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

S_DE PASS-04 — Delaware consumer-money custody, trust-account, administrator, and return component

Fresh public-source research session: October 25, 2026, Pacific / October 26, 2026, UTC Relationship to prior work: Focused continuation of the saved PASS-01 through PASS-03 materials by the same coordinator; not an independent review.

All prior Delaware findings, calculations, examples, corrections, source limitations, and provider-, contract-, fee-, federal-, currentness-, local-, and tribal-specific holds remain unchanged. This pass does not establish a current license for any provider, validate any contract or account structure, or prove that any fee was earned or deductible.

Executive disposition

Delaware’s consumer-money regime turns on actual receipt, control, account structure, and purpose, not on labels such as “independent administrator,” “dedicated account,” “processor,” “client account,” or an out-of-state headquarters.

The operative framework has three principal branches:

1. Provider or provider-designee custody. Money paid to a provider by or for an individual under a plan for creditor distribution is held in trust. It must enter a qualifying trust account, remain segregated from nonparticipant money, be supported by individual ledgers, be reconciled monthly, and be disbursed or returned under statutory and regulatory rules.
2. Statutorily deemed noncustodial arrangements. Under §2422A(j), a provider is deemed not to hold a trust account when the consumer retains the funds at a bank of the consumer’s choosing or uses a provider-designated bank or third-party account satisfying the text’s stated client-name, creditor-claim, or client-control criterion. That deeming does not exempt the provider from Chapter 24A licensing, reporting, fee, termination, delegation, or federal requirements.
3. Third-party administration. Using an affiliate, processor, or supposedly independent account administrator does not by itself remove Delaware duties. The statute expressly addresses provider designees and other persons controlling trust accounts, makes providers liable for delegated conduct, and subjects delegates to examination. Regulation 102 also treats a person to whom the account is transferred as a provider, although application of that rule to a particular bank, processor, or account administrator remains fact-specific.

A Delaware state-law noncustody classification also does not establish compliance with the federal Telemarketing Sales Rule’s more specific dedicated-account conditions, and neither state nor federal law was found to equate withdrawal from a debt-relief service with automatic closure of the underlying bank account or revocation of an ACH authorization.

A. Substantive findings

1. Custody classifications and administrator boundaries

S_DE-P4-C001 — Trust trigger and account definition

A Delaware Chapter 24A “trust account” is an account held by a provider that is:

• established at an insured bank;
• separate from the provider’s or its designee’s other accounts;
• designated as a trust account or otherwise labeled to show that its money is not the provider’s or designee’s money; and
• used to hold money of one or more individuals for creditor disbursement.

“All money” paid to a provider by or for an individual under a plan for distribution to creditors is held in trust and must be deposited within two business days after receipt. A single account may therefore contain money of multiple consumers, but it must have individual account records and its cash must equal the sum of those individual balances. §§2402A(20), 2422A(a), (c)(1), (d)–(f). Delaware Code+2

The reviewed clauses define “bank” broadly enough to include a regulated commercial bank, savings bank, savings and loan association, credit union, mortgage bank, or trust company. They do not state that the bank must be physically located in Delaware. This pass does not establish that no banking, contract, or other law imposes a separate location requirement. §2402A(4). Delaware Code

S_DE-P4-C002 — Indirect custody and delegated control

The statutory definition of “provider” includes a person providing debt-management services “directly or through others.” The trust provisions separately refer to:

• property of the provider or its designee;
• reconciliation where the provider or its designee has multiple trust accounts;
• payment errors caused by the provider or another person in control of the trust account; and
• money received by the provider or its agent.

A provider remains liable when it delegates a statutory or agreement duty to another person, including an independent contractor. Providers and persons receiving delegated obligations are subject to Attorney General supervision and examination. §§2402A(15), 2419A(d)(1)(A), 2422A(b), (c)(3), (f), 2431A, 2432A(b). Delaware Code+2

Accordingly, moving the ledger, ACH authority, disbursement authority, or bank interface to an affiliate or processor does not by itself create lawful noncustody. The actual account title, ownership, contractual rights, technical permissions, withdrawal authority, loss allocation, and control over creditor payments must be examined.

S_DE-P4-C003 — Statutory noncustody test

Section 2422A(j) deems a provider not to hold a trust account for creditor disbursement when client funds are either:

1. retained by the client in a bank of the client’s choosing at all times before disbursement to creditors; or
2. deposited by the client in a bank or with a third party designated by the provider, in an account having the listed characteristic that:it is in the client’s name;it is not subject to claims of creditors of a party other than the client; orthe client exercises full control over all aspects of the account.

The enacted list uses the disjunctive “or.” This pass does not rewrite the alternatives into an unstated cumulative test. It also does not assume that a marketing description such as “client-owned,” “FDIC-insured,” or “independently administered” proves the facts required by any alternative. §2422A(j). Delaware Code+1

The effect of §2422A(j) is narrow: the provider is deemed not to hold a trust account for creditor disbursement. It does not say that the provider is exempt from Chapter 24A, that a third-party administrator is exempt, or that any federal dedicated-account condition has been met.

S_DE-P4-C004 — Transferred accounts and administrators

Regulation 102 §2.3 states that the person forming the debt-management agreement and “any person to whom the account is then transferred” are providers subject to the Act. The provider also remains liable for a delegate’s violations under §2431A. These provisions prevent an automatic conclusion that a successor, affiliate, or administrator becomes legally invisible merely because the original provider no longer performs every account function. Delaware Regulations+2

The term “account” in Rule 2.3 must be applied to the actual arrangement. This pass does not conclude that an ordinary depository bank or every payment processor becomes a debt-management provider merely by furnishing banking infrastructure.

Account and business-model matrix

The matrix reflects statutory classification, not approval of any operating model. Delaware Code+3

2. Account institution, ownership, segregation, deadlines, and withdrawals

Account institution and designation — S_DE-P4-C005

A statutory trust account must be established at an “insured bank,” separated from the provider’s or designee’s other accounts, and designated to show that the funds do not belong to the provider or designee. The account may hold money of one or more consumers. §§2402A(4), 2402A(20). Delaware Code

The Act does not establish in these clauses:

• the amount of federal deposit insurance available to each participant;
• FDIC or NCUA pass-through treatment;
• bankruptcy priority beyond the express statutory property rule;
• how account insurance applies where a pooled account exceeds insurance limits; or
• who bears losses under the bank’s deposit or ACH contract.

Those issues remain held. “Insured bank” and the provider’s separate dishonesty insurance must not be treated as the same protection.

Ownership and beneficial interest — S_DE-P4-C006

Money held in trust is not property of the provider or its designee and is unavailable to their creditors. A consumer retains a claim to the consumer’s own undistributed balance. The trust account is established for the benefit of individuals receiving debt-management services. §§2422A(a)–(b). Delaware Code

That statutory property rule is controlling for Chapter 24A purposes, but this pass does not extend it into a categorical federal-bankruptcy priority opinion.

Segregation and pooled accounting — S_DE-P4-C007

Delaware permits a trust account holding money of one or more individuals, but requires:

• a separate account record for each individual;
• no commingling with money of other persons;
• cash at all times equal to the sum of individual account balances; and
• separate monthly reconciliation of each trust account.

Regulation 102 repeats the individual-record, monthly-reconciliation, exact-balance, and noncommingling requirements. §§2422A(c)(1), (d)–(f); Rules 11.2, 11.3, 11.6. Delaware Code+2

Pooling among plan participants is therefore distinguishable from commingling provider money, operating funds, or other nonparticipant funds with the trust corpus.

Deposit and creditor-remittance timing — S_DE-P4-C008

The statutory and rule timing requirements are:

The eight-day rule is applied together with the statute’s express nonfinal-payment exception and creditor-due-date requirement. This pass does not define “final” for a particular ACH, card, check, chargeback, return-code, or bank contract. §§2422A(a), (c)(2)–(3); Rule 11.1. Delaware Code+1

Permitted transfers and withdrawals — S_DE-P4-C009

A provider may not initiate a transfer from an individual’s bank or other account unless it is:

1. a return of money to the individual; or
2. before termination, properly authorized by both the agreement and Chapter 24A, and for payment to creditors under the plan or payment of a fee.

Thus, account access technology does not itself authorize a transfer. Creditor payments and fee withdrawals require independent agreement and statutory authority. After termination, paragraph (B)’s creditor/fee transfer authority is unavailable by its terms; the express permitted transfer is a return to the individual. §2428A(a)(5). Delaware Code

A fee ceiling, an invoice, a contract entry, or the presence of funds in an account does not prove that a fee is currently payable. All PASS-02 fee-timing and prior-credit qualifications remain controlling.

Interest and financial-institution charges — S_DE-P4-C010

Regulation 102 Rule 11.6 states that interest payable on a Chapter 24A trust account must be credited to the individual depositors rather than the provider, except that the interest may be used to pay financial-institution fees relating to the trust account. The rule does not authorize using interest for provider service fees or establish an allocation method among consumers. Delaware Regulations+1

For a federally covered dedicated account, the TSR independently requires the customer to own the funds and receive accrued interest, if any. eCFR

Reserves, shortages, reversals, and errors — S_DE-P4-C011

A consumer accounting must state the amount held in reserve. The statute does not in the reviewed provisions establish a standard reserve percentage or convert a reserve into provider property. §2427A(b)(4). Delaware Code

A statutory trust account must remain fully matched to individual ledger balances. If provider or controller error causes a missed or misdirected creditor payment, it must be corrected promptly and the consumer must be reimbursed for creditor charges. Suspected embezzlement or unlawful appropriation requires immediate Attorney General notice and, absent a different rule, a remedial-action notice within five days. §§2422A(c)(3), (e)–(g). Delaware Code+1

No reviewed clause supplies a universal rule allocating losses caused by:

• bank failure;
• forged instructions;
• an ACH return;
• chargeback;
• check reversal;
• administrator insolvency; or
• a pending item that later fails.

Those issues depend on actual facts, bank and ACH contracts, other law, and potentially later remedies work.

Account relocation — S_DE-P4-C012

Before relocating a trust account, the provider must inform the Attorney General of the new bank’s name, business address, and telephone number, then provide the new account number as soon as practicable. Rule 11.5 states that the licensee must notify the Consumer Protection Unit before the account is moved and provide the bank and account information. §§2422A(i); Rule 11.5. Delaware Code+1

No reviewed clause supplies a complete bank-account closure process, ACH-revocation procedure, or successor-administrator migration protocol.

3. Ledgers, statements, access, reporting, examinations, and records

Consumer accountings — S_DE-P4-C013

A provider must furnish the statutory accounting:

• upon cancellation or termination;
• at least monthly before cancellation or termination; and
• within five business days after a consumer request, although no more than one such requested accounting per calendar month is required.

The accounting must show:

1. money received since the prior report;
2. creditor disbursement dates and amounts, including payments made directly by the consumer at the provider’s direction;
3. deductions from consumer receipts;
4. the amount held in reserve; and
5. for a new principal-reduction settlement, the settlement amount and terms, debt at enrollment, debt at settlement, and settlement-fee calculation.

§2427A(a)–(b). Delaware Code+1

Record retention and account files — S_DE-P4-C014

Consumer records must be retained for at least five years after the consumer’s final payment and produced to the consumer within a reasonable time after request. Electronic storage is permitted. The Attorney General may require longer retention by rule. §2427A(c)–(e). Delaware Code

Regulation 102 Rule 12 requires, at minimum:

• a consumer file containing the preliminary analysis, original agreement, income and debt data, monthly creditor payment amounts, and periodic statements;
• an activity record containing account number, identifying data, agreement date, total debt, dated receipts, charged fees, creditor disbursements and payment dates, estimated term, and collection activity for unpaid fees following cancellation;
• settlement terms, debt amounts, and settlement-fee calculations; and
• an alphabetical consumer index.

Rules 12.1.1–12.1.4. Delaware Regulations+1

Regulatory access and examination — S_DE-P4-C015

The provider’s agreement must authorize the bank holding a provider or agent trust account to disclose trust-account records to the Attorney General. The licensing materials also require identification of trust accounts and irrevocable consent for Attorney General inspection. §§2419A(d)(2), 2405A(b)(3); Rule 4.2.5. Delaware Code+2

The Attorney General may examine providers and delegates and obtain access to offices, assets, securities, books, records, and papers. Regulation 102 permits an examination of a licensee or affiliate with or without notice during regular business hours. §2432A(b); Rule 12.1. Delaware Code+1

Public application and renewal materials — S_DE-P4-C016

The currently linked Delaware initial application asks for each trust account containing Delaware-resident funds, including account name, location, number, and dollar value, and asks for every person with account access. It requires an irrevocable inspection consent. The PDF itself is internally marked “Revised 2 3 12,” so its current legal sufficiency cannot be inferred merely from its continued presence on the agency website. Initial application, printed page 4 / PDF index 3. Delaware DOJ+2

The renewal form asks for:

• trust-account name, location, number, and value;
• 12-month Delaware receipts and creditor disbursements;
• the highest single-day accumulated balance during the preceding six months;
• every person with trust-account access;
• gross money accumulated for Delaware debt-settlement programs;
• affiliates and agents; and
• insurance at least equal to the larger of $250,000 or the highest daily trust-account balance holding Delaware-resident funds.

Renewal application, printed pages 2–3 / PDF indices 1–2. Delaware DOJ+3

The forms support the agency’s operational information demands. They do not establish that an applicant has been approved or that the forms incorporate every current legal requirement.

Renewal reporting and insurance — S_DE-P4-C017

For annual renewal:

• insurance must equal the larger of $250,000 or the highest daily trust-account balance during the preceding six months;
• a custodial provider must disclose Delaware consumer money received under plans and money distributed to their creditors during the preceding 12 months; and
• the provider must disclose, to the best of its knowledge, gross money accumulated under Delaware plans.

Regulation 102 clarifies that the insurance balance is the Delaware-client-attributable balance and that creditor distributions must be reported regardless of whether the licensee directly receives payments or directs consumers to accumulate an account for debt settlement. §§2411A(b)(5)–(7); Rules 5.3.5–5.3.7. Delaware Code+2

This provider misconduct insurance is not a finding of deposit insurance, pass-through insurance, or complete customer-loss protection.

Obsolete overdraft cross-reference — S_DE-P4-C018

Current §2405A(b)(3) still refers to an “overdraft notification agreement required by §2422A.” In 2007, however, 76 Del. Laws ch. 146 §5 deleted former §2422A(j) and (k)—the original overdraft-notification provisions—and redesignated former subsection (l) as current subsection (j). Current Regulation 102 Rule 4.2.5 requires trust-account identification and inspection consent but does not repeat an overdraft-notification requirement. Delaware Code+2

This is an orphaned statutory cross-reference, not a basis to invent a current overdraft agreement. Complete current application practice remains a regulator-form question outside this pass.

4. Cancellation, termination, plan failure, rejection, and cessation

Return-mechanics matrix

These branches arise from §§2411A(f), 2419A(a)(6)(G), 2419A(d), 2420A, 2422A(h), 2426A, and Rule 11.4. Delaware Code+5

S_DE-P4-C019 — Cancellation language does not erase later statutory refunds

The mandatory cancellation notice states that a later termination does not require refund of fees already paid. That sentence cannot be read as eliminating the more specific refund rules in §§2419A(d), 2422A(h), and 2426A. Section 2419A(g) makes the statutory termination and cancellation rights effective even when omitted from the agreement and renders contrary provisions void. §§2419A(g), 2420A(b). Delaware Code

The distinction is:

• principal or unexpended money: returned under custody and termination rules;
• previously paid fees: subject to the applicable statutory fee-refund branch;
• fees currently payable but not yet withdrawn: deductible only if their legal, contractual, allocation, credit, and timing predicates are established;
• completed lawful creditor payments: no longer part of the present trust balance, although other cancellation or remedy questions can remain.

S_DE-P4-C020 — No inferred fee deduction

Section 2422A(h) permits deduction only of fees “payable” under §2423A, and Rule 11.4 refers only to fees permitted by the Act. Neither phrase makes a billed, scheduled, accrued, or contractually described amount automatically deductible. Delaware Code+1

The PASS-02 qualifications remain unchanged:

• §2423A(f) begins with its express subsections (c) and (d) qualification;
• prior setup and monthly charges are credited only to the extent not already credited against an earlier settlement fee;
• no universal 18%-earned rate exists;
• no allocation-method switching is permitted by implication;
• no arbitrary portfolio front-loading follows from the state ceiling; and
• independently applicable federal fee timing remains separate.

Accordingly, an unverified proposed fee is held rather than subtracted from consumer principal.

5. Delaware money-transmission and administrator gateway

S_DE-P4-C021 — Separate Chapter 23 analysis may be required

In July 2026 Delaware enacted a modernized Money Transmission and Virtual Currency Act. The enacted definition includes receiving money for transmission from a person located in Delaware, including electronic or other transmission. The licensing provision generally requires a license unless the person acts as an authorized delegate or within an exemption. §§2303(18), (27), 2304. Delaware Code+2

Potential exemptions in the enacted framework include:

• a payment-system operator acting only among licensed or exempt persons;
• an agent of a payee where a written appointment exists, the payee holds the agent out publicly, and payment to the agent extinguishes the payor’s obligation without payor loss risk;
• a processing intermediary where the directly obligated entity is licensed or exempt, identifies itself to the sender, and bears sole responsibility for satisfying the transmission obligation; and
• specified federally insured depository institutions and other institutional actors.

These are conditional exemptions, not labels. §2305. Delaware Code+1

A Chapter 24A provider license, the provider’s own statutory exemption, or a contractual reference to an “independent account administrator” does not automatically confer a Chapter 23 exemption on a separate processor.

Implementation status is unresolved

85 Del. Laws ch. 338 was approved July 6, 2026. Section 3 says the Act is effective immediately but is to be implemented on the earlier of:

1. one year after enactment; or
2. publication in the Delaware Register of notice that final implementing regulations have been promulgated.

The codified transition section separately protects certain existing licensees from conflicting or new requirements until renewal or July 7, 2027, whichever is later. Delaware General Assembly+1

No authenticated implementation notice was located in this focused pass. Search silence is not treated as proof that no notice exists. The precise October 25, 2026 operative transition between the legacy and modernized frameworks therefore remains held.

An official 2026 renewal-exemption form still bears the title “Sale of Checks and Transmission of Money Act,” cites former-style §2304(c) and Regulation 2302, and requests an applicant’s exemption theory and regulatory relationships. That is evidence of an operational legacy form, not conclusive proof of the governing law or any administrator’s exemption. PDF page 1 / index 0. Delaware State Bank Commissioner+1

Gateway result

No money-transmitter license or exemption conclusion is made for any provider, administrator, bank, affiliate, or processor. Resolution requires at least:

• the exact legal entity receiving the consumer’s money;
• where receipt legally occurs;
• who owes the transmission obligation;
• whether the consumer’s creditor obligation is extinguished on receipt;
• written delegate or agent agreements;
• bank or regulated-institution status;
• who bears loss if the processor fails;
• account and ACH authority;
• the applicable Chapter 23 implementation date; and
• current license or exemption evidence for the actual entity.

6. Conditional federal dedicated-account overlay

S_DE-P4-C022 — State noncustody is not federal dedicated-account clearance

For a debt-relief service covered by the federal Telemarketing Sales Rule, requesting the customer to place money in a dedicated account is allowed only when:

1. the account is at an insured financial institution;
2. the customer owns the money and receives accrued interest, if any;
3. the account administrator is not owned, controlled by, or affiliated with the debt-relief service;
4. the administrator and debt-relief service do not exchange compensation for referrals; and
5. the customer can withdraw from the debt-relief service at any time without penalty and receive all account funds—other than fees earned in compliance with §310.4(a)(5)(i)(A)–(C)—within seven business days after the request.

16 C.F.R. §310.4(a)(5)(ii). eCFR

A debt-relief fee is federally earned only after:

• a debt has been renegotiated, settled, reduced, or otherwise altered under a valid executed agreement;
• the consumer has made at least one payment under that agreement; and
• an individually settled debt’s fee follows the rule’s proportional-balance method or a consistent percentage-of-savings method.

16 C.F.R. §310.4(a)(5)(i)(A)–(C). eCFR

Distinctions preserved

• Delaware §2422A(j) noncustody does not prove administrator independence under the TSR.
• A state fee ceiling or signed agreement does not prove federal fee earning.
• “Withdraw from the debt-relief service” is not, without more, a rule that the bank must close the account.
• Return of remaining funds is distinct from revocation of future ACH debits.
• Account closure, ACH authorization, chargebacks, bank fees, and administrator release remain governed by actual account documents and other law.
• The seven-business-day federal rule is conditional on actual TSR coverage; coverage is not presumed for every channel or entity.

B. Bounded ledger examples

These examples do not rerun or modify PASS-01 Examples E01–E06. They illustrate only the funds rules verified in this pass.

Unless expressly stated otherwise, each example assumes:

• exact U.S. dollars with no rounding;
• no interest;
• no bank charge;
• no pending check;
• no pending ACH;
• no reversal or chargeback;
• no unidentified consumer;
• no fee proven payable;
• completed creditor remittances were lawful; and
• no private account or contract facts beyond those stated.

S_DE-P4-E01 — Cleared pooled-trust receipt and termination before final remittance

Inputs

• Cleared consumer receipt for creditor distribution: $1,200
• Completed payment to Creditor A: $450
• Completed payment to Creditor B: $500
• Fee withdrawals: $0
• Snapshot: business day 6 after receipt

Operator

$1,200−$450−$500=$250$1,200-$450-$500=$250$1,200−$450−$500=$250Intermediate and result

• Starting final receipts: $1,200
• Completed creditor remittances: $950
• Current individual trust ledger: $250
• If this is the only consumer in the account, required trust cash: $250

If the consumer terminates at that snapshot, the current trust principal to return is $250 immediately, with any fee-refund amount determined separately. If the plan continues, Rule 11.1’s eight-day distribution requirement means the $250 cannot simply remain indefinitely, subject to the statutory finality and creditor-due-date rules. Delaware Code+2

No previously completed creditor payment is subtracted twice.

S_DE-P4-E02 — Reconciliation shortage

Individual ledgers

• Consumer A: $250
• Consumer B: $400
• Consumer C: $350

Required trust cash

$250+$400+$350=$1,000$250+$400+$350=$1,000$250+$400+$350=$1,000Actual bank cash

$980$980$980Shortage

$1,000−$980=$20$1,000-$980=$20$1,000−$980=$20Result

The account is short $20 against the statutory requirement that trust cash equal the sum of consumer balances. On the stated facts, the statutes and rules do not authorize reducing one or more consumer ledgers to make the reconciliation appear balanced. The cause must be investigated and corrected; if provider or controller error caused creditor charges, the consumer must also be reimbursed for those charges. §§2422A(c)(3), (e)–(f); Rule 11.3. Delaware Code+2

This arithmetic does not identify who must fund the correction under a bank, processor, or indemnity contract.

S_DE-P4-E03 — Pending ACH is not assumed final

Inputs

• Existing cleared trust balance: $300
• Newly initiated ACH: $800
• Bank interface displays provisional total: $1,100
• The $800 ACH has not become final

Operator

Cleared funds=$300\text{Cleared funds}=$300Cleared funds=$300Provisional funds=$800\text{Provisional funds}=$800Provisional funds=$800Result

The provider may delay creditor payment to the extent the consumer payment is not final. The confirmed cleared return base at that moment is $300. The $800 cannot be treated simultaneously as final money available for disbursement and as a potential reversal. If the ACH later becomes final after termination, it must be traced under the return rules; if it reverses, it is not available principal. §2422A(c)(2)(A). Delaware Code

The exact moment of “receipt” and finality under the ACH and bank agreements remains unresolved.

S_DE-P4-E04 — Failed plan and unproven claimed fee

Inputs

• Final consumer receipts: $2,000
• Completed lawful creditor payments: $1,200
• Prior fee withdrawals: $0
• Provider asserts a currently payable fee: $100
• No facts establish that the $100 satisfies state earning, prior-credit, contractual, allocation, or federal timing requirements

Current held cash

$2,000−$1,200=$800$2,000-$1,200=$800$2,000−$1,200=$800Return operator

Return=$800−fees actually payable\text{Return}=$800-\text{fees actually payable}Return=$800−fees actually payableOn the established facts, no fee is proven payable:

$800−$0=$800$800-$0=$800$800−$0=$800Result

The demonstrated principal return is $800. The asserted $100 is held and is not deducted merely because it was billed or scheduled. If a separate verified ledger instead showed that a lawful $100 fee had already been withdrawn, current account cash would already reflect that withdrawal; it could not be subtracted a second time. §2422A(h); Rule 11.4. Delaware Code+1

S_DE-P4-E05 — Federal dedicated-account withdrawal

Assumptions

• The provider is deemed noncustodial under an actually satisfied §2422A(j) alternative.
• The TSR applies to the transaction.
• The account is at an insured financial institution.
• The customer owns the funds.
• The administrator is unaffiliated and has no prohibited referral-compensation arrangement.
• No fee has been earned under all three federal performance conditions.
• No interest, bank fee, pending item, or reversal exists.

Inputs

• Customer deposits: $1,000
• Completed creditor payment: $300

Account funds remaining

$1,000−$300=$700$1,000-$300=$700$1,000−$300=$700Result

Upon a qualifying request to withdraw from the debt-relief service, the federal return amount is $700, due within seven business days. The result does not decide whether the underlying bank account must be closed or whether a separate ACH authorization has been revoked. eCFR

S_DE-P4-E06 — Creditor rejection followed by consumer termination

Inputs

• Final consumer receipts: $900
• Completed lawful payment to participating creditor: $600
• Money reserved for Creditor X: $300
• Creditor X rejects participation
• No payable fee established

Current held principal

$900−$600=$300$900-$600=$300$900−$600=$300Sequence

1. Provider must notify the consumer within five days after learning that Creditor X rejected or withdrew.
2. The notice must identify Creditor X and explain the right to modify or terminate.
3. Rejection alone does not establish automatic termination.
4. If the consumer then terminates, the $300 current trust balance is returned immediately.

§§2419A(d)(3), 2426A(b). Delaware Code+1

C. Primary-source register

All “fresh” access entries below refer to the October 25, 2026 Pacific session. No exact per-source fetch timestamps are asserted.

D. Claim-to-evidence register

E. Component coverage and remaining gaps

F. Researcher self-check

Freshly read in PASS-04

• Current official Delaware Code Chapter 24A custody, trust, account, reporting, examination, cancellation, termination, transfer, and cessation provisions.
• The 2007 official session-law amendment deleting the old overdraft-notification subsections.
• The materially different, readable official Administrative Code snapshot for Regulation 102, including Rules 2.3, 4.2.5, 5.3, 11, 12, and 13.
• The original October 2010 final order and its October 11, 2010 effective date.
• The current Delaware DOJ program page.
• Initial and renewal application PDFs, including visual inspection of the relevant trust-account pages.
• The federal TSR dedicated-account and debt-specific fee-earning clauses.
• Delaware’s 2026 money-transmission modernization session law, codified definitions, licensing/exemption provisions, transition provision, and 2026 legacy-titled exemption-renewal form.

Reused without rerunning

• PASS-02’s education/counseling qualification.
• PASS-02’s §2423A(f) opening qualification and prior-fee-credit limitation.
• PASS-02’s hold on adjusted fee amounts and full Rule 102 currentness.
• PASS-03’s corrected October 25, 2026 Pacific PASS-02 access date.
• All six PASS-01 worked fee examples and their numerical review. None was recalculated or modified here.
• PASS-01 Example E04’s held $300 deduction and E05’s distinction between the $200 timely-cancellation illustration and the separate $260 later-termination branch.

Not read or not established

• Any private consumer, provider, processor, bank, or ACH account.
• Any actual provider or administrator contract.
• Current license or exemption status for a named provider, bank, or administrator.
• Any actual Attorney General higher-fee authorization.
• Complete current provider forms or an authenticated October 2026 agency checklist beyond the publicly linked materials.
• A complete amendment-by-amendment audit of Regulation 102 after the official readable page’s February 11, 2025 update.
• An authenticated Delaware Register notice implementing the 2026 money-transmission act.
• Full legacy Chapter 23 currentness during the transition.
• FDIC or NCUA pass-through coverage, bankruptcy priority, administrator insolvency allocation, or bank failure treatment.
• Full bond, restitution, seizure, receivership, remedies, contract-waiver, or case-law issues.
• Local, tribal, secured-sector, collection, litigation, garnishment, and limitations subjects.

No exact individual source-fetch timestamps were available; only the actual fresh session date is reported. No API route, account action, application, filing, purchase, external contact, private data access, Chrome control, other Chat, local write, site change, or publication action was used.

This is focused researcher work by the same coordinator, not an independent review, operational approval, complete Delaware dossier, or publication-readiness determination.

END S_DE PASS-04