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

S_ID PASS-01 — Idaho provider market access and consumer fees

Research/access date: October 24, 2026, Pacific time. Component status: Substantively completed for provider classification, public market access, consumer-fee ceilings, and applicable fee timing. This does not accept Idaho overall, does not accept A066, and does not close later agreement, funds-handling, bond-remedies, collection, litigation, limitations, exemptions, secured-debt, sector, local, tribal, contract, or comprehensive case-law passes.

Currentness qualification: The Idaho Department of Finance’s current statute index identifies Title 26, chapter 22 and the operative sections discussed below. The Legislature’s direct section pages returned internal/robots-access errors through the available public route, so the statutory language was read from the 2025 codification reproduced by Justia, then checked against the Department’s 2026 materials and the Idaho Supreme Court’s August 21, 2025 decision. A final search for 2026 session legislation touching these sections could not be completed through the blocked Legislature route. Core conclusions are high-confidence; exact official-code-page currentness remains a documented hold rather than being overstated. Department of Finance+1

Controlling result

Idaho has an activity-based licensing regime, not a special voluntary “debt-settlement registration” and not a blanket prohibition on all debt relief. A person engaging or offering to engage in Idaho in any of three debtor-side activities—receiving debtor funds for creditors, providing debt-management counseling or services, or contracting to adjust, compromise, or discharge indebtedness—must obtain an Idaho Department of Finance license unless an exact statutory exemption applies. The provider’s marketing label does not decide coverage. Justia Law+1

The principal consumer-fee pathways are:

A. Substantive findings

1. How Idaho defines and classifies the relevant conduct

1.1 The statutory classification is functional

Idaho Code § 26-2223(7) contains three independent debtor-side branches:

1. Receiving money from debtors for application, payment, or proration to creditors.
2. Providing counseling or other services to debtors in managing their debts.
3. Contracting with a debtor to adjust, compromise, or discharge an account, note, or other indebtedness.

A provider can therefore be covered without ever taking custody of settlement funds. Negotiating a principal reduction falls naturally within the adjustment/compromise branch; a DMP that seeks interest, fee, or payment concessions may fall within the management-services branch; and a DMP that also receives and distributes debtor money falls within the first branch. [C001–C003; S_ID-P1-S003 §26-2223(7); S_ID-P1-S014 pp. 3–5] Justia Law+1

The custody distinction primarily determines which fee rule applies:

• Custodial payment/proration: § 26-2229(3)(a), 15% of each amount received at one time.
• Noncustodial unsecured-debt management: § 26-2229(3)(b), 20% of principal unsecured debt at contracting.

Custody is not itself a prerequisite to licensing. [C002, C015–C017; S_ID-P1-S003; S_ID-P1-S008] Justia Law+1

1.2 Credit repair is a separate classification and may overlap

Section 26-2223(8) separately covers selling, providing, performing, advising on, or assisting with services intended to improve a consumer’s credit record, history, or rating. A company can therefore be both a debt counselor and credit-repair organization when its representations and actual services satisfy both branches. A generic “financial wellness,” “debt resolution,” or “credit advocacy” name does not avoid either classification. [C003–C004; S_ID-P1-S002 §26-2222(5); S_ID-P1-S003 §26-2223(8)] Justia Law+1

1.3 Tax-debt settlement is covered

In Wall & Associates, Inc. v. Idaho Department of Finance, the Idaho Supreme Court held that a tax-debt settlement business was a debt counselor under the plain statutory language. The court explained that Idaho regulates debtor-side intermediaries and rejected the argument that tax liabilities fall outside the Act merely because the government does not fit every use of the statute’s “creditor” definition. [C008; S_ID-P1-S014 pp. 3–10] Justia Law+1

Federal enrolled-agent status did not displace Idaho licensing. The court held that an enrolled agent could comply with both IRS rules and Idaho’s requirement to obtain a debt-counselor license. [C008; S_ID-P1-S014 pp. 11–13] Justia Law

1.4 Secured debt remains within potential licensing coverage, but the unsecured fee ceiling does not carry over

The Idaho Supreme Court rejected the proposition that § 26-2229(3)(b)’s reference to unsecured debt limits the entire ICAA. Instead, the unsecured qualifier limits that particular fee ceiling. Thus:

• A provider may still be a licensed debt counselor for secured-debt or tax-lien work.
• The 20% ceiling cannot simply be applied to secured debt.
• The absence of that ceiling does not itself establish a lawful unlimited-fee pathway.

[C009; S_ID-P1-S008 §26-2229(3)(b); S_ID-P1-S014 pp. 9–10] Justia Law+1

1.5 Consumer versus business purpose

Section 26-2223(7), unlike the credit-repair branch in subsection (8), does not use the word “consumer” or expressly limit covered indebtedness to personal, family, or household purposes. The Wall record also included representations about helping individuals or businesses, but the court did not separately adjudicate a pure business-only debt-management program. The best current reading is:

• Idaho’s debt-counselor text is broader than a consumer-purpose-only statute.
• A pure commercial-debt program should not be presumed outside the Act.
• A categorical conclusion on a provider serving only business entities remains held pending a controlling commercial-debt decision or official interpretation.

[C007; S_ID-P1-S003 §26-2223(7)–(8); S_ID-P1-S014 pp. 3–7] Justia Law+1

Federal TSR and CROA purpose limitations are separate questions; they do not narrow Idaho’s state definition.

1.6 Idaho nexus and remote providers

The statute covers engaging or offering to engage “in this state.” Its definition of an agent expressly reaches compensated persons who contact people in Idaho in connection with a licensee or required-to-be-licensed business. The Idaho Supreme Court applied the Act to an out-of-state provider serving Idaho clients. Accordingly, a remote provider does not avoid Idaho coverage merely because its offices, employees, or settlement operations are elsewhere. [C005; S_ID-P1-S002 §26-2222(1); S_ID-P1-S003 §26-2223(7); S_ID-P1-S014] Justia Law+2

The sources read do not resolve whether a passive website, with no Idaho solicitation, customer, contract, agent contact, or service, is by itself enough. That edge remains held. [C006]

2. Whether each model is prohibited, licensed, or exempt

2.1 Covered conduct is conditionally authorized through licensing

Section 26-2223 prohibits covered operation without compliance and a license. Section 26-2225 directs the Department’s director to issue a license when the statutory requirements and fees are satisfied and the applicant is not otherwise unqualified. Idaho therefore has a mandatory-license regime, not a categorical ban on licensed debt counseling or settlement. [C010; S_ID-P1-S003 §26-2223; S_ID-P1-S005 §26-2225] Justia Law+1

Operating without a required license is a felony under § 26-2238(2), subject to the statutory exemption provision. Administrative denial, suspension, revocation, civil penalties, restitution, and other remedies may also apply. [C011, C034; S_ID-P1-S007; S_ID-P1-S012; S_ID-P1-S014 pp. 14–17] Justia Law+3

2.2 Model-by-model access result

2.3 Exemptions are specific, not label-based

Section 26-2239 exempts:

• Idaho-licensed lawyers only to the extent they are retained by clients and the covered work is incidental to legal practice; the exemption expressly excludes an attorney operating a separate covered business.
• A regulated lender, subsidiary, affiliate, or agent only to the extent it collects for the lender or performs covered acts incidental to the regulated-lender business.
• Banks, trust companies, credit unions, insurance companies, and industrial loan companies authorized in Idaho.
• Government agencies or instrumentalities.
• Certain Idaho real-estate licensees acting within their licensed activity.
• Authorized escrow businesses acting within that business.
• Mortgage lenders acting in their regular mortgage business, but not a separate covered business.
• Court-appointed trustees, receivers, or conservators.
• The specified pre-delinquency telephone-company billing activity.
• A commonly owned or controlled affiliate collecting only for affiliates where debt collection is not its principal business.

[C012–C014; S_ID-P1-S013 §26-2239(1)–(10)] Justia Law+2

Consequences:

• Nonprofit status is not a general Idaho exemption.
• Accreditation is not a license.
• An attorney’s name, ownership interest, referral relationship, or limited involvement does not satisfy the incidental-practice exemption.
• Federal nonprofit or creditor exclusions under CROA do not create an Idaho exemption.
• Enrolled-agent status does not create an Idaho tax-settlement exemption.

The Department expressly warned in September 2026 that accreditation is not a license and directed consumers to NMLS Consumer Access. [C004, C011–C014; S_ID-P1-S014; S_ID-P1-S020] Department of Finance+1

2.4 Original creditor and self-creditor boundary

Idaho separately covers a person collecting its own account when the debt was acquired from another person while delinquent or in default—the debt-buyer branch in § 26-2223(6). Section 26-2239 contains no general “self-creditor” exemption. An original creditor restructuring its own directly originated debt may nevertheless fall outside some third-party collection language, but that does not automatically resolve whether a separate counseling, credit-repair, or debtor-representation business is covered. This boundary remains fact-specific and later collection-side work remains open. [C014; S_ID-P1-S003 §26-2223(2)–(7); S_ID-P1-S013] Justia Law+2

2.5 Administrative-rule status

The official Idaho administrative-rule cumulative index marks IDAPA 12.01.11, “Rules Pursuant to the Idaho Collection Agency Act,” as expired March 31, 2022. The archived chapter is historical evidence only and cannot be silently treated as a current operative rule. No replacement ICAA-specific rule chapter was verified in the official index reviewed. [C032; S_ID-P1-S022–S023] ProdDFMMainSA+1

3. Current fee structures, limits, refunds, and dated guidance

3.1 Controlling Idaho fee matrix

3.2 The 20% rule is not “20% of the monthly payment”

The operative text bases the noncustodial ceiling on the principal amount of unsecured debt at the time of contracting. An April 2025 Department consumer release instead says debt-settlement companies may charge 20% of the consumer’s “monthly payment.” That language does not match the statute. The same release describes the custodial 15% rule as a percentage of a “monthly payment,” although the statute instead uses each amount received “at any one time.” [C019; S_ID-P1-S008 §26-2229(3); S_ID-P1-S021 p. 1] Justia Law+1

The Department’s own legal page warns that agency policy statements and guidance do not have the force and effect of law. The statutory text therefore controls over the release’s simplified wording. Department of Finance

3.3 No indexing or adjusted-dollar schedule was found

Neither § 26-2229(3) nor the official operational materials reviewed establish:

• A CPI adjustment.
• An annually adjusted dollar amount.
• A separate setup-fee allowance.
• A monthly-maintenance allowance outside the controlling ceiling.
• A separate per-debt fee cap.
• A separate savings-percentage cap under Idaho law.
• A minimum consumer fee.

The operative limits are the static 15% and 20% percentages. No adjusted-dollar amount was calculated or invented. [C018; S_ID-P1-S008] Justia Law

A savings-based fee may be numerically compatible with Idaho’s 20% aggregate ceiling, but Idaho’s statute does not affirmatively approve every savings-based contract. When the federal TSR applies, a savings fee must use the same percentage across individualized debts and remains subject to Idaho’s lower aggregate result if Idaho is more restrictive. [C016, C025] Justia Law+1

3.4 Refund interpretation

The cancellation sentence is attached to the noncustodial § 26-2229(3)(b) model. It does not expressly create the same 50% refund for:

• A custodial § 26-2229(3)(a) program.
• A standalone credit-repair program.
• A secured-debt program outside the unsecured fee ceiling.

The formula is not 50% of all fees automatically. It is 50% of the collected fees associated with the amount of debt remaining unsettled at cancellation. A defensible example must therefore maintain the same debt balances and allocation method used for previous earnings. [C017] Justia Law

3.5 Provider charges versus other amounts

The consumer-fee ceilings regulate compensation for the provider’s covered service. They should not be confused with:

• Creditor settlement payments.
• Taxes or government filing charges.
• The provider’s $150 state application fee.
• The provider’s $100 annual renewal fee.
• A compliant independent dedicated-account provider’s charge.

However, labeling an affiliated or retained amount as a “technology,” “legal,” “account,” or “processing” fee does not automatically place it outside the provider ceiling. Section 26-2229(3)(a) expressly bars other charges for the custodial service; treatment of pass-through, affiliate, and third-party charges in other models requires the later agreement/funds pass. [C015–C018, C028–C030] Justia Law+3

4. When fees may be requested or received

4.1 Idaho’s state rules

For ordinary debt management or settlement, Idaho’s fee provisions primarily establish amount ceilings. The custodial provision refers to compensation for services performed, but the sections reviewed do not prescribe an Idaho settlement-by-settlement trigger equivalent to the federal TSR. The noncustodial provision likewise supplies a ceiling and cancellation refund without affirmatively authorizing advance collection. [C020; S_ID-P1-S008 §26-2229(3)] Justia Law

Accordingly:

• A state maximum is not an advance-fee safe harbor.
• A provider cannot argue that a fee was timely merely because it was below 15% or 20%.
• Other Idaho provisions requiring fair, open, honest conduct and prohibiting misleading fee representations continue to apply.
• Federal timing rules must be applied independently.

Idaho expressly prohibits a covered credit-repair organization from charging or receiving money or other consideration before the agreed service is fully performed. [C021–C022; S_ID-P1-S006; S_ID-P1-S009 §26-2229A(8)–(9)] Justia Law+1

4.2 Federal TSR timing—conditional common context

The TSR defines a debt-relief service as a represented program or service to renegotiate, settle, or alter debt terms involving one or more unsecured creditors or debt collectors. TSR coverage also requires the rule’s telemarketing nexus; it should not be assumed for every website, face-to-face transaction, business-purpose service, or nontelephone channel. [C023; S_ID-P1-S025 §310.2(o); S_ID-P1-S027] eCFR+1

Where the TSR applies, no debt-relief fee may be requested or received until:

1. The provider has renegotiated, settled, reduced, or otherwise altered at least one debt under a valid settlement agreement, DMP, or comparable agreement executed by the customer.
2. The customer has made at least one payment under that agreement.
3. For debts resolved individually, the charged fee uses one of the permitted allocation methods.

[C024; S_ID-P1-S026 §310.4(a)(5)(i)(A)–(C)] eCFR

The two federal individualized-debt allocation methods are:

• Proportional total-fee method: individual enrolled debt ÷ total enrolled debt × total contracted fee.
• Savings method: the same percentage of actual savings for every individualized debt.

A provider may not switch methods between debts merely to accelerate earnings or increase the fee. [C025] eCFR

A dedicated account does not make the provider’s fee earned. The TSR requires, among other things, an insured institution, customer ownership, an unaffiliated administrator, no referral compensation, and return of all funds other than lawfully earned fees within seven business days after withdrawal. [C026] eCFR

Inbound calls responding to debt-relief advertisements are excluded from the ordinary inbound-call exemption, so “the consumer called us” is not a universal TSR escape. [C023; S_ID-P1-S027 §310.6(b)(5)–(6)] eCFR

4.3 Federal credit-repair overlap

CROA applies only when its definition is met. It covers paid interstate services represented as improving an individual consumer’s credit record, history, or rating, or providing related advice or assistance. Its exclusions include qualifying § 501(c)(3) organizations and a creditor helping restructure debt owed to itself. These federal exclusions do not become Idaho exemptions. [C027; S_ID-P1-S028 §1679a] U.S. Code

For a covered credit-repair organization, CROA bars charging or receiving consideration before the agreed service is fully performed. The TSR has an additional credit-repair timing/results-documentation rule when its telemarketing coverage exists. [C021, C027; S_ID-P1-S026 §310.4(a)(2); S_ID-P1-S029 §1679b(b)] eCFR+1

The April 2025 Idaho release incorrectly attributes the debt-settlement “settled debt plus first payment” trigger to CROA. That precise trigger is found in the TSR’s debt-relief provision, not CROA’s credit-repair advance-payment provision. [C019, C024, C027] Department of Finance+2

5. Regulator, application route, lookup, and public market access

The issuing regulator is the Idaho Department of Finance, acting through the director under the Idaho Collection Agency Act. [C028; S_ID-P1-S001, S_ID-P1-S003–S005] Department of Finance+1

Verified operational path

The 2026 annual package operationally distinguishes activity categories including credit repair, debt/credit counseling, debt settlement, and delinquent-debt purchasing. Those reporting categories help identify the Department’s administration but do not replace the statutory definitions or create separate substantive exemptions. Department of Finance

No provider-specific authorization established

No company name or NMLS identifier was supplied or searched. This pass verifies the public route and legal availability of licensure, not that any unnamed or marketed provider is currently licensed. A website statement, accreditation badge, attorney relationship, nonprofit description, or NMLS application in progress is not proof of an active Idaho license.

6. Worked fee and boundary examples

The examples are in Section D below. They use one stated allocation method throughout each scenario, distinguish numerical compliance from legal timing, and do not assume a fee became earned merely because money moved.

7. Component boundary

This pass resolves the principal provider-access and consumer-fee questions but deliberately leaves the following for later passes except where needed above:

• Full contracts and disclosures.
• Trust/dedicated-account treatment under Idaho law.
• Complete bond, claims, and discontinuance obligations.
• Private and public remedies.
• Creditor-side collection licensing.
• Litigation conduct and unauthorized-practice issues.
• Limitations periods and debt revival.
• Detailed secured-debt, mortgage, student-loan, tax, medical, and other sector rules.
• Tribal and local jurisdiction.
• Full Idaho and federal case survey.
• Named-provider license status.

No acceptance of those categories is implied.

B. Source table

Idaho legal authorities

Operational, interpretive, and rule-status materials

Federal common-context authorities

C. Claim table

D. Worked examples

No Idaho rounding rule for these consumer-fee ceilings was located. These examples use exact arithmetic. Where a computation produced fractional cents, a provider should not round upward beyond a statutory ceiling without authority.

Example 1 — Custodial DMP remittance

Facts and assumptions

• Provider is licensed and receives one debtor remittance of $500.00.
• The money is received for payment or proration to creditors.
• No exemption applies.
• No separate government or independent third-party charge is included.

Operator

• Idaho maximum = 15% × amount received at that one time.

Calculation

• $500.00 × 0.15 = $75.00.

Result

• Maximum provider compensation for that remittance: $75.00.
• At least $425.00 remains for creditor payment if the fee is deducted from the receipt.
• A proposed $75 service fee plus a $25 setup fee would total $100 and fail both the $75 numerical ceiling and the “no other charges” clause.

This establishes only the Idaho amount ceiling. It does not independently establish that the fee was timely under any applicable federal rule. [C015, C020] Justia Law

Example 2 — Noncustodial unsecured program with proportional TSR allocation

Inputs

• Total principal unsecured debt at contracting: $20,000.00.
• Debt A: $12,000.00.
• Debt B: $8,000.00.
• Contracted total provider fee: 18% of enrolled principal.
• Provider does not receive, hold, or disburse debtor funds.
• TSR applies.
• Provider uses the proportional-total-fee method consistently.

Idaho aggregate ceiling

• $20,000 × 20% = $4,000 maximum.

Contracted fee

• $20,000 × 18% = $3,600.
• $3,600 is numerically below the Idaho ceiling.

Debt A allocation

• Debt A ratio = $12,000 ÷ $20,000 = 0.60.
• Allocated fee = 0.60 × $3,600 = $2,160.

The $2,160 may be requested or received only after Debt A has been altered under a qualifying agreement and the customer has made the required first payment under that agreement.

Debt B allocation

• Debt B ratio = $8,000 ÷ $20,000 = 0.40.
• Allocated fee = 0.40 × $3,600 = $1,440.

Debt B’s $1,440 is not earned merely because Debt A performed. Debt B needs its own qualifying trigger if debts are resolved individually.

Consistency check

• $2,160 + $1,440 = $3,600.
• The same enrolled balances and allocation method were used throughout.
• No previous fee was assumed earned solely because one consumer payment occurred.

[C016, C024–C025] Justia Law+2

Example 3 — Lower-debt case exceeding the Idaho ceiling

Inputs

• Noncustodial unsecured principal at contracting: $3,000.
• Proposed total provider fee: $750.

Calculation

• Idaho maximum = $3,000 × 20% = $600.
• Excess = $750 − $600 = $150.

Result

The proposed fee exceeds Idaho’s ceiling by $150. Later performance under the TSR cannot legalize the state-law excess; timing compliance and amount compliance are separate. [C016, C020, C024] Justia Law+1

Example 4 — Savings-based method across two debts

Inputs

• Debt A at enrollment: $10,000.
• Debt B at enrollment: $10,000.
• Total principal at contracting: $20,000.
• Fee: the same 30% of actual savings for every debt.
• TSR and Idaho both apply.
• Provider is noncustodial.

Idaho ceiling

• $20,000 × 20% = $4,000 aggregate maximum.

Debt A

• Settlement payment: $6,000.
• Savings: $10,000 − $6,000 = $4,000.
• Fee: 30% × $4,000 = $1,200, after Debt A’s qualifying trigger.

Debt B

• Settlement payment: $4,000.
• Savings: $10,000 − $4,000 = $6,000.
• Fee: 30% × $6,000 = $1,800, after Debt B’s qualifying trigger.

Result

• Total fee = $1,200 + $1,800 = $3,000.
• $3,000 is below Idaho’s $4,000 aggregate ceiling.
• The same 30% savings rate was used on both debts.

If the same-percentage calculation had produced $4,500, Idaho would limit the aggregate provider fee to $4,000 even though the federal allocation formula was applied correctly. [C016, C025] Justia Law+1

Example 5 — Cancellation and prior-fee reconciliation

5A. State-formula illustration

Inputs

• Original enrolled balances: Debt A $12,000; Debt B $8,000.
• Total previously collected fees: $2,000.
• Those fees were consistently allocated in the same 60%/40% proportion:Debt A association: $1,200.Debt B association: $800.
• Debt A was settled.
• Debt B remained unsettled when the debtor cancelled.

Refund calculation

• Refund = 50% × collected fees associated with unresolved Debt B.
• 50% × $800 = $400.

Important legal limitation

The $400 arithmetic does not prove that collecting the $800 associated with Debt B was timely or lawful. If the TSR applied and Debt B had not satisfied its individual trigger, taking that $800 earlier could violate federal timing even though the later Idaho refund computation is mathematically correct.

5B. TSR-compliant variant

• Debt A fee of $2,160 was collected only after Debt A’s qualifying trigger.
• Debt B fee collected: $0.
• Debt B remains unsettled at cancellation.

Under the stated allocation, fees collected and associated with unsettled Debt B equal $0, so 50% × $0 = $0 under this particular Idaho cancellation formula. Contractual refund rights, deceptive-practice remedies, dedicated-account return rules, and other claims remain separate.

[C017, C024–C026] Justia Law+2

Example 6 — Secured-debt hold

Inputs

• Provider negotiates a $15,000 debt secured by property.
• Provider does not handle debtor funds.
• No exact exemption applies.

Result

• Licensing may still be required.
• The § 26-2229(3)(b) calculation of 20% × $15,000 is not a valid Idaho fee-ceiling calculation because subsection (3)(b) is limited to unsecured debt.
• Exact lawful Idaho provider fee: HOLD—no amount established.
• No licensed or unlimited-fee scenario is invented.

[C009] Justia Law

Example 7 — Credit-repair startup fee

Inputs

• Covered credit-repair organization promises a defined service.
• It proposes to take a $99 startup fee before that service is fully performed.

Result

• Idaho § 26-2229A(8) prohibits the advance charge or receipt.
• If federal CROA also applies, § 1679b(b) independently reaches the same timing problem.
• No generic Idaho percentage ceiling is invented for the standalone credit-repair model.

[C021, C027] Justia Law+1

Pass coverage and gap table

E. Researcher self-check

Actually read and used

• Idaho Department of Finance’s current statute index and the listed ICAA section structure.
• The accessible 2025 text of §§ 26-2222, 26-2223, 26-2224, 26-2225, 26-2226, 26-2227, 26-2229, 26-2229A, 26-2231, 26-2232A, 26-2238, and 26-2239.
• Material portions of the Idaho Supreme Court’s Wall & Associates opinion, including classification, tax debt, secured-debt fee language, federal-preemption argument, and restitution.
• The official administrative-rule cumulative index and the archived ICAA rule chapter.
• IDOF’s current application/forms page, collection-agency page, 2026 annual report/bond package, April 2026 licensing release, September 2026 credit-repair alert, and the conflicting 2025 fee release.
• Current eCFR text for 16 C.F.R. §§ 310.2, 310.4, and 310.6.
• Current House U.S. Code text for 15 U.S.C. §§ 1679a and 1679b.
• PDF pages used for substantive findings were also visually inspected rather than relying only on extracted text.

Not read or not established

• The official Idaho Legislature’s actual section HTML, because the direct routes returned access/internal errors.
• A complete official 2026 session-law comparison for every relevant section.
• A usable, current Idaho-specific NMLS application or renewal checklist.
• Any named company’s NMLS or Idaho license record.
• Any private provider contracts, fee schedules, call scripts, account arrangements, or borrower records.
• The entire Idaho administrative-action inventory.
• A comprehensive Idaho case-law, local-law, tribal-law, secured-debt, sector, remedies, or collection-side investigation.
• Any model act or model-act comments as a substitute for enacted Idaho wording.

No inaccessible passage was represented as read. No search snippet, company chart, association summary, marketing statement, or archived rule was used as controlling current law. No provider application was filed, no regulator or company was contacted, and no local file or publication-ready legal opinion is claimed.

END S_ID PASS-01.