Pacific.
Scope: P02 provenance repairs and the three remaining public-evidence gaps concerning CCSO registration instructions, generic public verification, and implementing rules.
Disposition: A — PARTIAL; B — PARTIAL; C — UNRESOLVED.
The fresh research located additional official procedural materials, including a DISB lockbox bulletin, a current-version generic NMLS instructional form, NMLS guidance, and a historical final-rule document. None establishes the complete current D.C. CCSO application/renewal route, a CCSO-specific public-verification category, or an operative CCSO implementation rule adopted under § 28-4608. The three gaps therefore remain open—not converted into findings that the requirements or procedures do not exist.
P02’s governing-law findings remain bounded as supplied. This pass does not reconsider provider classifications, federal compliance, consumer-fee amounts, money transmission, BBL requirements, remedies, or the remaining D.C. dossier.
1. Explicit provenance erratum
1.1 Before-and-after correction map
The submission and capture timestamps below are coordinator-supplied provenance, not independently retrieved platform logs. They do not establish when each original source was accessed.
| Item |
Original P02 representation |
Corrected evidentiary treatment |
| Overall research/access date |
P02 repeatedly stated October 24, 2026, Pacific. |
Preserve that statement in the original answer as an original asserted date, but do not treat it as an authenticated source-by-source access record. |
| Documented submission |
Not reconciled with the October 24 labels. |
Supplied submission timestamp: 2026-10-26T02:37:30.352Z, equivalent to October 25, 2026, 7:37:30.352 p.m. PDT. |
| Documented capture |
Not reconciled with the October 24 labels. |
Supplied capture timestamp: 2026-10-26T03:11:09.345Z, equivalent to October 25, 2026, 8:11:09.345 p.m. PDT. |
| Individual original source accesses |
Presented as uniformly October 24. |
Not individually authenticated here. The later submission/capture does not prove that every source was accessed October 25. No blanket redating is made. |
| Original source-read claims |
P02 described direct reads, selected PDF inspections, and failures. |
Retained below as P02 researcher-attributed claims, unless a specific passage was freshly checked in this pass. |
| PASS-03 accesses |
Not part of P02. |
Only the specifically identified fresh checks below are assigned October 27, 2026, Pacific. No exact access time is invented. |
| Publication currency |
P02 reported the Code’s publication status. |
Freshly rechecked separately from access date: the Code index displays currency through October 22, 2026, last permanent law 26-190, effective October 14, and last emergency act 26-784, effective October 22. These are publisher statements, not the effective dates of every underlying provision. D.C. Law Library |
| Source-register format |
Twenty-three headed source descriptions, rather than one complete visible table. |
Section 4 supplies all 23 original groups, complete literal URLs, original pinpoints/read claims, and fresh-read limitations. Reformatting does not itself establish a new read. |
| P02-S023 locator |
A malformed parser fragment appeared in the earlier citation presentation. |
The complete encoded URL supplied by the coordinator is preserved in the table. The fragment is not treated as authority or as a separate document. |
| Model/provenance attribution |
Original submission was attributed to GPT-5.6 Sol Pro. |
Preserved as supplied historical metadata. No current model-selection, upgrade, or unseen execution claim is made. |
Erratum effect: The original answer and its provenance remain preserved. Its blanket October 24 access labels are now qualified as unverified historical assertions; they are not silently replaced with October 25 or October 27.
1.2 Minimal P02 coverage patch
| Reviewed P02 proposition |
PASS-03 result |
| C009: No current CCSO-specific prescribed form/checklist/complete submission route authenticated. |
Still unresolved at the CCSO-specific level. Additional generic filing resources were authenticated, but no complete category-specific route was established. |
| C010: Generic CCSO public-registration category unverified; no actual provider checked. |
Still unresolved at the CCSO-category level. Generic NMLS documentation was read. No entity, person, license, or status query was performed. |
| C033: No operative CCSO implementation rule/adoption authenticated. |
Still unresolved. A historical final-rule text was inspected, but its Chapter 37 provisions do not supply CCSO implementation rules. |
| All other P02 coverage and operational holds |
Unchanged. This is not acceptance of the D.C. parent, A066, launch readiness, or publication readiness. |
2. Substantive findings: the three permitted investigations
A. Current CCSO statement, checklist, renewal form, and submission instructions
A1. The prescribed-form requirement remains distinct from the missing form
The freshly read § 28-4602(a)(1) requires a registration statement on a form prescribed by the Mayor. Subsection (c) also permits requests for additional information and prevents acceptance until the requested information is furnished. These provisions do not identify the currently usable form or submission channel. A self-created statement, a payment, or a generic system form cannot be treated as the authenticated complete route merely because it resembles the statutory requirements. D.C. Law Library
The current DISB Divisions page still names CCSOs among the applications reviewed by its Licensing Division and identifies NMLS as the non-depository database. The current Compliance Requirements: Banking page supplies a different enumerated list and forms links without identifying a CCSO checklist. That mismatch remains a procedural evidence gap, not proof that CCSO registration is inactive or unnecessary. DC DISB+1
A2. The generic MU1 PDF is not an authenticated D.C. CCSO application
The public NMLS Company Form inspected here is version 5.0, dated July 1, 2026. Its first page expressly identifies the PDF as instructional and says forms are completed electronically through NMLS. It also tells users to identify business activities regardless of whether they plan to manage a corresponding license through NMLS.
Consequently, the presence of a District of Columbia selection does not establish that D.C. CCSO registration is an available category or that DISB has prescribed this form for § 28-4602. Nationwide Licensing System
NMLS’s public guidance points to state-specific checklists and a requirements chart. The checklist compiler produced no readable body in this research tool; the linked chart returned an unsupported spreadsheet-content response. Those routes were located, but their D.C. CCSO contents were not authenticated. Nationwide Licensing System+1
A3. A generic lockbox bulletin does not complete the CCSO filing route
DISB’s currently linked August 25, 2023 lockbox bulletin addresses Banking Bureau filings accompanied by payment, with different routing according to delivery method. It is not a CCSO application or checklist.
There is also a drafting inconsistency in its third numbered paragraph: the prose refers to the Securities Bureau, while the accompanying address block says Banking Bureau. No resolution of that inconsistency is inferred. The bulletin therefore supplies conditional generic mailing guidance—not proof that a current CCSO filing should be submitted on paper or that a particular package would be accepted. DC DISB
A4. Renewal remains a separate missing procedural document
The statutory annual-fee provision remains part of the supplied foundation. It does not, by itself, identify a current renewal form, required annual attachments, electronic workflow, or agency renewal instructions. No CCSO-specific current renewal document was authenticated.
A result: The legal category and statutory obligation remain established from P02. The actual current prescribed statement, checklist, renewal document, and complete filing channel remain HOLD.
B. Generic CCSO public lookup, help, and blank method
The current DISB non-depository verification page directs users to NMLS Consumer Access but does not expressly identify CCSOs in its listed categories. The NMLS participation page inspected here lists the District in its mortgage jurisdiction list; that is not evidence of a D.C. CCSO public-record category. DC DISB+1
The selected NMLS guidebook pages explain the separation between the public Consumer Access system and the licensing system and describe state/license information. They help define what a generic verification process would need to match. They do not establish a D.C. CCSO category or demonstrate that any provider is authorized. The guidebook is an April 17, 2026 archived version, not a verified latest edition as of October 27. Nationwide Licensing System+2
The missing public evidence is a current agency or NMLS document mapping:
D.C. Code Chapter 46 CCSO registration → the exact public registration/license category → the relevant public verification fields or published help instructions.
No actual or hypothetical entity name, person, license number, account, case identifier, or status was entered. No roster search was performed.
B result: Generic system documentation is available; CCSO-specific public verification remains unverified. This does not support an inference that any particular provider is registered or unregistered.
C. Operative CCSO implementation rules and final adoption
C1. The rulemaking statute identifies required subjects, not an authenticated adopted rule
Freshly read § 28-4608 identifies registration requirements, sample disclosures, contract/cancellation forms, and civil fines as rulemaking subjects. It provides for Council review of proposed rules and preserves Administrative Procedure Act requirements; its emergency-rule authority is time-limited.
That statutory instruction is not evidence that a particular identifiable rule was adopted, remains operative, or prescribes a current form. D.C. Law Library
The current Title 16 and Title 26-C indexes were inspected. An index heading is not a rule body. Previously failed Title 16 body routes were not repeatedly reopened; two newly followed Title 26-C body routes also failed. DISB’s rulemaking-status page provides navigation instructions, not a CCSO adoption record. DCRegs+2
C2. A historical final-rule document was found, but it does not close the CCSO gap
An official-hosted final-rule notice reports final action on May 18, 2005 and says effectiveness follows publication in the D.C. Register. The exact final publication date/citation was not authenticated. Its inspected Chapter 37 text—printed page 177—classifies specified insurance violations, not CCSO violations. It therefore does not supply the missing CCSO rules or fine schedule. District Department of the Environment+2
This is a limited historical finding. It is not a determination about the complete current Chapter 37, the whole 178-page document, or all possible CCSO rulemaking.
C3. The adjacent trust-law note is not a CCSO repeal
The editor’s note displayed beneath § 28-4608 refers specifically to §§ 28-4701–28-4712 and their relocation into Title 19. Those are Chapter 47 references. The note does not establish repeal of Chapter 46 or its registration/rulemaking requirements. D.C. Law Library
C result: No current operative CCSO implementation-rule body, final adoption record, mandatory administrative form, or CCSO-specific civil-fine classification was authenticated.
3. Reading and date conventions for the registers
H — Historical, unverified access date: P02 asserted October 24, 2026, but its individual source-access date is not authenticated. Original read descriptions below are attributed to P02, not newly certified.
F27 — Fresh body read: The specified body or passage was actually read in this pass on October 27, 2026, Pacific.
V27 — Fresh visual inspection: The specified PDF page was rendered and visually inspected on October 27. This does not imply inspection of the entire PDF.
D27 — Discovery only: A search-rendered result or locator surfaced, but no fresh primary-body read is claimed.
CF — Coordinator-reported failure: A failure supplied in the assignment, not a new failure generated here.
For original PDFs, printed-page references are preserved as P02 stated them. Where P02 did not supply a verified zero-based PDF index, the table says so rather than reconstructing one.
4. Complete visible table of the original 23 P02 source groups
The entries below preserve the original group IDs. Complete URLs are literal locators; their presence does not mean they were reopened.
| Original source ID |
Issuer, title, and complete literal URL(s) |
Original version/status, exact pinpoints, and P02 read claim |
PASS-03 read/access bounds |
| S_DC-P2-S001 |
D.C. Council / D.C. Law Library — Title 28, Chapter 46, Consumer Credit Service Organizations https://code.dccouncil.gov/us/dc/council/code/titles/28/chapters/46 https://code.dccouncil.gov/us/dc/council/code/sections/28-4601 https://code.dccouncil.gov/us/dc/council/code/sections/28-4602 https://code.dccouncil.gov/us/dc/council/code/sections/28-4603 https://code.dccouncil.gov/us/dc/council/code/sections/28-4604 https://code.dccouncil.gov/us/dc/council/code/sections/28-4605 https://code.dccouncil.gov/us/dc/council/code/sections/28-4606 https://code.dccouncil.gov/us/dc/council/code/sections/28-4607 https://code.dccouncil.gov/us/dc/council/code/sections/28-4608 |
P02 described current codification and histories running from 1991 through the May 6, 2020 amendment to § 4601. Pinpoints: § 4601(1)–(4); § 4602(a)–(c); § 4603(1)–(7); § 4604(a)–(b); § 4605(a)–(e); § 4606(a)–(c); §§ 4607–4608. P02 claimed all operative sections directly opened/read. |
H; F27 only for §§ 28-4602 and 28-4608, including their histories/notes. No fresh whole-chapter or remaining-section read. § 4602 lists amendments through October 3, 2001; § 4608 through April 9, 1997. D.C. Law Library+1 |
| S_DC-P2-S002 |
D.C. Council — D.C. Law 8-236 https://code.dccouncil.gov/us/dc/council/laws/8-236 |
P02 identified the enacting law, effective March 8, 1991, 38 DCR 306, using metadata/codification links. It expressly did not claim a complete independently read session-law body. |
H; not reopened. The distinction between metadata and full law text is preserved. |
| S_DC-P2-S003 |
D.C. Law Library — Code publication information https://code.dccouncil.gov/us/dc/council/code |
Pinpoint: publication-information block. P02 claimed direct read and currency through October 22, 2026; last permanent law 26-190 and emergency act 26-784. |
H; F27. Publication block freshly checked; not a claim that every rule/order is current or located. D.C. Law Library |
| S_DC-P2-S004 |
D.C. Law Library — § 26-551.03 https://code.dccouncil.gov/us/dc/council/code/sections/26-551.03 |
Pinpoints: (b), (g), editor’s note quoting D.C. Law 14-28 § 802. P02 claimed direct read concerning transferred regulatory functions. |
H; not reopened. Agency-identity foundation retained only within the supplied reviewed scope. |
| S_DC-P2-S005 |
D.C. Law Library — §§ 31-101 and 31-103 https://code.dccouncil.gov/us/dc/council/code/sections/31-101 https://code.dccouncil.gov/us/dc/council/code/sections/31-103 |
Pinpoints: § 31-101(2), (3), (5); § 31-103(a)(3). P02 claimed direct read concerning DISB and administration. |
H; not reopened. No new delegation analysis. |
| S_DC-P2-S006 |
DISB — Banking Bureau https://disb.dc.gov/page/banking-bureau |
Pinpoint: Licensing Division description and CCSO/database bullets. P02 claimed a direct current-page read. No legal effective date stated. |
H; CF timeout. D27 only in this pass; no fresh body read. The failed standalone route was not repeatedly reopened. |
| S_DC-P2-S007 |
DISB — Divisions https://disb.dc.gov/page/divisions-1 |
Pinpoint: Banking Division → Licensing Division bullets, naming CCSOs and NMLS. P02 claimed direct read. Undated operational webpage, not a rule. |
H; F27, selected Licensing Division body. Confirms wording, not a complete filing procedure. DC DISB |
| S_DC-P2-S008 |
DISB — Compliance Requirements: Banking https://disb.dc.gov/page/compliance-requirements-banking |
Pinpoints: non-depository category list and forms section. P02 claimed direct read; noted no CCSO checklist in the displayed list. |
H; F27. Displayed categories and forms read; linked NMLS destination examined only within the failure bounds below. DC DISB |
| S_DC-P2-S009 |
DISB — Non-Depository Institutions Operating in D.C. https://disb.dc.gov/page/non-depository-institutions-operating-dc |
Pinpoint: generic verification paragraph, category enumeration, NMLS Consumer Access direction. P02 claimed direct read. |
H; F27. Generic guidance only; no provider, license, or roster query. DC DISB |
| S_DC-P2-S010 |
DISB — Licensing and Registration Requirements https://disb.dc.gov/page/licensing-and-registration-requirements |
Pinpoint: forms/application listing. P02 claimed direct read and no CCSO form surfaced. |
H; CF timeout; not freshly reopened. No fresh statement about the full current body is made. |
| S_DC-P2-S011 |
Office of Documents and Administrative Issuances — DCMR Title 16 https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16 https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-1 https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-37 |
P02 claimed direct reads of the Title 16 index and Chapter 1 section list, with Chapter 37 failure. It rejected displayed 1/1/1900 dates as reliable rule-effective dates. Coordinator later reported both Chapter 1 and Chapter 37 bodies failed. |
H; F27 for Title 16 index only. The two previously failed body routes were not repeated. No current Chapter 1/37 body read is claimed. DCRegs |
| S_DC-P2-S012 |
D.C. OAG — Student Aid Center release https://oag.dc.gov/release/attorney-general-sues-student-aid-center-inc |
P02 date: May 25, 2016. Pinpoints: description of out-of-District provider, District marketing, debt-relief services, and CCSOA allegations. P02 claimed direct read; release summarized allegations. |
H; researcher-attributed historical record only. Not reopened or queried. No new reliance. |
| S_DC-P2-S013 |
D.C. OAG / court filing — Student Aid Center complaint https://oag.dc.gov/sites/default/files/2018-02/Release-May-25-2016-SA-%20DC-Complaint.pdf |
Pinpoints: ¶¶ 3, 24, 29, 37–47; printed pp. 2, 7–8, 11–12. P02 claimed parsed-text reading and visual inspection of printed pp. 11–12. PDF indexes not authenticated. Allegations, not adjudicated findings. |
H; researcher-attributed historical record only. Not reopened or queried. No new reliance. |
| S_DC-P2-S014 |
D.C. OAG — Burlington release https://oag.dc.gov/release/attorney-general-racine-obtains-settlement-against |
P02 date: May 23, 2017. Pinpoints: provider location, District consumers, validation/reduction services, settlement description. P02 claimed direct read. |
H; researcher-attributed historical record only. Not reopened or queried. No new reliance. |
| S_DC-P2-S015 |
D.C. Superior Court / OAG publication — Burlington consent judgment https://oag.dc.gov/sites/default/files/2018-02/Release-May-23-2017-Burlington-Financial-Group-Consent-Judgment-and-Order.pdf |
Pinpoints: printed pp. 2–4; ¶¶ 2, 4, 6–8, 11, 18, 22–23. P02 claimed visual inspection. PDF indexes not authenticated. Party-specific consent judgment; P02 noted denials rather than a controlling merits holding. |
H; researcher-attributed historical record only. Not reopened or queried. No new reliance. |
| S_DC-P2-S016 |
D.C. OAG — YF Solution Assurance of Voluntary Compliance https://oag.dc.gov/sites/default/files/2018-02/Release-August-8-2017-YF-Solution-Assurance-of-Voluntary-Compliance.pdf |
Pinpoints: printed pp. 3–4; ¶¶ 8–14, 18. P02 claimed visual inspection. PDF indexes not authenticated. Historical assurance; filename date is not independently reverified here as an operative date. |
H; researcher-attributed historical record only. Not reopened or queried. No new reliance. |
| S_DC-P2-S017 |
U.S. District Court, D.D.C. / GovInfo — Chen v. Bell-Smith memorandum opinion https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_08-cv-00999/pdf/USCOURTS-dcd-1_08-cv-00999-0.pdf |
P02 identified filing date March 8, 2011. Pinpoint: printed pp. 39–40. P02 claimed visual inspection. PDF indexes not authenticated. Federal trial-court opinion, not controlling D.C. appellate authority. |
H; not reopened or queried. No whole-opinion or citator review. |
| S_DC-P2-S018 |
D.C. Law Library — Money Transmitters Act provisions https://code.dccouncil.gov/us/dc/council/code/sections/26-1001 https://code.dccouncil.gov/us/dc/council/code/sections/26-1002 https://code.dccouncil.gov/us/dc/council/code/sections/26-1003 https://code.dccouncil.gov/us/dc/council/code/sections/26-1004 |
Pinpoints: § 26-1001(10); § 26-1002(a); § 26-1003(a)–(b); § 26-1004. P02 claimed direct reads, expressly short of the complete application/interpretive framework. |
H; not reopened. Funds/transmission analysis remains outside P3. |
| S_DC-P2-S019 |
D.C. Law Library — Basic Business License provisions https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.01 https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.02 https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.03 https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.04 https://code.dccouncil.gov/us/dc/council/code/sections/47-2851.07 |
P02’s stated pinpoints were definitions, license requirement, general-services category, government fees, and preservation of regulator eligibility decisions. It did not supply a narrower subsection pinpoint for every item. P02 claimed direct reads and retained an implementation-note conflict. |
H; not reopened. No invented finer original pinpoint; no BBL reconciliation in P3. |
| S_DC-P2-S020 |
DLCP — Business Licensing Division https://dlcp.dc.gov/service/business-licensing-division |
Pinpoints: business definition, BOSS route, General Business category, BBL verification. P02 claimed direct read. Undated operational guidance. |
H; not reopened. |
| S_DC-P2-S021 |
D.C. Law Library — Foreign-entity provisions https://code.dccouncil.gov/us/dc/council/code/sections/29-105.02 https://code.dccouncil.gov/us/dc/council/code/sections/29-105.05 |
Pinpoints: registration duty; activities excluded from the Title 29 test; § 29-105.05(b) savings clause. P02 claimed direct reads. |
H; not reopened. No foreign-qualification application to facts. |
| S_DC-P2-S022 |
DISB — Historical initial non-depository instructions https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/Non_Dep_Initial_Lic_Instructions_051214.pdf |
May 2014 historical version. P02 claimed text reading and visual inspection of page 1; PDF index not authenticated. P02 expressly excluded it as current CCSO procedure. |
H; not reopened. Historical only. |
| S_DC-P2-S023 |
DISB — FY 2017–2018 Biennial Report https://disb.dc.gov/sites/default/files/dc/sites/disb/publication/attachments/DISB_BAR1718_FinalRead%20%281%29.pdf |
FY 2017–2018 historical report. Pinpoint: printed p. 14, licensing-system discussion. P02 claimed text and visual reading; PDF index not authenticated. |
H; no fresh body read. An incidental search result resurfaced, but was not used as current evidence. Complete encoded locator replaces the malformed fragment without changing the source ID. |
5. New PASS-03 source/version register
These IDs identify genuinely additional documents or pages. Fresh checks of original authorities retain their P02 IDs rather than receiving duplicate P3 IDs.
| New source ID |
Issuer, title, and complete literal URL |
Exact read scope and version/status |
Fresh check and limitation |
| S_DC-P3-S001 |
DISB — Laws and Regulations: Banking https://disb.dc.gov/page/laws-and-regulations-banking |
Banking-law and DCMR navigation links. Undated operational index. |
F27. Navigation, not a CCSO rule body or adoption record. DC DISB |
| S_DC-P3-S002 |
DISB — Supporting Resources: Banking https://disb.dc.gov/page/supporting-resources-banking |
Resource list, including the Banking Bureau lockbox notice. Undated webpage. |
F27. Establishes the official link to S003, not CCSO-specific applicability. DC DISB |
| S_DC-P3-S003 |
DISB — Change of Address for Banking Bureau Lockbox Filings https://disb.dc.gov/sites/default/files/dc/sites/disb/page_content/attachments/banking_lockbox_update_notice.pdf |
August 25, 2023 bulletin; opening paragraph and numbered items 1–3. One unnumbered page, PDF index 0, fully visually inspected. |
F27/V27. Generic conditional instructions; not a CCSO checklist. Item 3’s bureau-name inconsistency preserved. No new legal effective date inferred from current linking. DC DISB |
| S_DC-P3-S004 |
DISB — Legislation and Rulemakings: Status https://disb.dc.gov/page/legislation-and-rulemakings-status |
Instructions for navigating legislative/rulemaking resources, including agency/chapter search guidance. Undated. |
F27. No CCSO final-rule record is supplied by the page itself. DC DISB |
| S_DC-P3-S005 |
Office of Documents and Administrative Issuances — DCMR Title 26-C Banking index https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?subtitleId=9 |
Chapter-heading index, including applications and fees headings. |
F27 index only. New attempts to read Chapter 26-C2 and 26-C6 bodies failed; exact URLs appear in the failure log. No substantive rule inferred from a heading. DCRegs |
| S_DC-P3-S006 |
Conference of State Bank Supervisors / NMLS — Company Form MU1, instructional PDF https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/Shared%20Documents/NMLS%20Company%20%28MU1%29%20Form.pdf |
Version 5.0, July 1, 2026; printed p. 1 / PDF index 0: purpose, instructional-only limitation, business-activity/state selection. |
F27/V27 for p. 1. No whole-nine-page visual review claimed. Not authenticated as D.C.’s prescribed CCSO form. Nationwide Licensing System |
| S_DC-P3-S007 |
NMLS — Policy Guidebook for Licensees, archived version https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/NMLSPolicyGuideArchives/NMLS%20Policy%20Guidebook%20for%20Licensees%2004172026.pdf |
April 17, 2026 archived version. Selected printed pp. 17–19 / PDF indexes 16–18: public Consumer Access distinction, company filing guidance, state/license information. |
F27/V27, selected pages only. Not a full 208-page review or verification of the latest edition. Nationwide Licensing System+2 |
| S_DC-P3-S008 |
NMLS — Consumer Access Participation https://mortgage.nationwidelicensingsystem.org/knowledge/products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/nmls_consumerAccess_participation.html |
Displayed participation text, including the District in the mortgage list and the separate other-industries portion. Undated. |
F27. No D.C. CCSO category authenticated from the displayed body. Nationwide Licensing System |
| S_DC-P3-S009 |
NMLS — Using License Requirements and Fees Chart https://mortgage.nationwidelicensingsystem.org/knowledge/products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_licReqsFeesChart.html |
Instructions identifying the checklist compiler and downloadable requirements chart. Undated. |
F27. Guide read; chart contents not read because the linked file response was unsupported. Nationwide Licensing System |
| S_DC-P3-S010 |
NMLS — Company New License Application https://mortgage.nationwidelicensingsystem.org/knowledge/products/nmls/pubs/aboutNMLS/reference/aboutNMLS/maps/topics/aboutNMLS_licReqFees_companyNewApp.html |
Chart guidance identifying agency, license name, statute, and application-related columns. Undated. |
F27. Column descriptions do not establish a D.C. CCSO entry or requirements. Nationwide Licensing System |
| S_DC-P3-S011 |
DCRA, OP/HPO, DOH, DMH, and DISB; official DOEE-hosted copy — Notice of Final Rulemaking, Civil Infractions: Schedule of Fines Amendments https://doee.dc.gov/sites/default/files/dc/sites/ddoe/publication/attachments/Civil%20Infractions%20Schedule%20of%20Fines.pdf |
Opening page [PDF 0], printed p. 2 [PDF 1], and p. 177 [PDF 176], including §§ 3700.1 and 3701.1–3701.3. Reports final action May 18, 2005; effectiveness upon publication. |
F27/V27, selected pages only. Historical final notice; final publication date and present operative status unverified. Not a CCSO implementation source. District Department of the Environment+2 |
6. Atomic PASS-03 claim register
Source IDs below resolve to the complete literal URLs in Sections 4–5. Research-process claims are distinguished from legal propositions.
| Claim ID |
Precise assertion |
Source and exact pinpoint |
Status / confidence limit |
| S_DC-P3-C001 |
Supplied P02 submission and capture timestamps convert to October 25, 2026 PDT, not October 24. |
Coordinator-supplied timestamps reproduced in §1.1. |
Provenance correction. No independently retrieved platform log. |
| S_DC-P3-C002 |
P02’s individual original source-access dates cannot be authenticated from the supplied event timestamps. |
Original P02 assertions versus supplied submission/capture metadata. |
Historical access uncertainty. No blanket redating. |
| S_DC-P3-C003 |
The fresh Code index displays publication currency through October 22, 2026. |
P2-S003, publication-information block. |
Verified publisher statement, not a universal effective-date finding. |
| S_DC-P3-C004 |
Section 28-4602 requires a prescribed registration statement and permits nonacceptance pending requested information. |
P2-S001, § 28-4602(a)(1), (c). |
Verified text. Does not identify the current form. |
| S_DC-P3-C005 |
DISB’s Divisions page names CCSOs and NMLS but does not itself provide the complete CCSO submission instructions. |
P2-S007, Banking Licensing Division bullets. |
Verified operational wording; limited inference. |
| S_DC-P3-C006 |
The publicly inspected MU1 PDF is an instructional generic form, not authenticated as D.C.’s prescribed CCSO form. |
P3-S006, p. 1 / PDF 0, introductory instructions and business-activity selection. |
Verified document limitation; D.C. adoption unresolved. |
| S_DC-P3-C007 |
No current CCSO-specific statement, checklist, or renewal instructions were authenticated in the examined public material. |
P2-S007–S009; P3-S001–S010; failed-route log. |
Research result, not absence of a requirement or document. |
| S_DC-P3-C008 |
The lockbox bulletin supplies conditional generic payment-mailing guidance, not a CCSO filing package. |
P3-S003, opening paragraph and items 1–3. |
Verified limited scope. Item 3 inconsistency unresolved. |
| S_DC-P3-C009 |
The inspected public verification/participation pages do not authenticate a D.C. CCSO public-record category. |
P2-S009, verification paragraph; P3-S008, displayed participation sections. |
Page-bounded finding, not system-wide absence. |
| S_DC-P3-C010 |
Generic NMLS guidance does not substitute for a published mapping to D.C. Chapter 46 registration. |
P3-S007, pp. 17–19 / PDF 16–18; P3-S009–S010. |
Methodological conclusion. No actual record inspected. |
| S_DC-P3-C011 |
Section 28-4608 identifies registration, sample disclosures, contract/cancellation forms, and civil fines as implementation subjects. |
P2-S001, § 28-4608(b)(1)–(4). |
Verified statutory text. Not evidence of a specific adoption. |
| S_DC-P3-C012 |
The statute’s Council-review and emergency-rule provisions do not establish that an unidentified rule is currently operative. |
P2-S001, § 28-4608(a), (c). |
Verified text plus limited inference. An identifiable rule and publication history remain necessary. |
| S_DC-P3-C013 |
The editor’s note referring to §§ 28-4701–4712 is not a repeal of Chapter 46. |
P2-S001, § 28-4608 editor’s note and next-chapter reference. |
Verified cross-reference distinction. |
| S_DC-P3-C014 |
The inspected Title 16 and Title 26-C pages are indexes, not the missing operative CCSO rule bodies. |
P2-S011, Title 16 index; P3-S005, Title 26-C index. |
Verified read boundary. Failed bodies remain unread. |
| S_DC-P3-C015 |
The historical Chapter 37 excerpt inspected here concerns specified insurance violations, not CCSO implementation. |
P3-S011, p. 177 / PDF 176, §§ 3700.1, 3701.1–3701.3. |
Verified only for that historical excerpt. |
| S_DC-P3-C016 |
The historical notice’s final-publication date and present operative status were not authenticated. |
P3-S011, opening page and p. 2 / PDF 1. |
Unresolved. Its proposed-rule citation is not substituted for final publication. |
| S_DC-P3-C017 |
No operative CCSO implementation rule or final adoption under § 28-4608 was authenticated in this pass. |
P2-S001 § 4608; P2-S011; P3-S001, S004–S005, S011; search/failure log. |
Qualified unresolved result, not an exhaustive absence claim. |
| S_DC-P3-C018 |
P02 C009, C010, and C033 remain open despite the additional procedural sources. |
C007, C009–C010, C017. |
Coverage determination. No operational approval. |
| S_DC-P3-C019 |
No actual or hypothetical identifier/status query, named-provider check, or roster search was performed. |
This pass’s tool-use/read log. |
Research-process statement, not a legal conclusion. |
7. A–C subquestion coverage and exact remaining public evidence
| Subquestion |
Status |
Claim IDs |
Exact missing evidence / permitted next investigation |
| A1. Current Mayor/DISB-prescribed CCSO registration statement |
Unresolved |
C004, C006–C007 |
An official current CCSO form or a published directive expressly prescribing a particular electronic form for § 28-4602. Inspect an accessible official form, rule appendix, or state-resource checklist. |
| A2. Current CCSO application checklist and attachments |
Unresolved |
C007 |
A category-specific checklist identifying required submissions and revision status. A generic NMLS form or chart-column description is insufficient. |
| A3. Complete electronic submission route |
Unresolved |
C005–C007 |
Public instructions identifying the exact D.C. CCSO registration category and its filing workflow. No account access or filing is needed to establish that published mapping. |
| A4. Complete paper submission route |
Unresolved |
C008 |
An official CCSO instruction expressly allowing/requiring paper submission and identifying the applicable form/package. The generic lockbox notice does not supply this. |
| A5. Current CCSO renewal form/instructions |
Unresolved |
C007 |
Current public renewal document or category-specific instructions, including what is renewed or submitted. Do not infer a renewal form from the annual-fee statute alone. |
| A6. Generic procedural resources |
Answered within limits |
C005–C008 |
DISB/NMLS resources were authenticated, but they remain generic. The unresolved step is matching them to Chapter 46. |
| B1. Generic public-verification help |
Partial |
C009–C010 |
General documentation was read. A public help document expressly addressing the D.C. CCSO category is still missing. |
| B2. Exact public CCSO category label |
Unresolved |
C009 |
A current agency/NMLS category list or help page mapping the public label to Chapter 46. No entity lookup is authorized or necessary for this question. |
| B3. Blank CCSO verification method |
Partial |
C010 |
The generic concept is documented; category-specific fields and coverage are not. Obtain published category/field documentation without submitting identifiers. |
| B4. Provider authorization or status |
Excluded |
C019 |
No actual or hypothetical provider/status query. No next provider investigation is authorized by this pass. |
| C1. Statutory rulemaking subjects and conditions |
Answered |
C011–C012 |
The statute was freshly read. This does not close the separate rule-adoption question. |
| C2. Operative registration implementation rules |
Unresolved |
C014, C017 |
A complete public rule body, final-adoption citation, effective date, and subsequent amendment history tied to Chapter 46. |
| C3. Administrative sample disclosure provisions |
Unresolved |
C011, C017 |
An authenticated adopted rule or official form appendix under § 28-4608(b)(2). Existing statutory disclosure duties are not reexamined here. |
| C4. Administrative contract and cancellation forms |
Unresolved |
C011, C017 |
Authenticated adopted forms or a current official instruction identifying them. Do not manufacture a mandatory form from statutory language. |
| C5. CCSO-specific civil-fine implementation |
Unresolved |
C015–C017 |
An applicable current rule classifying Chapter 46 violations and its final-adoption history. The historical insurance excerpt does not supply it. |
| C6. Final adoption, currentness, and effective status |
Unresolved |
C012, C016–C017 |
Identifiable final notice and final publication details, plus later amendments or supersession. Proposed-rule dates and index dates cannot substitute. |
| C7. Adjacent trust-law editor’s note |
Answered |
C013 |
The note concerns Chapter 47 references; no Chapter 46 repeal inference is supported. |
| C8. Historical Chapter 37 document |
Answered only as historical scope |
C015–C016 |
Limited excerpt classified; present operative status and any later CCSO changes remain unresolved. |
| All other P02/state-parent categories |
Excluded / unchanged |
C018 |
Remote/business/mixed-model boundaries, BBL implementation, funds/transmission, foreign qualification, consumer-fee amounts, completion, broader contracts/remedies, and all remaining parent/A066 holds remain for their authorized passes. |
8. Two fictional procedure/failure branches
These are document-review branches, not fictional provider records, applications, or status searches.
Branch 1 — Generic form found, prescribed-form match missing
Inputs: A draft checklist references § 28-4602. A public generic MU1 instructional PDF is available. No official document has been found identifying it as the D.C. CCSO prescribed statement.
Decision test: Is there an authenticated public instruction linking that form and an exact D.C. category to Chapter 46?
Observed branch: The required linkage is missing.
Result: Mark the application-method item unresolved. Do not substitute another license category, treat the instructional PDF as a mail-in application, or infer that completing a generic form would satisfy D.C. registration. The next evidence needed is the category-specific prescription or checklist—not a sample filing. This follows the prescribed-form requirement and the generic form’s own limits. D.C. Law Library+1
Branch 2 — Generic lookup help and an old rule excerpt found, but neither matches CCSO
Inputs: A draft verification procedure has generic NMLS help, a current DCMR index, and an older Chapter 37 excerpt.
Decision tests: Does the public help identify a Chapter 46 CCSO category? Does the rule excerpt contain operative CCSO implementation text with authenticated current status?
Observed branch: Neither match has been established.
Result: Stop at the documentation gap. Do not run an identifier query, infer provider status, or conclude that no rule exists. The missing evidence is a published CCSO category mapping and an authenticated applicable rule/adoption record. Nationwide Licensing System+2
9. Actual search, read, and failure log
The table distinguishes fresh failed accesses from coordinator-reported earlier failures. A blank or unsupported response is not treated as an empty legal category.
| Log ID |
Route or search scope |
Actual result and date |
Consequence |
| S_DC-P3-L001 |
Official-domain searches combining CCSO / “consumer credit service” with registration, application, checklist, renewal, “28-4608,” final rulemaking, DCMR, and NMLS. |
Conducted October 27. Located the sources above; no complete CCSO-specific form or operative implementation rule authenticated. |
Bounded search coverage, not exhaustive absence proof. Search snippets and commercial form titles were discovery only. |
| L002 |
https://code.dccouncil.gov/us/dc/council/code/sections/28-4602 https://code.dccouncil.gov/us/dc/council/code/sections/28-4608 https://code.dccouncil.gov/us/dc/council/code |
Fresh bodies read October 27. |
Supports only the statutory procedural text, editor-note distinction, and publication block described above. |
| L003 |
https://disb.dc.gov/page/banking-bureau https://disb.dc.gov/page/licensing-and-registration-requirements |
Coordinator-reported timeouts. Not repeatedly reopened here. Banking Bureau search-rendered material surfaced, but no fresh body read claimed. |
Original direct-read claims remain historical; the current Divisions page was used for the permitted operational wording. |
| L004 |
https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-1 https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=16-37 |
Coordinator-reported body failures. Not repeated here. |
Current bodies remain unread in P3. Index access is separately recorded. |
| L005 |
https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?TitleNum=16 https://www.dcregs.dc.gov/Common/DCMR/ChapterList.aspx?subtitleId=9 |
Index bodies read October 27. |
Navigation and headings only; no rule text inferred. |
| L006 |
https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=26-C2 |
Fresh attempt October 27 failed in the web tool. |
Applications-chapter body not authenticated; no unchanged retry loop. |
| L007 |
https://www.dcregs.dc.gov/Common/DCMR/RuleList.aspx?ChapterNum=26-C6 |
Fresh attempt October 27 failed in the web tool. |
Fees-chapter body not authenticated; no fee inference or unchanged retry loop. |
| L008 |
https://mortgage.nationwidelicensingsystem.org/slr/Pages/DynamicLicenses.aspx?StateID=DC |
Legacy generic state-resource locator; tool reported it inaccessible October 27. |
No category results obtained. This was not an entity or status query. |
| L009 |
https://mortgage.nationwidelicensingsystem.org/consumer/Pages/default.aspx |
Legacy generic consumer-help route inaccessible October 27. |
No help body or record result obtained. |
| L010 |
Officially linked route: https://mortgage.nationwidelicensingsystem.org/Pages/default.aspx Redirected destination: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Home.aspx |
Destination returned no readable body lines October 27. |
A discovered destination, not an authenticated state-category listing. |
| L011 |
https://mortgage.nationwidelicensingsystem.org/knowledge/Products/consumeraccess/SitePages/Home.aspx https://mortgage.nationwidelicensingsystem.org/knowledge/Products/consumeraccess/SitePages/Information-about-NMLS-Consumer-Access.aspx |
Both produced no readable body lines October 27. |
No inference that the pages or categories are absent. Other public documentation was used within its limits. |
| L012 |
https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Checklist-Compiler.aspx |
No readable body lines October 27. No filter or category result authenticated. |
CCSO checklist contents remain unknown. |
| L013 |
Public chart link: https://csbsannualrenewalchecklist.azurewebsites.net/life |
Tool returned an unsupported application/msexcel response. Contents were not parsed or locally processed. |
No claim about whether a D.C. CCSO row exists. No chart-derived fee or procedure. |
| L014 |
New PDFs P3-S003, S006, S007, S011. |
Selected pages actually rendered and inspected, as indexed in §5. |
No whole-document visual-read claim for the nine-, 208-, or 178-page documents. |
| L015 |
Historical final-rule PDF text searches for “consumer credit” and “28-460.” |
No matching parsed-text hits returned in the examined file. |
A limited text-search result only—not proof of no CCSO rules elsewhere or in later amendments. |
| L016 |
Original P2-S012–S016 enforcement records. |
Not reopened or queried. |
No new reliance on those historical records. |
| L017 |
Original P2-S017 Chen; P2-S022–S023 historical documents. |
No fresh body reads. S023 incidentally resurfaced in search discovery only. |
No whole-case/citator review; no historical document promoted to current procedure. |
| L018 |
Provider/person/entity/license/account/property/case identifiers; rosters; status searches. |
None submitted. |
No actual or hypothetical authorization/status conclusion. |
10. Researcher self-check and final disposition
Freshly read: The selected Code provisions and publication block; the identified current DISB operational/resource pages; current DCMR indexes; generic NMLS help and instructional material; and the specifically indexed PDF pages in the new-source register.
Historical or reused: The remaining P02 source descriptions and read claims are preserved as attributed historical records. P2-S012–S016 were not reopened or queried. P2-S022–S023 remain historical only. No new reliance was placed on the whole Chen opinion or a citator.
Unread or inaccessible: Current CCSO-specific application, checklist, renewal instructions, public-category mapping, and implementing-rule/adoption documents remain unauthenticated. Failed or blank routes are recorded without converting them to evidence that requirements do not exist.
Not performed: No identifier or status query, roster search, filing, contact, record request, complaint, account change, API workflow, browser control, local write, hash generation, other chat, or publication action. This is not independent review or acceptance.
Final patch
The audit trail is repaired by separating original asserted access dates, supplied submission/capture metadata, and actual October 27 fresh checks. All 23 original source groups are now presented in a visible table with their original limitations preserved.
The three public-evidence gaps remain:
- A: Current CCSO prescribed statement/checklist/renewal and complete filing route — unresolved within a partially documented procedural framework.
- B: Generic public CCSO category and category-specific verification method — unresolved; no provider checked.
- C: Operative CCSO implementation rules and final adoption under § 28-4608 — unresolved.
The research found generic instructions and a limited historical rule excerpt, but those materials do not supply the missing category-specific evidence. All P02 operational, broader-coverage, state-parent, A066, and publication holds remain in place.
END S_DC PASS-03.