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

S_DE PASS-05 — bounded timing and predicate correction

Fresh access session: October 25, 2026, Pacific / October 26, 2026, UTC. No individual source-fetch timestamps are asserted.

Review relationship: Same-coordinator correction to the saved complete PASS-04; not an independent review.

Only the three specified precision groups are corrected. All PASS-04 examples, arithmetic, account classifications, money-transmission findings, source limitations, and provider-, contract-, bank/ACH-, fee-, federal-coverage-, currentness-, local-, tribal-, and parent-level holds remain preserved.

1. Exact replacement table

2. Corrected substantive findings

A. Deposit and creditor-disbursement clocks

The corrected sequence is:

1. Deposit obligation: Section 2422A(a) reaches all money paid to the provider by or for the consumer pursuant to a creditor-distribution plan. The provider must deposit it within two business days after receipt. “Final money” is removed as a blanket deposit predicate. Delaware Code+1
2. Creditor-disbursement obligation: Section 2422A(c)(2) requires disbursement as disclosed in the agreement. The provider may delay creditor payment to the extent the consumer’s payment is not final, and regular periodic payments must comply with creditor due dates. Delaware Code
3. Rule 102 eight-day language: Rule 11.1 separately says money must be distributed to creditors within eight days. It does not say “within eight days after deposit.” PASS-04 therefore may not construct a fresh eight-day clock beginning when the deposit occurs or an automatic maximum of two business days plus eight days. Delaware Regulations
4. Time computation: Section 2402A(8) defines “day” as a calendar day, and Rule 102 §1.1 imports that definition. Rule 13.1 excludes the triggering act or event from the count and extends the final day when it falls on a Saturday, Sunday, or Delaware legal holiday. Because the eight-day trigger has not been conclusively fixed, no calendar calculation is made. Delaware Code+2

The text’s syntax may support treating receipt as the shared event for both Rule 11.1 periods, but that interpretation is held rather than presented as a controlling judicial or agency construction. What is established is narrower: the rule supplies no after-deposit anchor and no automatic 2-plus-8 calculation.

Corrected event-matrix cells

These replacements are supported by §§2402A(8), 2422A(a), (c)(2), and Rules 1.1, 11.1, and 13.1. Delaware Code+4

Effect on the saved examples

PASS-04 Examples E01 and E03 remain numerically and conditionally unchanged:

• E01: The $250 current balance calculation remains valid under its stated cleared-receipt and completed-remittance assumptions. A snapshot on “business day 6” does not, standing alone, prove that any creditor payment was late because this correction does not establish the eight-day trigger or perform a calendar calculation.
• E03: The distinction between $300 cleared and $800 provisional remains valid. Section 2422A(c)(2)(A) expressly bears on delaying creditor disbursement for a nonfinal payment; PASS-05 does not decide when the provisional $800 was legally “received” for the separate deposit obligation.

No arithmetic was rerun.

B. Thirty-day cancellation right versus refund timing

Section 2420A(a) creates:

• an ordinary cancellation right before midnight of the third business day after assent; and
• an extended right to cancel within 30 days after assent if the agreement fails to comply with §2420A(b), §2419A, or §2428A.

The 30-day period specifies when cancellation may be exercised. It does not state that the provider has 30 days to refund money, nor does it state that the refund must be completed within the same 30-day period. Delaware Code

The mandatory form says that cancellation during the ordinary three-day period results in refund of all money already paid to the provider, but that clause likewise supplies no separate numerical refund deadline. Section 2427A(a)(1) requires an accounting upon cancellation or termination. Sections 2422A(h) and 2426A contain “promptly” and “immediately” return duties, respectively, but only when their separate termination or plan-failure conditions are present. Delaware Code+2

Corrected return-matrix cell

The emergency-waiver conditions remain unchanged: a personal financial emergency must necessitate creditor disbursement before expiration of the three-day period; the consumer must send or deliver a signed, dated statement in the consumer’s own words describing the circumstances and explicitly waiving cancellation; a standard-form waiver is void. No conclusion is made about any actual waiver or its effect on a separately arising extended right for a deficient agreement. Delaware Code

C. Federal summary precision

For an actually covered debt-relief service, the corrected federal sequence is:

1. The seller or telemarketer must have renegotiated, settled, reduced, or otherwise altered at least one debt pursuant to a settlement agreement, debt-management plan, or other valid contractual agreement executed by the customer.
2. The customer must have made at least one payment pursuant to that agreement between the customer and the creditor or debt collector.
3. For debts altered individually, the fee must use either:the enrolled-balance proportional method; ora savings percentage that remains constant from debt to debt, with savings calculated from the enrolled amount and the amount actually paid to satisfy the debt. eCFR

The saved C022 reference to compliance with all §310.4(a)(5)(i)(A)–(C) conditions was not false; the PASS-04 narrative shorthand is replaced with the more exact predicates above.

For a dedicated account, the affected referral condition is:

The administrator does not give or accept money or other compensation in exchange for referrals of business involving the debt-relief service.

It is not limited to reciprocal or direct payments between the administrator and the provider. eCFR

Corrected account/model-matrix cell

The other dedicated-account conditions—insured financial institution, customer ownership and interest, withdrawal without penalty, and seven-business-day return of funds other than properly earned fees—remain unchanged. eCFR

PASS-04 Example E05 remains exactly conditional: no fee is assumed earned, no interest or pending item exists, and the stated remaining $700 is returned within seven business days if all applicable federal conditions and coverage predicates are satisfied. No calculation was rerun.

3. Corrective claim table

4. Corrected source/version usage cells

No new source document was required, so no duplicative S_DE-P5-S001+ source IDs are created. The existing PASS-04 document IDs are reused.

S_DE-P4-S004, the 2010 final order, was not needed or freshly reread for these corrections. Its historical status remains unchanged: it is not treated as proof that every displayed Rule 102 clause was first adopted in 2010 or that no later amendment exists.

5. Focused coverage patch

6. Preserved examples and holds

All six PASS-04 ledger examples remain numerically unchanged:

• E01: $250 current balance; prior creditor payments are not subtracted twice.
• E02: $20 reconciliation shortage; no consumer-ledger write-down authorization.
• E03: $300 cleared and $800 provisional; receipt and finality remain unresolved.
• E04: unproven $100 fee is not deducted; $800 conditional return remains.
• E05: conditional $700 federal dedicated-account return within seven business days.
• E06: five-day creditor-rejection notice does not itself terminate the agreement; $300 return follows only upon the assumed termination.

No PASS-01 fee example, PASS-04 ledger arithmetic, proportional allocation, lawful fee, interest amount, pending item, deadline calendar, insurance result, priority rule, or remitted-creditor clawback was recalculated or invented.

The following remain expressly open:

• complete 2026 Regulation 102 history and certification;
• indexed fee amounts and Attorney General approvals;
• provider and administrator authorization;
• actual account, bank, ACH, processor, and referral contracts;
• actual receipt, finality, fee earning, prior credits, and fee deductibility;
• insurance and federal deposit-insurance treatment;
• bankruptcy and receivership priority;
• complete agreements, waivers, bonds, remedies, collections, courts, limitations, and secured-sector law;
• money-transmission implementation, existing-licensee, delegate, and transition questions;
• local, tribal, country, and seven parent-dimension work.

Nothing in PASS-05 constitutes component, Delaware-state, parent, A066, operational, or publication acceptance.

7. Researcher self-check

Freshly read

• Current Chapter 24A definitions and the complete relevant deposit, disbursement, cancellation, waiver, termination, accounting, and return paragraphs at the literal Delaware Code URL.
• Rule 102 §§1.1, 11.1, and 13.1 at the materially different readable official route.
• The complete relevant federal §310.4(a)(5)(i)(A)–(C) and (ii)(C)–(E) clauses.

Reused without rerunning

• Every PASS-04 account classification, unaffected source, money-transmission finding, ledger example, numerical result, and coverage hold.
• The historical 2007 deletion and 2006 enactment work concerning the orphaned overdraft cross-reference.
• PASS-02’s fee, prior-credit, counseling, and adjustment qualifications.
• PASS-03’s provenance correction.

Not read or not performed in PASS-05

• The historical 2010 final order was not freshly reread and is not claimed to be the first adoption of every Rule 102 clause.
• Previously failed Rule 102 endpoints were not retried or recharacterized.
• No new Chapter 23 money-transmission research or implementation-notice conclusion was performed.
• No provider, administrator, contract, consumer account, bank record, ACH record, court case, private data, application, filing, or fee history was reviewed.
• No exact individual source-fetch timestamp is claimed.
• No Deep Research, Work mode, Codex research generation, API, Chrome control, new tab, other Chat, purchase, account change, filing, contact, site change, local write, or publication action was used.

This is a bounded same-coordinator precision correction, not independent review or publication readiness.

END S_DE PASS-05