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The explanation above is written for readers. These original working documents preserve the evidence trail, including technical language, dated passages and known corrections. They have not all received independent professional review. Use the marked limits before relying on a particular rule or figure.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
These components repair their stated scope. They do not replace every other finding in this research series.
Bounded P04 claim-link and source-pinpoint repair →Actual access date: October 24, 2026, Pacific Review status: Same-coordinator scoped correction after separate review of P1; not independent review. Preserved without recalculation: All seven P1 examples, 26 reviewed numeric quantities, three reviewed comparisons, substantive framework, historical material, proposal material, provider/contract holds, post-compilation holds, federal applicability holds, and all later-pass categories.
P1 §5.2 and C023 were too broad in treating the full-remittance settlement-completion definition as merely proposed: the official October 14, 2026 Agency 187 compilation already contains that definition in existing rule 187—20.1, with a source note identifying ARC 4061C, IAB October 10, 2018, effective November 14, 2018. ARC 0368D separately proposes replacing Chapter 20 and remains unresolved as a final rulemaking in the sources checked. Iowa Legislature+4
Title/issuer: Iowa Administrative Code, Banking Division [187], Agency PDF Direct literal URL: https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf
Official index locator: https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187
Version and exact usage: The official agency index is labeled “Iowa Administrative Code — 10/14/2026” and lists Chapter 20, Debt Management, within the Agency 187 PDF. Chapter 20 occupies printed pages 1–5, PDF indices 68–72, parsed lines 2652–2897. All five Chapter 20 pages were read; the other portions of the 75-page agency PDF were not comprehensively reviewed. Iowa Legislature+6
Chapter/version qualifications: The Chapter 20 page footers state IAC 2/5/25. Rule 20.1 and the remaining Chapter 20 rules carry source citations to ARC 4061C, IAB 10/10/18, effective 11/14/18; the chapter-end filing note identifies Notice ARC 3954C and the same effective date. The original 2018 adoption order was not freshly read. The October 14, 2026 compilation establishes the text present in that official compilation; it does not complete a later-than-October-14 amendment audit. Iowa Legislature+2
The old P1 aliases remain stable. Only the following cells are replaced.
| Stable P1 claim alias | Replacement precise assertion | Replacement evidence and pinpoint | Conditions and confidence limits |
|---|---|---|---|
| S_IA-P1-C009 / C009 | The percent-of-total-debt method uses equal installments over the first two-thirds of the contract. Its separate pro-rata collection provision applies “upon completion of a settlement”; in the official October 14, 2026 compiled Chapter 20, rule 187—20.1 defines that phrase as the point when all payments necessary to completely satisfy that debt have been remitted to the creditor. | P1 S002, Iowa Code §533A.9(4)(b)(1), printed p.1, lines 23–38; S_IA-P2-S001, 187—20.1, Ch. 20 printed p.1/PDF index 68/parsed lines 2655–2664. Iowa Legislature+1 | High for the statutory formula and rule text contained in the identified compilations. No change to P1 arithmetic. Later-than-October-14 rule changes, controlling interpretation, contract terms, earlier-fee reconciliation, cancellation-ledger treatment, and independently applicable federal timing remain held. |
| S_IA-P1-C010 / C010 | The savings method uses $50 monthly installments credited against fees earned from settlements, permits the stated savings calculation subject to the 30% savings-rate and 18% aggregate ceilings, and contains a collection branch “upon completion of a settlement.” For that completed-settlement branch, the existing compiled 187—20.1 full-remittance definition applies. | P1 S002, §533A.9(4)(b)(2), printed pp.1–2, lines 39–57; S_IA-P2-S001, 187—20.1, printed p.1/PDF index 68/lines 2655–2664. Iowa Legislature+1 | High for the text. This correction does not establish that the monthly installments are collectible in advance under federal law, that a particular contract complies, or that any previously collected amount was lawfully earned. |
| S_IA-P1-C016 / C016 | The Iowa Division of Banking provides an NMLS Consumer Access route and displays “Debt Management — December 31” operationally. Existing rule 20.3(6) qualifies the expiration statement: a license ordinarily expires on the next December 31 after issuance, but a license granted on or after November 1 and before January 1 does not expire until December 31 of the following year. Rule 20.5 requires timely renewal to remain authorized, submission through NMLS by December 1, a complete application, appropriate fees, and no revealed ground for denial; operation after expiration is unauthorized. | P1 S004, License Verification, “License Search” and “License Types”; S_IA-P2-S001, 20.3(6), printed p.1/PDF index 68/lines 2692–2695; 20.5(1)–(4), printed p.2/PDF index 69/lines 2708–2729. Iowa Division of Banking+3 | High for the operational page and compiled rule text. No named provider record, license issuance, renewal, active status, branch authority, or expiration date was verified. |
| S_IA-P1-C018 / C018 | ARC 0368D is a Notice of Intended Action proposing to rescind and replace Chapter 20. The official current-status routes checked still identify ARC 0368D as a proposed action/Notice of Intended Action. Separately, the October 14, 2026 Agency 187 compilation contains the preexisting Chapter 20 text sourced to ARC 4061C. | P1 S005, notice heading and purpose, lines 3–26; closed-comment/publication information, lines 212–224; Banking Division organization page, ARC 0368D entry, lines 89–94; S_IA-P2-S001, Chapter 20 source notes. Iowa Administrative Rules+3 | High that the proposal exists and that the compiled older rule text exists. Final adoption, withdrawal, modification, or another disposition of ARC 0368D was not established. Other chapters appearing as “Adopted and Filed” does not prove either adoption or nonadoption of this proposal. |
| S_IA-P1-C023 / C023 | Replacement for the prior cell: The settlement-completion definition is not merely proposed. Existing compiled rule 187—20.1 defines “upon completion of a settlement of a debtor’s debt” as when all payments necessary to completely satisfy the debt have been remitted to the creditor. ARC 0368D repeats materially the same definition in its proposed replacement chapter, but its final disposition remains held. | S_IA-P2-S001, 187—20.1, printed p.1/PDF index 68/lines 2655–2664; source note ARC 4061C, IAB 10/10/18, effective 11/14/18. P1 S005, proposed 20.1, lines 75–86. Iowa Legislature+1 | High for the definition appearing in the October 14, 2026 compilation and for the stated 2018 source/effective note. Original adoption-order history, post-October-14 changes, rule validity challenges, controlling decisions, and application to an actual performance record remain unverified. |
| S_IA-P1-C024 / C024 | A noncustodial program’s lawful collection schedule cannot be determined from Iowa’s fee ceilings alone. The state completed-settlement branch now has a verified compiled-rule qualification requiring full remittance to the creditor. Separately, where the federal TSR applies, §310.4(a)(5)(i)(B) uses the customer’s making at least one payment under the settlement agreement as one of its conditions. The two thresholds are textually distinct and must not be substituted for each other. | P1 S002, §533A.9(4); S_IA-P2-S001, 187—20.1; preserved P1 S006, §310.4(a)(5). A narrow fresh official eCFR check confirms the separate “at least one payment” wording. Iowa Legislature+2 | High for the textual distinction. Federal coverage, exemptions, sales-channel facts, CROA overlap, state/federal interaction, contract performance, and actual fee entitlement remain held. |
| S_IA-P1-C025 / C025 | Reading the official October 14, 2026 compiled Chapter 20 narrows P1’s operative-rules-text gap. It does not establish complete Iowa compliance, approval of a contract, or authorization of a provider. | P1 S001 §§533A.2–.9; P1 S004–S005; S_IA-P2-S001, complete Chapter 20 as compiled at printed pp.1–5/PDF indices 68–72. Iowa Legislature+4 | Post-compilation session laws, changes after October 14, final ARC 0368D disposition, provider-specific NMLS records, current company/branch checklists, system charges, contract evidence, controlling decisions, and federal applicability remain unresolved. |
Replace the proposal-only completion discussion with the following:
The settlement-completion definition is independently present in the official October 14, 2026 compiled Chapter 20. Existing rule 187—20.1 defines “upon completion of a settlement of a debtor’s debt” as the point when all payments necessary to completely satisfy that debt have been remitted to the creditor. The rule’s source note identifies ARC 4061C, IAB October 10, 2018, effective November 14, 2018. ARC 0368D proposes a replacement Chapter 20 and repeats the same full-remittance definition, but the proposal’s final disposition remains unverified. Iowa Legislature+1
Accordingly, whenever P1 C009, C010, E03, E04, E05, or E07 assumes a completed Iowa settlement for the statutory pro-rata fee branch, the assumption now means that all payments necessary to satisfy the individual debt have been remitted to the creditor. This does not change any P1 formula or numerical result. It does not resolve prior-fee credits, combined cancellation accounting, contract interpretation, or whether the assumed performance actually occurred. E06 assumed no completed settlement and needs no mathematical or factual rewrite. The state full-remittance definition remains distinct from the conditional federal TSR requirement that the customer make at least one payment under the settlement agreement. Iowa Legislature+2
| Identity or route | Direct literal URL | Actual use in PASS-02 | Status and limitation |
|---|---|---|---|
| New S_IA-P2-S001 — Agency 187 PDF | https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf | Freshly read all of Chapter 20: printed pp.1–5, PDF indices 68–72, parsed lines 2652–2897. | Substantive new authority for 20.1, 20.3(6), and 20.5. The full 75-page agency document was not read. Chapter footer is IAC 2/5/25; source note states effective 11/14/18. Iowa Legislature+4 |
| Official Agency 187 index/locator | https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187 | Freshly read. Establishes the official index label “Iowa Administrative Code — 10/14/2026,” Agency PDF route, and Chapter 20 listing. | Locator for S_IA-P2-S001; not assigned a duplicative substantive document ID. Iowa Legislature+1 |
| Individual Chapter 20 rule-list route | https://www.legis.iowa.gov/law/administrativeRules/rules?agency=187&chapter=20&pubDate=10-14-2026 | The coordinator previously reported a cache miss. Fresh PASS-02 access returned a rule-listing page, including the October 14, 2026 heading and rule names, but not the operative rule bodies. | No substantive reliance; Agency PDF supplies the actual text. A failed or listing-only HTML route is not generalized into a claim that the rules were unread. Iowa Legislature |
| P1 S005 — ARC 0368D | https://rules.iowa.gov/Notice/Details/0368D | S005 remains unchanged. Coordinator-provided provenance records a complete 260-line read; PASS-02 freshly checked the notice identity, proposed 20.1, renewal provisions, publication date, and closed-comment status. | Notice published June 10, 2026; comments closed July 14, 2026. It remains a proposal in the routes checked; no final-disposition inference. Iowa Administrative Rules+3 |
| Banking Division rulemaking status route | https://rules.iowa.gov/Organization/Details/banking-division | Freshly checked for bounded status qualification. | ARC 0368D is displayed as “Notice of Intended Action”; other entries’ adopted status does not prove this proposal’s disposition. Iowa Administrative Rules |
| P1 S001 dynamic and dated Chapter 533A routes | https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf | https://www.legis.iowa.gov/docs/code/2026/533A.pdf | Both freshly opened. Each rendered a 14-page Iowa Code 2026 Chapter 533A with a December 9, 2025 footer. | No new source ID and no byte-identity assertion. They remain two observed routes to the same underlying statutory chapter. Iowa Legislature+1 |
| P1 S002 — §533A.9 section PDF | https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf | Freshly checked for exact completed-settlement clauses and footer. | Complete two-page section; footer dated December 12, 2025. Existing S002 retained, not duplicated. Iowa Legislature+1 |
| P1 S004 — IDOB verification page | https://idob.iowa.gov/finance/finance-license-verification | Freshly checked for the NMLS route and operational expiration table. | Procedure only; no provider search or license result. Iowa Division of Banking |
| Federal timing comparator only | https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | Freshly opened only to confirm the distinct first-customer-payment language in §310.4(a)(5)(i)(B). | P1 S006’s original Cornell provenance remains unchanged. No federal coverage, exception, CROA, §310.2, or §310.6 reanalysis was performed. eCFR |
| Corrective claim ID | Corrective assertion | Evidence and qualification |
|---|---|---|
| S_IA-P2-C001 | The official October 14, 2026 Agency 187 compilation contains an existing 187—20.1 definition requiring all payments necessary to satisfy the debt to have been remitted to the creditor before a settlement is “completed” under that phrase. | S_IA-P2-S001, printed p.1/PDF index 68/lines 2655–2664. Compilation-date and later-amendment limits preserved. Iowa Legislature |
| S_IA-P2-C002 | The existing rule, not merely ARC 0368D, supplies the full-remittance assumption for P1’s completed-settlement fee branches. | S_IA-P2-S001 and P1 S002 §533A.9(4)(b)(1)–(2). No change to formulas or results. Iowa Legislature+1 |
| S_IA-P2-C003 | Iowa’s compiled rule qualifies the generic December 31 expiration description with the November 1–January 1 issuance window and separately requires timely, complete renewal to remain authorized. | S_IA-P2-S001, 20.3(6), printed p.1/index 68/lines 2692–2695; 20.5(1)–(4), p.2/index 69/lines 2708–2729. No provider status established. Iowa Legislature+1 |
| S_IA-P2-C004 | ARC 0368D’s identity and unresolved final status are separate from the existence of the older compiled Chapter 20 text. | P1 S005; Banking Division status page; S_IA-P2-S001. No adoption, withdrawal, or nonadoption inference. Iowa Administrative Rules+2 |
| S_IA-P2-C005 | PASS-02 narrows the old-rules-text gap only. It does not verify complete Iowa compliance, a particular contract, or any provider’s authority. | S_IA-P2-S001; P1 S001–S006. Provider, contract, post-compilation, case-law, federal, local, tribal, and later-pass holds remain. |
| Existing P1 coverage row or example | Corrected status | PASS-02 linkage | Remaining exact hold |
|---|---|---|---|
| Percent-of-total-debt collection | Partial — narrowed | C009; P2-C001–C002; E03 | The pro-rata completed-settlement branch now carries the full-remittance assumption. Earlier installments, federal timing, actual performance, contract terms, and prior-fee allocation remain unresolved. |
| Percent-of-savings collection | Partial — narrowed | C010; P2-C001–C002; E04–E05 | The completed-settlement calculation now carries the full-remittance assumption. The legality of earlier $50 collections, credits, federal timing, and actual earning remains held. |
| Partial-settlement allocation | Partial — narrowed | C009–C010; E03–E05 | “Completed” is clarified; the formulas are unchanged. No finding that one creditor payment, one customer payment, or creditor acceptance alone satisfies the Iowa full-remittance definition. |
| Cancellation/refunds | Partial — unchanged except assumption clarification | C011 with corrected C009–C010; E06–E07 | E06 assumed no completed settlement and is unchanged. In E07, use of the completed-settlement branch requires full remittance. The interaction between the completed-settlement amount, scheduled-installment retention, prior collections, and refund remains held; the figures must not simply be added. |
| Public license lookup | Answered as procedure, with expiry qualification | C016; P2-C003 | NMLS route and general December 31 description preserved; issuance-window and renewal conditions added. No named-provider result. |
| Named-provider authorization | Unresolved | C021, corrected C016 and C025 | Actual NMLS/Iowa record, active status, company/branch scope, renewal, and authority to operate remain unverified. |
| Administrative Chapter 20 currency | Partial — materially narrowed | Corrected C018, C023, C025; P2-C001, C004–C005 | Official Chapter 20 text in the October 14, 2026 compilation was read. Final ARC 0368D disposition, changes after October 14, original adoption-order history, and controlling interpretations remain held. |
| Federal TSR timing | Partial — no scope expansion | Corrected C024; P2-C002 | Iowa full remittance and conditional TSR first customer payment are distinct. Full TSR applicability, §310.2/§310.6 exceptions, CROA, channel facts, and credit-repair overlap remain held. |
| Post-compilation statutory/rule currentness | Unresolved | C022, corrected C025 | No post-compilation session-law bill-status audit and no later-than-October-14 rule-change audit were completed. |
| Complete licensing and contract compliance | Unresolved | Corrected C025 | Current NMLS company/branch checklists, system charges, provider records, actual contract, settlement evidence, accounting records, case law, and agency interpretations remain required. |
The coordinator-identified reconciliation between Iowa Code §533A.8(7)’s five-year record provision and rule 20.9(1)(b)’s 36-month language remains a separate unresolved conditions/currentness issue. PASS-02 does not resolve that issue and does not shorten any retention period. Rule 20.9(1)(b), as present in the October 14 compilation, states at least 36 months from the final transaction, but the statutory relationship was not analyzed here. Iowa Legislature+1
The full current NMLS company and branch checklists, NMLS charges, government/system fees beyond previously established text, actual provider records, full contract analysis, post-compilation legislation, CROA, federal sales-channel applicability, local law, tribal law, secured-debt issues, remedies, limitations, litigation, and all other later Iowa dossier categories remain open.
The following were freshly accessed:
The same coordinator’s complete P1 review, all P1 calculations, example structures, prior source reads, proposal read history, historical material, and federal-source provenance were reused. No numerical example was rerun or rewritten.
The following were not established:
No application was filed, no provider or regulator was contacted, no private data was accessed, no local artifact was written, and no publication or site was changed.
This PASS-02 is a same-coordinator bounded correction, not independent review, and it does not imply Iowa launch approval, provider approval, contract approval, A066 acceptance, or publication readiness.
END S_IA PASS-02
Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
These components repair their stated scope. They do not replace every other finding in this research series.
Bounded P04 claim-link and source-pinpoint repair →Stable P1 claim alias · Replacement precise assertion · Replacement evidence and pinpoint · 7 data rows
| Stable P1 claim alias | Replacement precise assertion | Replacement evidence and pinpoint | Conditions and confidence limits |
|---|---|---|---|
| S_IA-P1-C009 / C009 | The percent-of-total-debt method uses equal installments over the first two-thirds of the contract. Its separate pro-rata collection provision applies “upon completion of a settlement”; in the official October 14, 2026 compiled Chapter 20, rule 187—20.1 defines that phrase as the point when all payments necessary to completely satisfy that debt have been remitted to the creditor. | P1 S002, Iowa Code §533A.9(4)(b)(1), printed p.1, lines 23–38; S_IA-P2-S001, 187—20.1, Ch. 20 printed p.1/PDF index 68/parsed lines 2655–2664. Iowa Legislature +1 | High for the statutory formula and rule text contained in the identified compilations. No change to P1 arithmetic. Later-than-October-14 rule changes, controlling interpretation, contract terms, earlier-fee reconciliation, cancellation-ledger treatment, and independently applicable federal timing remain held. |
| S_IA-P1-C010 / C010 | The savings method uses $50 monthly installments credited against fees earned from settlements, permits the stated savings calculation subject to the 30% savings-rate and 18% aggregate ceilings, and contains a collection branch “upon completion of a settlement.” For that completed-settlement branch, the existing compiled 187—20.1 full-remittance definition applies. | P1 S002, §533A.9(4)(b)(2), printed pp.1–2, lines 39–57; S_IA-P2-S001, 187—20.1, printed p.1/PDF index 68/lines 2655–2664. Iowa Legislature +1 | High for the text. This correction does not establish that the monthly installments are collectible in advance under federal law, that a particular contract complies, or that any previously collected amount was lawfully earned. |
| S_IA-P1-C016 / C016 | The Iowa Division of Banking provides an NMLS Consumer Access route and displays “Debt Management — December 31” operationally. Existing rule 20.3(6) qualifies the expiration statement: a license ordinarily expires on the next December 31 after issuance, but a license granted on or after November 1 and before January 1 does not expire until December 31 of the following year. Rule 20.5 requires timely renewal to remain authorized, submission through NMLS by December 1, a complete application, appropriate fees, and no revealed ground for denial; operation after expiration is unauthorized. | P1 S004, License Verification, “License Search” and “License Types”; S_IA-P2-S001, 20.3(6), printed p.1/PDF index 68/lines 2692–2695; 20.5(1)–(4), printed p.2/PDF index 69/lines 2708–2729. Iowa Division of Banking +3 | High for the operational page and compiled rule text. No named provider record, license issuance, renewal, active status, branch authority, or expiration date was verified. |
| S_IA-P1-C018 / C018 | ARC 0368D is a Notice of Intended Action proposing to rescind and replace Chapter 20. The official current-status routes checked still identify ARC 0368D as a proposed action/Notice of Intended Action. Separately, the October 14, 2026 Agency 187 compilation contains the preexisting Chapter 20 text sourced to ARC 4061C. | P1 S005, notice heading and purpose, lines 3–26; closed-comment/publication information, lines 212–224; Banking Division organization page, ARC 0368D entry, lines 89–94; S_IA-P2-S001, Chapter 20 source notes. Iowa Administrative Rules +3 | High that the proposal exists and that the compiled older rule text exists. Final adoption, withdrawal, modification, or another disposition of ARC 0368D was not established. Other chapters appearing as “Adopted and Filed” does not prove either adoption or nonadoption of this proposal. |
| S_IA-P1-C023 / C023 | Replacement for the prior cell: The settlement-completion definition is not merely proposed. Existing compiled rule 187—20.1 defines “upon completion of a settlement of a debtor’s debt” as when all payments necessary to completely satisfy the debt have been remitted to the creditor. ARC 0368D repeats materially the same definition in its proposed replacement chapter, but its final disposition remains held. | S_IA-P2-S001, 187—20.1, printed p.1/PDF index 68/lines 2655–2664; source note ARC 4061C, IAB 10/10/18, effective 11/14/18. P1 S005, proposed 20.1, lines 75–86. Iowa Legislature +1 | High for the definition appearing in the October 14, 2026 compilation and for the stated 2018 source/effective note. Original adoption-order history, post-October-14 changes, rule validity challenges, controlling decisions, and application to an actual performance record remain unverified. |
| S_IA-P1-C024 / C024 | A noncustodial program’s lawful collection schedule cannot be determined from Iowa’s fee ceilings alone. The state completed-settlement branch now has a verified compiled-rule qualification requiring full remittance to the creditor. Separately, where the federal TSR applies, §310.4(a)(5)(i)(B) uses the customer’s making at least one payment under the settlement agreement as one of its conditions. The two thresholds are textually distinct and must not be substituted for each other. | P1 S002, §533A.9(4); S_IA-P2-S001, 187—20.1; preserved P1 S006, §310.4(a)(5). A narrow fresh official eCFR check confirms the separate “at least one payment” wording. Iowa Legislature +2 | High for the textual distinction. Federal coverage, exemptions, sales-channel facts, CROA overlap, state/federal interaction, contract performance, and actual fee entitlement remain held. |
| S_IA-P1-C025 / C025 | Reading the official October 14, 2026 compiled Chapter 20 narrows P1’s operative-rules-text gap. It does not establish complete Iowa compliance, approval of a contract, or authorization of a provider. | P1 S001 §§533A.2–.9; P1 S004–S005; S_IA-P2-S001, complete Chapter 20 as compiled at printed pp.1–5/PDF indices 68–72. Iowa Legislature +4 | Post-compilation session laws, changes after October 14, final ARC 0368D disposition, provider-specific NMLS records, current company/branch checklists, system charges, contract evidence, controlling decisions, and federal applicability remain unresolved. |
Identity or route · Direct literal URL · Actual use in PASS-02 · 9 data rows
| Identity or route | Direct literal URL | Actual use in PASS-02 | Status and limitation |
|---|---|---|---|
| New S_IA-P2-S001 — Agency 187 PDF | https://www.legis.iowa.gov/docs/iac/agency/10-14-2026.187.pdf | Freshly read all of Chapter 20: printed pp.1–5, PDF indices 68–72, parsed lines 2652–2897. | Substantive new authority for 20.1, 20.3(6), and 20.5. The full 75-page agency document was not read. Chapter footer is IAC 2/5/25; source note states effective 11/14/18. Iowa Legislature +4 |
| Official Agency 187 index/locator | https://www.legis.iowa.gov/law/administrativeRules/chapters?agency=187 | Freshly read. Establishes the official index label “Iowa Administrative Code — 10/14/2026,” Agency PDF route, and Chapter 20 listing. | Locator for S_IA-P2-S001; not assigned a duplicative substantive document ID. Iowa Legislature +1 |
| Individual Chapter 20 rule-list route | https://www.legis.iowa.gov/law/administrativeRules/rules?agency=187&chapter=20&pubDate=10-14-2026 | The coordinator previously reported a cache miss. Fresh PASS-02 access returned a rule-listing page, including the October 14, 2026 heading and rule names, but not the operative rule bodies. | No substantive reliance; Agency PDF supplies the actual text. A failed or listing-only HTML route is not generalized into a claim that the rules were unread. Iowa Legislature |
| P1 S005 — ARC 0368D | https://rules.iowa.gov/Notice/Details/0368D | S005 remains unchanged. Coordinator-provided provenance records a complete 260-line read; PASS-02 freshly checked the notice identity, proposed 20.1, renewal provisions, publication date, and closed-comment status. | Notice published June 10, 2026; comments closed July 14, 2026. It remains a proposal in the routes checked; no final-disposition inference. Iowa Administrative Rules +3 |
| Banking Division rulemaking status route | https://rules.iowa.gov/Organization/Details/banking-division | Freshly checked for bounded status qualification. | ARC 0368D is displayed as “Notice of Intended Action”; other entries’ adopted status does not prove this proposal’s disposition. Iowa Administrative Rules |
| P1 S001 dynamic and dated Chapter 533A routes | https://www.legis.iowa.gov/docs/ico/chapter/533A.pdf | https://www.legis.iowa.gov/docs/code/2026/533A.pdf | Both freshly opened. Each rendered a 14-page Iowa Code 2026 Chapter 533A with a December 9, 2025 footer. | No new source ID and no byte-identity assertion. They remain two observed routes to the same underlying statutory chapter. Iowa Legislature +1 |
| P1 S002 — §533A.9 section PDF | https://www.legis.iowa.gov/docs/code/2026/533A.9.pdf | Freshly checked for exact completed-settlement clauses and footer. | Complete two-page section; footer dated December 12, 2025. Existing S002 retained, not duplicated. Iowa Legislature +1 |
| P1 S004 — IDOB verification page | https://idob.iowa.gov/finance/finance-license-verification | Freshly checked for the NMLS route and operational expiration table. | Procedure only; no provider search or license result. Iowa Division of Banking |
| Federal timing comparator only | https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310/section-310.4 | Freshly opened only to confirm the distinct first-customer-payment language in §310.4(a)(5)(i)(B). | P1 S006’s original Cornell provenance remains unchanged. No federal coverage, exception, CROA, §310.2, or §310.6 reanalysis was performed. eCFR |
Corrective claim ID · Corrective assertion · Evidence and qualification · 5 data rows
| Corrective claim ID | Corrective assertion | Evidence and qualification |
|---|---|---|
| S_IA-P2-C001 | The official October 14, 2026 Agency 187 compilation contains an existing 187—20.1 definition requiring all payments necessary to satisfy the debt to have been remitted to the creditor before a settlement is “completed” under that phrase. | S_IA-P2-S001, printed p.1/PDF index 68/lines 2655–2664. Compilation-date and later-amendment limits preserved. Iowa Legislature |
| S_IA-P2-C002 | The existing rule, not merely ARC 0368D, supplies the full-remittance assumption for P1’s completed-settlement fee branches. | S_IA-P2-S001 and P1 S002 §533A.9(4)(b)(1)–(2). No change to formulas or results. Iowa Legislature +1 |
| S_IA-P2-C003 | Iowa’s compiled rule qualifies the generic December 31 expiration description with the November 1–January 1 issuance window and separately requires timely, complete renewal to remain authorized. | S_IA-P2-S001, 20.3(6), printed p.1/index 68/lines 2692–2695; 20.5(1)–(4), p.2/index 69/lines 2708–2729. No provider status established. Iowa Legislature +1 |
| S_IA-P2-C004 | ARC 0368D’s identity and unresolved final status are separate from the existence of the older compiled Chapter 20 text. | P1 S005; Banking Division status page; S_IA-P2-S001. No adoption, withdrawal, or nonadoption inference. Iowa Administrative Rules +2 |
| S_IA-P2-C005 | PASS-02 narrows the old-rules-text gap only. It does not verify complete Iowa compliance, a particular contract, or any provider’s authority. | S_IA-P2-S001; P1 S001–S006. Provider, contract, post-compilation, case-law, federal, local, tribal, and later-pass holds remain. |
Existing P1 coverage row or example · Corrected status · PASS-02 linkage · 10 data rows
| Existing P1 coverage row or example | Corrected status | PASS-02 linkage | Remaining exact hold |
|---|---|---|---|
| Percent-of-total-debt collection | Partial — narrowed | C009; P2-C001–C002; E03 | The pro-rata completed-settlement branch now carries the full-remittance assumption. Earlier installments, federal timing, actual performance, contract terms, and prior-fee allocation remain unresolved. |
| Percent-of-savings collection | Partial — narrowed | C010; P2-C001–C002; E04–E05 | The completed-settlement calculation now carries the full-remittance assumption. The legality of earlier $50 collections, credits, federal timing, and actual earning remains held. |
| Partial-settlement allocation | Partial — narrowed | C009–C010; E03–E05 | “Completed” is clarified; the formulas are unchanged. No finding that one creditor payment, one customer payment, or creditor acceptance alone satisfies the Iowa full-remittance definition. |
| Cancellation/refunds | Partial — unchanged except assumption clarification | C011 with corrected C009–C010; E06–E07 | E06 assumed no completed settlement and is unchanged. In E07, use of the completed-settlement branch requires full remittance. The interaction between the completed-settlement amount, scheduled-installment retention, prior collections, and refund remains held; the figures must not simply be added. |
| Public license lookup | Answered as procedure, with expiry qualification | C016; P2-C003 | NMLS route and general December 31 description preserved; issuance-window and renewal conditions added. No named-provider result. |
| Named-provider authorization | Unresolved | C021, corrected C016 and C025 | Actual NMLS/Iowa record, active status, company/branch scope, renewal, and authority to operate remain unverified. |
| Administrative Chapter 20 currency | Partial — materially narrowed | Corrected C018, C023, C025; P2-C001, C004–C005 | Official Chapter 20 text in the October 14, 2026 compilation was read. Final ARC 0368D disposition, changes after October 14, original adoption-order history, and controlling interpretations remain held. |
| Federal TSR timing | Partial — no scope expansion | Corrected C024; P2-C002 | Iowa full remittance and conditional TSR first customer payment are distinct. Full TSR applicability, §310.2/§310.6 exceptions, CROA, channel facts, and credit-repair overlap remain held. |
| Post-compilation statutory/rule currentness | Unresolved | C022, corrected C025 | No post-compilation session-law bill-status audit and no later-than-October-14 rule-change audit were completed. |
| Complete licensing and contract compliance | Unresolved | Corrected C025 | Current NMLS company/branch checklists, system charges, provider records, actual contract, settlement evidence, accounting records, case law, and agency interpretations remain required. |
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
These components repair their stated scope. They do not replace every other finding in this research series.
Bounded P04 claim-link and source-pinpoint repair →Recorded check status: scoped support with explicit limits
Recorded check status: scoped support with explicit limits
Recorded check status: qualified by pass03 with remaining provider and currentness holds
Recorded check status: scoped support with explicit limits
Recorded check status: scoped support with explicit limits
Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.
Recorded check status: scoped source support access date correction required
Recorded check status: scoped source support access date correction required
Recorded check status: scoped source support access date correction required
Recorded check status: scoped source support access date correction required
Recorded check status: scoped source support access date correction required
Recorded check status: scoped source support access date correction required
Recorded check status: scoped source support access date correction required
Recorded check status: scoped source support access date correction required
Recorded check status: scoped source support access date correction required
The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.
revise
Inside: 1. Executive findings · Preliminary business-model classification · 2. Substantive findings: classification and market access
Inside: Bounded provenance and renewal-wording correction to saved PASS-02 · 1. Provenance patch · 2. Minimal replacement for S_IA-P1-C016 / C016
Inside: Iowa consumer-money custody, trust accounts, administrators, records, and returns · 1.1 Activity, not the account label, controls · 1.2 Account/model matrix
Inside: Iowa debt-management bond, security, and necessary consumer-recovery component · Bounded conclusion · 1.1 Who must obtain and maintain the bond
Inside: Iowa mandatory agreement, disclosure, signature, electronic-consent, notice, amendment, and waiver component · Bounded disposition · 1.2 Mandatory pre-enrollment sequence
Inside: Bounded PASS-05 source-qualification correction · 1. Exact drop-in narrative replacements · 2. Replacement and distinct atomic-claim table
Inside: Ordinary consumer-debt limitation, accrual, acknowledgment, payment, and judgment-duration gateway · A1. The 2026 compilation requires a later-enactment qualification · A2. Classification and accrual matrix
Inside: Bounded P04 claim-link and source-pinpoint repair · 1. One added atomic records claim · P04 §3.3 — Chapter 533C paragraph
Inside: Bounded P06 example-premise, claim-link, and case-use patch · A. Corrected S_IA-P6-E03 and affected matrix entry · S_IA-P6-E03 — Custodial contract and creditor-consent boundary
Inside: Iowa collection actors, notification/licensing boundaries, security, and public consumer-procedure gateway · Principal findings · A1. The underlying obligation must qualify
Inside: Ordinary consumer-debt collection communications and prohibited conduct · 1.1 Iowa’s conduct definition includes collection for oneself · 1.3 Actor and cumulative-law matrix
Original saved Markdown SHA-256: 33703b2c05e227c2f3cc9c269d3853c89de18ef6e0c9cc1e1506f9531c917c75. Public formatting, private-reference removal and correction annotations are separate from that immutable original.