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

SettleADebt S_IA PASS-05

Iowa debt-management bond, security, and necessary consumer-recovery component

Actual fresh research date: October 25, 2026, Pacific; October 26, 2026 UTC Review relationship: Same-coordinator continuation of the saved and reviewed P1–P3 work; not independent review. P4 treatment: PASS-04 is saved but unreviewed. No new P4 legal conclusion is treated here as reviewed or used to expand this component. Scope: Bond/security and the minimum recovery mechanics necessary to understand that security. Fees, trust-account ledgers, agreement enforceability, general civil litigation, limitations, remedies, and earlier examples are not rerun.

Exact individual source-fetch timestamps were not preserved and are not invented. Historical enactment, compilation, publication, and effective dates below remain distinct from this PASS-05 access date.

Bounded conclusion

Iowa’s official 2026 Code requires a debt-management applicant to provide a superintendent-approved bond:

• $25,000 for each office;
• in favor of the people of Iowa;
• conditioned on compliance with laws pertaining to the business and faithful accounting for entrusted money by the provider, employees, and agents;
• expressly for indemnifying debtors against loss resulting from conduct prohibited by Chapter 533A; and
• capped so that the surety’s aggregate liability to all debtors doing business with the bonded office never exceeds that office bond’s penal sum. Iowa Legislature

That is an aggregate office-level ceiling, not $25,000 per consumer, per violation, or per claim. A $25,000 requirement also does not prove that a particular provider has a valid bond, that capacity remains available, that a claimant’s loss is covered, or that the claimant will receive $25,000.

The operative statute and compiled rule do not authorize a cash deposit, letter of credit, fidelity policy, self-insurance, or other substitute for the required surety bond. The public NMLS material confirms an electronic surety-bond system for the Iowa Debt Management License, but the current Iowa-specific rendered form and claim instructions were not recovered through the public routes checked. NMLS’s July 29, 2025 adoption table also says branch bonds are not accepted in its ESB system, creating an unresolved filing-mechanics question because Iowa law still calculates the required penal amount “for each office.” Iowa Legislature+1

1. Operative bond and security requirements

1.1 Who must obtain and maintain the bond

The bond obligation attaches to each covered Chapter 533A license application. A person cannot engage in Iowa debt management until a good and sufficient bond has been filed. Compiled Rule 187—20.3(5) likewise requires an applicant to file a $25,000 surety bond complying with §533A.2(4). Iowa Legislature+1

The obligation does not independently apply to a person who actually satisfies one of §533A.2(2)’s conditional exemptions because those persons are not required to be licensed or otherwise comply with Chapter 533A. That exemption conclusion is only as sound as the underlying entity and activity facts. An attorney relationship, nonprofit label, institutional affiliation, or money-transmitter role cannot be assumed to satisfy an exemption. Iowa Legislature

Employees acting for their licensed employer are conditionally exempt from separate licensure, but the bond’s accounting condition expressly reaches money entrusted to the provider and its employees and agents. Thus, the principal’s bond may respond to covered employee or agent conduct; the employee is not shown to need an independent bond merely because the employee handles an account. Iowa Legislature+1

1.2 Amount, office base, and branch treatment

The statutory base is:

$25,000×number of covered offices$25{,}000 \times \text{number of covered offices}$25,000×number of covered offices“Office” means each location, identified by street number, building number, city, and state, where a person engages in debt management. Each application must carry a $25,000 penal sum for each office. Iowa Legislature+1

Compiled Rule 20.6 treats a branch office as an independently licensed branch and requires a branch application through NMLS. A name or location change requires proof that the licensee obtained a new bond or amended the existing bond to reflect the new name or location. Iowa Legislature

That supports a separate security amount attributable to each covered office. It does not, without the current rendered form and filing instructions, establish whether Iowa currently requires:

• a wholly separate bond instrument for every office;
• one company bond with a multiplied penal sum;
• a schedule of offices;
• an office rider; or
• some other NMLS implementation.

That distinction matters because NMLS’s July 29, 2025 ESB adoption table lists the Iowa Debt Management License as a company license and carries the heading “Branch Bonds are Not Accepted.” The NMLS statement addresses its electronic filing architecture; it does not amend Iowa’s statutory $25,000-per-office calculation. NMLS Resource Center+1

1.3 Issuer and approval

The bond must be approved by Iowa’s Superintendent of Banking. Iowa’s general surety-company law provides that the insurance commissioner maintains a list of corporate sureties with current authority, and an approving public body must accept a bond guaranteed by an Iowa-organized or Iowa-authorized company holding the required insurance certificate of authority. That certificate is sufficient evidence of authority for bond approval. Iowa Legislature+2

No actual surety company, producer, certificate of authority, bond number, or superintendent approval was verified in this pass.

1.4 Authorized security form

The operative debt-management statute and compiled rule identify a bond and, more specifically, a surety bond. No operative provision reviewed authorizes the applicant to substitute:

• cash or a certificate of deposit;
• a letter of credit;
• a fidelity bond;
• a trust balance;
• errors-and-omissions insurance;
• self-insurance;
• a parent guarantee; or
• a money-transmitter security instrument.

The result is bounded: no alternative security pathway was established in the reviewed Chapter 533A and Chapter 20 provisions. It is not a conclusion about every possible agency power or subsequently enacted law.

The $250 office-license fee, $100 investigation fee, NMLS charges, consumer fees, and consumer principal are legally distinct from the $25,000 surety bond. Paying one does not satisfy another.

2. Covered duties, protected persons, and recovery predicates

2.1 Bond conditions

Section 533A.2(4) states two connected bond conditions:

1. The obligor will not violate any law pertaining to the debt-management business.
2. The obligor will faithfully account for all money collected on entrusted accounts by the provider, employees, and agents.

The statute then states the bond’s indemnity purpose: protecting debtors from loss resulting from conduct prohibited by Chapter 533A. Iowa Legislature

The broad “any law pertaining to such business” condition should not be converted automatically into a private bond claim for every conceivable regulatory violation. For a consumer-recovery conclusion, the strongest express statutory pathway requires:

• a person qualifying as a Chapter 533A debtor;
• a loss, not merely a technical violation;
• causal connection between the loss and conduct prohibited by Chapter 533A;
• connection to the office for which the bond was filed;
• a breach occurring before the surety’s effective cancellation cutoff;
• a valid bond and available penal capacity; and
• compliance with whatever claim, suit, notice, and timeliness requirements apply under the current official bond and governing law.

The first several elements are supported by the statute. The final procedural elements remain unresolved because the current official bond form and materially on-point controlling decision were not recovered.

2.2 Payee and intended protected class

The bond is expressly:

• in favor of the people of the state of Iowa; and
• intended to indemnify debtors for covered loss. Iowa Legislature

This identifies debtors as the protected class but does not, in the statutory paragraph itself, state:

• the precise person to whom a claim must be submitted;
• whether a consumer may proceed directly against the surety;
• whether the State or superintendent must be named;
• whether administrative approval is required;
• whether a final judgment against the provider is required;
• the form or content of proof of loss;
• the deadline for notice or suit; or
• whether a claimant must first exhaust recovery against the provider.

Iowa Code §636.20 supplies service mechanics when suit is otherwise required on a corporate-surety bond: service may be made on the surety’s Iowa agent, or on the insurance commissioner if the surety has no Iowa agent. It does not itself create a cause of action, establish standing, or set a Chapter 533A claim period. Iowa Legislature

2.3 Debtor loss versus provider liability

The bond is security for covered loss; it is not the full measure of the provider’s potential liability. The following remain legally distinct:

A consumer should not receive the same loss twice. But neither §533A.2(4) nor the other provisions reviewed establish the detailed offset, subrogation, or priority rules between restitution, provider payment, bond payment, bankruptcy distribution, and another recovery source.

3. Cancellation, maintenance, aggregate limits, and exhaustion

3.1 Continuing maintenance

Iowa law bars operation until a good and sufficient bond is filed. Failure to post the required bond, receipt by the superintendent of a cancellation notice, and failure to maintain the required bond are grounds for discipline. Available discipline includes revocation, suspension, probation, civil penalties, warning, and restitution. Iowa Legislature+1

This establishes an ongoing operational need for uninterrupted compliant security. It does not establish that the license automatically terminates at the instant a cancellation notice is received. The statute instead identifies cancellation notice as a disciplinary ground, while the no-bond operating prohibition remains independently applicable.

A replacement must therefore be effective in time to prevent an uncovered operating gap. The exact superintendent processing sequence, replacement acceptance mechanics, and overlap between predecessor and successor bonds were not stated in the provisions reviewed.

3.2 Surety cancellation and breach cutoff

The surety may cancel by giving the superintendent 30 days’ notice. The surety is relieved from liability for a breach occurring after the effective date of cancellation. Iowa Legislature

This supports the following distinction:

• A pre-effective-date breach is not released merely because cancellation later becomes effective.
• A post-effective-date breach falls outside the canceled surety’s statutory liability.
• The statute does not state an unlimited post-cancellation claims tail.
• The date a claimant discovers the loss, files a complaint, files suit, or obtains judgment is not expressly made the coverage trigger in §533A.2(4).

The current official bond form, applicable limitation period, and controlling interpretation are needed to determine the deadline for asserting an otherwise pre-cancellation covered loss.

3.3 Aggregate liability

The surety’s aggregate liability to all debtors doing business with the office for which the bond was filed cannot exceed that bond’s penal sum. Iowa Legislature

Therefore:

• $25,000 is not a per-debtor entitlement.
• $25,000 is not restored automatically for each new claim.
• A court judgment exceeding $25,000 would not, by itself, increase the surety’s statutory cap.
• Multiple violations involving one debtor do not establish multiple $25,000 limits.
• Bonds attributable to other offices cannot automatically be stacked for a debtor who did business with only one office.
• The aggregate-cap language does not itself explain how competing claims are prioritized or allocated.

No verified provision established:

• first-to-file priority;
• first-to-judgment priority;
• pro-rata distribution;
• superintendent allocation;
• interpleader procedure;
• a per-consumer sublimit;
• mandatory replenishment after payment;
• annual restoration of the penal sum;
• a separate aggregate for each bond year;
• automatic increase based on consumer volume or trust balances; or
• how claims overlap across a replacement bond and prior bond.

These remain explicit holds.

3.4 Name, location, and branch changes

Before a name or location change, Rule 20.6 requires proof of a new bond or an amendment to the existing bond reflecting the changed name or location. A branch requires its own license application, and branch licenses are treated as independent licenses for renewal. Iowa Legislature

The rule does not say what happens to:

• claims tied to the old legal name;
• conduct spanning a location change;
• a rider issued after the requested change date;
• predecessor-provider liabilities after a merger or conversion;
• a bond issued to an entity with a similar but legally different name; or
• claims involving consumers serviced from multiple offices.

Those questions require the actual bond, riders, corporate records, office facts, and controlling law.

3.5 Bond records

Compiled Rule 20.9(7)(d) requires the licensee to keep all correspondence and records concerning maintenance of the Chapter 533A surety bond. Iowa Legislature

The rule states a 36-month minimum, while the previously reviewed statute states a five-year period for covered records after the final entry on a transaction. PASS-05 preserves the existing hold: the rule does not authorize shortening a longer statutory retention duty. The precise classification and trigger for bond-maintenance correspondence remain unresolved.

3.6 Surety insolvency and guaranty association

Iowa’s Insurance Guaranty Association chapter expressly excludes “fidelity or surety bonds, or any other bonding obligations.” Therefore, Chapter 515B is not an established fallback source for a consumer if the debt-management surety becomes insolvent. Iowa Legislature

This does not resolve:

• the surety’s domiciliary liquidation process;
• proof-of-claim deadlines;
• reinsurance;
• collateral securing the surety;
• subrogation;
• receivership priority;
• another state’s guaranty mechanism; or
• the claimant’s recovery from the provider or its estate.

Those matters remain outside this bounded pass.

4. Official form, NMLS instructions, complaint route, and public records

4.1 NMLS electronic bond process

NMLS states that its electronic surety bond system allows company licensees to submit and manage bonds electronically, including new bonds, riders, status history, changes, and cancellations. NMLS further explains that the state regulator creates the bond form, which is then rendered in NMLS, and the surety supplies the licensee-specific information and electronic execution. Nationwide Licensing System+1

The NMLS ESB adoption table dated July 29, 2025 lists the Iowa Division of Banking’s Debt Management License and states that branch bonds are not accepted through that company-license ESB architecture. NMLS Resource Center+1

This establishes an electronic operational channel, but it does not answer:

• the exact current Iowa bond language;
• how the per-office statutory amount is represented when branch bonds are not accepted;
• whether the penal sum is multiplied in one bond;
• whether riders or schedules identify offices;
• the current surety cancellation transaction;
• public claim instructions; or
• whether consumers can see bond identifiers in NMLS Consumer Access.

4.2 Current Iowa-specific bond form

A one-page document found on a private surety website is dated September 10, 2016 and expressly says it is “for reference ONLY” because the bond form is rendered electronically in NMLS for official use. It includes language on a continuing obligation, direct action by the State or persons suffering loss, a $25,000 aggregate, and survival of obligations arising before termination. Axcess Surety+1

That document is useful only as a discovery lead. It is not:

• hosted by the Iowa Division of Banking;
• the live NMLS-rendered form;
• demonstrated current as of October 2026;
• proof of any actual provider’s bond; or
• sufficient authority for a current direct-action, tail, or continuous-term conclusion.

Accordingly, PASS-05 does not elevate its direct-action or continuous-obligation wording into a controlling claim.

4.3 Public complaint route

The Iowa Division of Banking’s official complaint page directs consumers to determine whether the Division regulates the business, including through NMLS Consumer Access, and then permits an online complaint. The page states that the licensee ordinarily receives 10–20 business days to research and respond. It also says the Division does not act as a judge to settle contract disputes, does not intervene in formal legal proceedings, and does not provide legal advice. Iowa Division of Banking+1

Thus, an IDOB complaint is:

• a regulator-investigation route;
• potential evidence for discipline or restitution;
• not itself a verified surety claim form;
• not a judgment;
• not proof of coverage;
• not an adjudication of bond liability; and
• not a substitute for satisfying any applicable notice or suit deadline.

Compiled Rule 20.10 confirms that a written consumer complaint is a complaint the superintendent may investigate. Iowa Legislature

4.4 Public availability of provider bond details

The reviewed public IDOB/NMLS routes establish a license-verification path, but no actual provider search was conducted and no public record was recovered showing:

• the provider’s surety;
• bond number;
• effective date;
• cancellation date;
• riders;
• covered offices;
• penal sum;
• prior paid claims; or
• remaining aggregate capacity.

Chapter 533A also makes most supervisory documents concerning licensees confidential, subject to specified enforcement, interagency, statistical, and complaint-summary exceptions. That confidentiality provision may limit public access to examination or supervisory bond information; it does not establish that every bond or bond identifier is confidential. Iowa Legislature

5. Consumer, superintendent, and court remedies

5.1 Superintendent remedies against a licensee

For a licensed provider, the superintendent may impose:

• revocation;
• suspension;
• probation;
• a civil penalty up to $5,000 per violation;
• citation and warning; and
• restitution. Iowa Legislature+1

For an unlicensed person, the superintendent may order compliance, impose a civil penalty up to $5,000 per violation, order restitution, and seek an injunction. Iowa Legislature

These are separate remedies:

• Restitution is remedial and may compensate affected persons according to an order.
• Civil penalties are public sanctions; Chapter 533A does not state that the penalty amount becomes consumer bond proceeds.
• Discipline protects the licensing system but does not quantify a consumer’s loss.
• Injunctions stop or prevent conduct but do not automatically establish a bond claim.

A restitution order might supply evidence of provider liability or loss, but the bond statute does not state that an agency restitution order is either necessary or conclusive against the surety.

5.2 Private action

The general bond paragraph does not provide a detailed private-action procedure. The current official rendered bond form and controlling Iowa bond law are needed to determine the exact direct-action route.

Chapter 533A does contain an express private cause of action for violations of the educational-loan debt-management section, §533A.8A. In that narrow branch, an affected debtor may recover actual damages, appropriate equitable relief, costs, and reasonable attorney fees; a non-governmental action under that section must be commenced within four years. Iowa Legislature

That four-year period is not established as:

• the limitation period for an ordinary debt-management bond claim;
• the time to notify the surety;
• the period for a non-educational Chapter 533A claim; or
• a universal Chapter 533A private-action deadline.

Likewise, the attorney-fee provision is special to the statutory §533A.8A action. No universal fee-shifting rule for bond litigation was established.

5.3 Judgment or agency order as a prerequisite

No provision reviewed in the official 2026 Chapter 533A text, compiled Chapter 20, or the targeted Chapter 636 provisions expressly says that a consumer must first obtain:

• a judgment against the provider;
• an IDOB restitution order;
• a criminal conviction;
• revocation of the provider’s license;
• proof that the provider is insolvent; or
• a denied demand to the provider

before making a bond claim.

That is an evidence gap, not a conclusion that none of those conditions applies. The live bond form, surety defenses, and governing procedural law remain necessary.

5.4 Decisions and formal interpretations

Targeted searches of official Iowa court and agency domains were performed for Chapter 533A bond actions, §533A.2(4), debtor standing, surety notice, claim deadlines, aggregate allocation, cancellation tails, successor security, and bond exhaustion.

No materially on-point Iowa appellate decision or formal public Iowa Division of Banking interpretation was located through those searches. The returned judicial materials concerned unrelated statutory bond regimes and were not imported into this analysis.

That is a bounded search result, not proof that no relevant case, trial-court order, administrative file, unpublished decision, or archived interpretation exists.

6. Security, claimant, remedy, and conditions matrix

Bounded recovery examples

These examples are comparison ledgers, not findings of actual liability. All figures are U.S. dollars and rounded to two decimals. Each assumes a valid applicable bond, a covered office, timely action, and no defenses unless stated.

S_IA-P5-E01 — One consumer, loss below available penal sum

Plain text

Proven covered uncompensated loss:          $7,500.00
Office bond penal sum:                     $25,000.00
Prior valid payments from same aggregate:       $0.00
Remaining arithmetic capacity:             $25,000.00

Upper-bound bond comparison:
min($7,500.00, $25,000.00) =                $7,500.00

Conditional result: $7,500 is the numerical upper bound under the stated assumptions.

It is not a payout guarantee. The claimant still must establish protected status, covered conduct, causation, applicable office, bond period, timeliness, and current capacity. The statute’s penal sum cannot increase the consumer’s compensable loss. Iowa Legislature

S_IA-P5-E02 — Money already returned is credited once

Plain text

Gross claimed causal loss:                 $12,000.00
Money already restored by provider:         -4,000.00
                                           ----------
Net uncompensated comparison loss:           $8,000.00

Assumed remaining bond capacity:            $25,000.00
Upper-bound comparison:
min($8,000.00, $25,000.00) =                 $8,000.00

The same $4,000 cannot be recovered again from the surety as part of the identical loss.

This example does not resolve whether Iowa applies collateral-source, subrogation, settlement-credit, or allocation rules differently in a particular action.

S_IA-P5-E03 — Multiple consumers exceed one office’s aggregate

Assume all three claims are valid, timely, covered by the same office bond, and uncompensated:

Plain text

Consumer A covered loss:                   $18,000.00
Consumer B covered loss:                    12,000.00
Consumer C covered loss:                     5,000.00
                                           ----------
Total covered losses:                      $35,000.00

Office aggregate penal sum:                $25,000.00
Aggregate shortfall:                       $10,000.00

The surety’s maximum collective exposure is $25,000, not $35,000. Iowa Legislature

No individual payout is calculated. Iowa’s reviewed provisions do not establish first-filed, first-judgment, pro-rata, superintendent-controlled, or another allocation method.

For comparison only, an equal-percentage pro-rata allocation would use:

$25,000$35,000=71.428571%\frac{$25{,}000}{$35{,}000}=71.428571%$35,000$25,000​=71.428571%But applying that percentage would invent an allocation rule. It is therefore not used as a legal payout result.

S_IA-P5-E04 — Cancellation cutoff

Assume:

Plain text

Day 0:  Surety gives compliant cancellation notice.
Day 30: Cancellation becomes effective.

Two separate alleged breaches:

Plain text

Breach 1: Day 20; covered loss =             $6,000.00
Breach 2: Day 40; covered loss =              6,000.00

Under §533A.2(4):

• Breach 1 occurred before effective cancellation and is not released merely by the later cancellation.
• Breach 2 occurred after effective cancellation and falls outside that surety’s statutory liability. Iowa Legislature

This does not establish when the Day-20 claim must be presented or sued upon. The claim deadline and current official tail terms remain unresolved.

S_IA-P5-E05 — Two offices do not automatically stack

Assume:

Plain text

Office A statutory penal amount:            $25,000.00
Office B statutory penal amount:             25,000.00
Consumer dealt only with Office A.
Covered uncompensated loss:                 $30,000.00

Comparison tied to Office A:

Plain text

min($30,000.00, $25,000.00) =               $25,000.00
Potential uncovered shortfall:                $5,000.00

Office B’s amount is not added merely because the same company operates both offices. The statute caps the surety’s liability to debtors doing business with the office for which the bond was filed. Iowa Legislature

Different facts could require analysis where multiple offices actually participated, but no stacking rule was established.

S_IA-P5-E06 — Prior payments and uncertain remaining capacity

Assume the same unchanged office bond and no replenishment, annual reset, or replacement:

Plain text

Penal sum:                                  $25,000.00
Earlier valid bond payments:                 -9,000.00
                                           ----------
Arithmetic remaining capacity:              $16,000.00

New otherwise covered loss:                 $20,000.00
Upper-bound comparison:
min($20,000.00, $16,000.00) =               $16,000.00

The $16,000 result is valid only under the explicit same-bond/no-reset assumptions.

The operative provisions reviewed do not establish whether:

• the earlier payment actually eroded the same aggregate;
• a successor bond began a new aggregate;
• the surety replenished capacity;
• the bond resets annually; or
• the claims span different office bonds.

Without the actual bond history and paid-claim record, remaining capacity cannot be verified.

S_IA-P5-E07 — Restitution and bond recovery are not additive for the same loss

Assume:

Plain text

Established consumer loss:                 $20,000.00
Provider restitution actually paid:         -8,000.00
                                           ----------
Remaining uncompensated loss:               $12,000.00

Assumed remaining bond capacity:            $25,000.00
Upper-bound bond comparison:                $12,000.00

The consumer cannot use the same $8,000 loss twice to produce a $28,000 recovery from a $20,000 loss.

This does not determine:

• whether the restitution order binds the surety;
• whether the surety receives a credit;
• whether the surety has subrogation rights;
• the order of collection; or
• whether another category of legally recoverable damage exists.

S_IA-P5-E08 — Statutory per-office requirement versus NMLS filing architecture

Assume three covered offices:

Plain text

Office count:                                        3
Statutory base per office:                  × $25,000.00
                                           -------------
Total required statutory penal amount:        $75,000.00

This arithmetic follows the statute’s $25,000-for-each-office language.

It does not determine whether NMLS requires:

Plain text

One $75,000 company ESB,
Three office schedules under one ESB,
One $25,000 ESB plus office riders,
or another regulator-approved structure.

NMLS’s published table says branch bonds are not accepted, while Iowa law retains a per-office base. The current Iowa-specific checklist and rendered form are necessary to reconcile those filing mechanics. Iowa Legislature+1

Source register — S_IA-P5-S001+

All fresh accesses occurred October 25, 2026 Pacific / October 26, 2026 UTC. No source below is assigned multiple IDs merely because several clauses were used.

Claim register — S_IA-P5-C001+

Complete PASS-05 component coverage and gaps

Researcher self-check

Actually read or re-read in PASS-05

The following public primary or official operational material was freshly inspected on October 25, 2026 Pacific:

• Complete operative bond paragraph in Iowa Code §533A.2(4).
• Necessary Chapter 533A definitions, exemptions, discipline, examination/confidentiality, educational-loan private remedy, injunction, civil-penalty, and restitution clauses.
• Compiled Rules 20.3(5), 20.6, 20.9(7)(d), 20.10, and 20.11.
• Iowa Code Chapter 636 provisions on authorized corporate sureties, approval certificates, and service where suit otherwise lies.
• Iowa Code §515B.1’s surety-bond exclusion.
• IDOB’s complaint and license-verification routes.
• NMLS’s generic ESB management and bond-creation instructions.
• The NMLS ESB adoption table’s Iowa row and no-branch-bond heading, including visual PDF inspection.
• The privately hosted 2016 Iowa reference form, including visual PDF inspection, solely as a noncontrolling discovery source.
• Targeted official-domain searches for Iowa decisions and formal agency interpretations concerning Chapter 533A bond recovery.

Reused but not regenerated

The following reviewed material was preserved:

• P1’s $25,000-per-office bond finding and source limits.
• P1’s classifications, fees, examples, quantities, and comparisons.
• P2’s operative-rule and completion correction.
• P3’s date and renewal correction.
• All existing currentness, provider, contract, NMLS-checklist, proposal, federal, local, tribal, and parent-level holds.

No P1 fee example or quantity was recalculated.

Not treated as reviewed

PASS-04 is saved but unreviewed. No new P4 funds, trust, money-transmission, or return conclusion is adopted here as reviewed. References to principal, refunds, or double recovery are limited to what is necessary to distinguish bond security from other recovery sources.

Not read or not established

This pass did not establish:

• A current official Iowa rendered debt-management bond form.
• A complete current Iowa NMLS company or branch checklist.
• Current NMLS fees or every system instruction.
• Any actual provider, office, license, bond, surety, producer, bond number, rider, cancellation, or claim.
• Any surety’s current certificate of authority.
• Remaining bond capacity or prior claim payments.
• A consumer bond-claim form or official claim instructions.
• A judgment, agency-order, exhaustion, or notice prerequisite.
• A general Chapter 533A bond-claim limitation period.
• Multiple-claim priority, pro-rata allocation, replenishment, annual reset, subrogation, or successor-bond overlap.
• Surety liquidation, reinsurance, collateral, or bankruptcy priority.
• The original 2018 Chapter 20 adoption order.
• Complete rule history, post-October-14 rule changes, or ARC 0368D’s final disposition.
• A complete post-compilation legislative audit.
• A materially on-point controlling Iowa appellate decision or formal public IDOB interpretation.
• Full general civil, contract, UTPA, tort, fee-shifting, remedies, or limitations analysis.
• Any bond filing, application, provider contact, regulator contact, legal opinion request, account access, private record, or claim submission.

No files were written, no site was changed, and no publication action occurred.

This is a focused same-coordinator component, not independent review, and it does not establish provider authorization, bond validity, claim coverage, claim timeliness, remaining surety capacity, Iowa launch approval, publication readiness, component acceptance, state acceptance, parent acceptance, or A066 acceptance.

END S_IA PASS-05