S_DE PASS-02 — bounded qualification and roster-date correction
Access date: October 24, 2026, Pacific
Review status: Same-coordinator scoped correction to PASS-01; not an independent review.
No P1 calculations, worked examples, state overview, unaffected claims, or full registers are repeated. Except for the replacements below, P1 remains preserved with all existing provider-specific, contract-specific, current-dollar, full-rule, currentness, local, tribal, and other-state holds.
1. Minimal replacement claim table
| Corrective claim ID |
Stable P1 alias |
Replacement text and exact qualification |
| S_DE-P2-C001 |
S_DE-C006, with corresponding qualification to S_DE-C009 |
Replace “No fees before compliant agreement” with: Section 2423A(a) permits fees or charges only as authorized by §2423A. Section 2423A(b) states the general rule that a provider may not impose charges or receive payment for debt-management services until the provider and individual sign an agreement complying with §§2419A and 2428A. That is not a universal rule that every payment before an agreement is forbidden: §2423A(d)(4), expressly subject to §2428A(d), addresses an individual who does not assent to an agreement and permits a fee for educational or counseling services up to the statutory starting amount of $100—or a larger fee approved by the Attorney General when the nature and extent of those services warrant it. Section 2423A(e) requires refund of a fee paid under (d)(4) if the individual assents to an agreement before 90 days expire after completion or termination of the counseling. Separately, §2423A(c) restricts educational or counseling charges when an individual does assent and permits Attorney General authorization based on the nature and extent of the services, while cross-referencing §2428A(d). Section 2428A(d) independently prohibits compensation for advising, arranging, or assisting an individual in obtaining an extension of credit or another service from a lender or service provider, except for educational or counseling services required in connection with a government-sponsored program. These provisions do not establish blanket permission for pre-agreement counseling fees; the service’s actual character, any required Attorney General approval, §2428A(d)’s application, current adjusted dollar amount, and complete operative rules remain held. §§2423A(a)–(e), 2428A(d). Delaware Code+2 |
| S_DE-P2-C002 |
S_DE-C008 |
Replace the per-debt explanation with: Section 2423A(d)(2)(C) states that aggregate fees under the principal-reduction plan category may not exceed 18% of total principal debt. Section 2423A(f) then begins, “Except as otherwise provided in subsections (c) and (d)”, and limits compensation in connection with settling each debt to 18% of that debt’s principal, less the §2423A(d)(2)(A) fee and aggregate §2423A(d)(2)(B) fees to the extent those amounts have not already been credited against an earlier settlement fee. The deduction therefore is not an assumption that every previously assessed setup or monthly fee was lawful, earned, or properly attributable. Neither the aggregate cap nor the per-debt ceiling creates a universal 18%-earned rate, authorizes collection timing, permits arbitrary portfolio front-loading, supports switching allocation methods, or excuses proof of the legal and contractual basis for prior fees. P1 Examples E02 and E04 remain unchanged as conditional arithmetic only. §§2423A(d)(2)–(3), (f). Delaware Code |
| S_DE-P2-C003 |
S_DE-C010 |
Replace the adjustment-mechanism explanation with: Section 2432A(f) first provides that the Attorney General may adopt inflation-reflecting dollar amounts instead of amounts specified in §§2402A, 2409A, and 2423A. It then provides that the Attorney General shall adopt a base year and adjust the amounts effective July 1 if the index change from that base year, measured as of December 31 of the preceding year, is at least 10%. General adjusted amounts are rounded to the nearest $100, while amounts in §2423A are rounded to the nearest dollar. Section 2432A(g) requires notice to licensed providers and public availability of any change. This verifies only the statutory mechanism. It does not establish an actually adopted base year, a qualifying index change, a particular notice, or any effective October 2026 adjusted amount. No CPI calculation or current fee-schedule certification is made; complete Regulation 102 and any operative adjustment notice remain held. §§2432A(f)–(g). Delaware Code |
| S_DE-P2-C004 |
S_DE-C015 and source S_DE-P1-S004 |
Replace the roster-date description with: S_DE-P1-S004 is a three-page official Delaware DOJ PDF containing two inconsistent date inscriptions. Its filename and repeated page inscription/footer state “4/15/25,” while the body heading on page 1 states “DEBT-MANAGEMENT SERVICES ACT LICENSED PROVIDERS AS OF 9/9/2024.” Neither date is silently treated as a correction of the other. The PDF is therefore a historical roster with internally inconsistent date metadata, not evidence of any provider’s licensing status in October 2026. Delaware DOJ+3 |
2. Minimal source and version usage checks
The supplied coordinator record stated that the archived 2008 final-order PDF had failed direct opening. During this limited fresh access, that exact archive URL returned parsed historical PDF text, but it was not substantively reviewed or relied upon because this correction does not reopen the full-rules investigation. It does not establish current Regulation 102 or any current adjusted amount. Delaware Regulations
3. Focused coverage patch
| Affected P1 component |
Corrected status |
Corrective claims |
Remaining exact holds |
| Mandatory signed agreement before fees |
Qualified / partial |
S_DE-P2-C001; old aliases S_DE-C006 and S_DE-C009 |
General §2423A(b) rule now distinguished from the restricted §§2423A(c), (d)(4), (e), and 2428A(d) counseling branches. Still unresolved: complete Regulation 102, current adjusted amount, actual Attorney General authorization, precise application of §2428A(d), service facts, and contract facts. |
| No-agreement counseling and 90-day refund |
Statutory baseline answered; applicability partial |
S_DE-P2-C001; old S_DE-C009 |
No blanket counseling-fee permission. Government-sponsored-program exception, any higher-fee approval, current dollar amount, and exact service classification remain held. |
| Principal-reduction aggregate/per-debt ceiling |
Statutory language corrected; operational application partial |
S_DE-P2-C002; old S_DE-C008 |
Must preserve §2423A(f)’s opening exception and its “to the extent not credited against an earlier settlement fee” condition. Actual fee method, prior-fee legality, earning, attribution, timing, contract allocation, and federal timing remain unresolved for any real transaction. |
| Inflation adjustment mechanism |
Mechanism answered; current schedule unresolved |
S_DE-P2-C003; old S_DE-C010 |
No authenticated base year, triggering index calculation, July 1 adjustment notice, current Regulation 102 text, or October 2026 adjusted amount. |
| Public roster date and current provider status |
Historical metadata corrected; current status unresolved |
S_DE-P2-C004; old S_DE-C015 |
Both 4/15/25 and 9/9/2024 inscriptions remain visible and unreconciled. A transaction-date roster or provider-specific agency record is still required. |
All other PASS-01 gaps remain unchanged, including actual-provider licensing, application status, actual contracts, complete fee history, lawful earning and allocation, current adjusted fees, complete regulations and amendment history, currentness, local law, tribal issues, other-state issues, and all categories expressly reserved for later Delaware passes.
4. Researcher self-check
Fresh public browsing was limited to the exact Delaware Code provisions, the two Delaware DOJ operational pages, the official three-page roster PDF, the current Regulation 102 route, and the supplied historical archive route.
The statutory passages and roster date inscriptions were freshly checked. The P1 arithmetic and six worked examples were not rerun. The coordinator-supplied review results—including the matched quantities and the $80 ≤ nominal $100 and day 45 < 90 observations—were reused as provided, not independently reproduced.
The current Regulation 102 route yielded no operative extracted text and was not read. The historical 2008 archive PDF was not substantively reviewed or used as current-law evidence. No current fee amount, provider registration, contract compliance, licensing status, publication readiness, or state-dossier acceptance is approved or inferred.
This is a same-coordinator bounded correction, not independent review. No Chrome control, Work mode, Deep Research, API route, account action, contact, purchase, private borrower data, site change, publication, or local-file write was used.
END S_DE PASS-02