S_ID PASS-02 — bounded corrections and qualifications to P1
Targeted PASS-02 access date: October 25, 2026, Pacific time.
Effect of this pass: P1 response 02b1cb10-7227-4f6a-9337-b56d3592d5ae, including its raw tables, 35 original claims, 36 coverage rows, seven examples, formulas, and numerical results, remains immutable. Only the cells and inline references identified below are replaced or qualified. No full Idaho report, fee analysis, federal analysis, or worked-example calculation was rerun.
1. Stable reference aliases
1.1 Immutable P1 source identities
No replacement source IDs are created for these documents.
1.2 Exact inline-reference replacements
| P1 location |
Incorrect P1 inline reference |
Replacement |
| §4.2, TSR debt-relief definition/coverage paragraph |
[C023; S025 §310.2(o); S027] |
[C023; S026 §310.2(o); S028 §310.6(b)(5)–(6)] |
| §4.2, settlement/performance-trigger paragraph |
[C024; S026 §310.4(a)(5)(i)(A)–(C)] or equivalent reference to S026 for §310.4 |
[C024; S027 §310.4(a)(5)(i)(A)–(C)] |
| §4.2, inbound-advertisement exemption paragraph |
[C023; S027 §310.6(b)(5)–(6)] |
[C023; S028 §310.6(b)(5)–(6)] |
| §4.3, CROA definition/exclusions paragraph |
[C027; S028 §1679a] |
[C027; S029 §1679a(1)–(3)] |
| §4.3, federal credit-repair advance-payment paragraph |
[C021, C027; S026 §310.4(a)(2); S029 §1679b(b)] |
[C021, C027; S027 §310.4(a)(2); S031 §1679b(b)] |
The final P1 claim-table rows C023–C027 already contain the correct source aliases supplied in the claim packet. Those final claim-table rows are therefore not replaced.
2. Credit-repair classification qualification
2.1 Replacement for P1 §1.2
Replace the classification paragraph in §1.2 with:
Idaho Code § 26-2223(8) supplies the relevant credit-repair activity branch, but it must be read together with the definition in § 26-2222(5). Under the accessible 2025 reproduction, a “credit repair organization” does not include:
- A consumer reporting agency, as defined in 15 U.S.C. § 1681a(f), that provides consumer reports based on information furnished by creditors, or any affiliate or subsidiary of such consumer reporting agency as defined by rule promulgated by the director.
- A person having an ongoing contractual arrangement with a consumer reporting agency described in § 26-2222(5)(a) to obtain consumer reports from a consumer reporting agency for either:Resale of the report, or information contained in or derived from it, to a consumer; orMonitoring information in the report on behalf of a consumer.
- A person, to the extent the person advertises, markets, provides, or facilitates consumer access to products or services offered or provided by an entity described in § 26-2222(5)(a) or a person described in § 26-2222(5)(b).
These are exclusions from the defined term “credit repair organization,” not exemptions under § 26-2239. Broadly described credit-improvement activity does not override a satisfied definitional exclusion. Conversely, a provider does not establish an exclusion merely through its label, accreditation, nonprofit description, affiliate claim, or assertion that it offers monitoring. Each element and cross-reference must be satisfied on the actual facts. Debt-settlement and debt-counseling classifications remain separately analyzed.
The complete exclusion language appears in § 26-2222(5)(a)–(c). The accessed page identifies itself as the 2025 Idaho Code, carries a nonofficial-citation warning, and warns that Idaho may have more current or accurate information. It is therefore not converted into verified official 2026 text. Justia Law
2.2 Replacement C004 claim cell
| Field |
Replacement |
| Claim ID |
C004 — original ID retained |
| Precise assertion |
Credit repair is separately classified and may overlap with debt settlement, but the defined term “credit repair organization” excludes the specific persons and activities described in § 26-2222(5)(a)–(c): the identified consumer-reporting-agency branch and described affiliates/subsidiaries; persons with the specified ongoing contractual CRA arrangement for resale or monitoring; and persons, to the stated extent, advertising, marketing, providing, or facilitating consumer access to the products or services of the persons described in paragraphs (a) or (b). These definitional exclusions are distinct from § 26-2239 exemptions. A label, accreditation, or nonprofit description alone establishes neither inclusion nor exclusion. |
| Sources and pinpoints |
S002 § 26-2222(5)(a)–(c); S003 § 26-2223(8). S020 p. 2 remains only the P1 researcher-accessed support for the accreditation-not-license statement; the later coordinator fetch failure is preserved and no fresh P2 verification of S020 is claimed. |
| Conditions / limits |
The exclusion applies only when all applicable textual elements are met; subsection (5)(c) is expressly limited “to the extent” of the specified activity. No actual provider was tested. S002 is a secondary 2025 reproduction; official current-text and amendment comparison remain held under C035. |
| Confidence |
High as to the reproduced text and required qualification; current official-code status remains held. |
2.3 Replacement model-table cell
Replace the P1 “Standalone credit repair” access cell with:
| Model |
Corrected Idaho classification/access wording |
| Standalone credit repair |
A person must first fall within the combined § 26-2222(5) definition and § 26-2223(8) activity branch. A person satisfying one of § 26-2222(5)(a)–(c)’s exact definitional exclusions is not a “credit repair organization” for the excluded activity, subject to the text’s conditions and subsection (5)(c)’s “to the extent” limitation. If the person is within the definition and activity branch, licensure is required unless a separate, exact statutory exemption applies. No inclusion, exclusion, exemption, or license status follows merely from a marketing label, accreditation, nonprofit claim, CRA relationship, or monitoring description. |
2.4 Replacement coverage cell
| Component |
Replacement status |
Claims |
Qualification |
| Credit-repair overlap and classification |
Partial / qualified |
C004; P2-C002; P2-C003 |
The activity branch and § 26-2222(5)(a)–(c) exclusions are now expressly reconciled. Actual-provider facts and official-current-text verification remain necessary. |
3. Narrow administrative qualifications
3.1 Replacement §5 application-content/procedure cell
Replace the affected P1 application-content summary with:
Section 26-2224(1)(a)–(l), in the accessible 2025 reproduction, specifies application contents. Information required at application must be updated as necessary to remain current, except advertisements and solicitations. Under subsection (2), an incomplete application becomes withdrawn and void if the applicant fails to provide the necessary completion information within 60 days after receipt of a written deficiency notice. For this clock, the statute defines receipt by the identified event: placement in regular U.S. mail using the application address, emailing the application email address, or posting to the prescribed electronic licensing system. The provision does not require proof that the applicant physically opened or actually read the notice. No calendar calculation is made here. Justia Law
3.2 Replacement C028 conditions cell
| Field |
Replacement |
| Claim ID |
C028 — original ID retained |
| Precise assertion |
Idaho applications use the director-prescribed electronic licensing system; IDOF routes applicants operationally to NMLS. Under the accessible § 26-2224 reproduction, required application information must be kept current except advertisements and solicitations. An incomplete-application deficiency notice is statutorily deemed received upon one of the events specified in § 26-2224(2)(a)–(c), and the 60-day cure period runs from that deemed receipt. |
| Sources and pinpoints |
S004 § 26-2224(1), especially (1)(f), (1)(l), and (2)(a)–(c); S016 for the operational NMLS route. |
| Conditions / limits |
“Receipt” is the statutory deemed-receipt event, not an assertion of actual physical or subjective receipt. No exact current NMLS company-license checklist was recovered; C033 remains open. S004 is a secondary 2025 reproduction and remains subject to C035. |
| Confidence |
High for the reproduced statutory wording and the bounded qualification; exact current checklist and official-current-text verification remain held. |
3.3 Replacement C030 cell
| Field |
Replacement |
| Claim ID |
C030 — original ID retained |
| Precise assertion |
License renewal is due electronically by December 31 with the $100 nonrefundable renewal fee. Failure to comply causes automatic expiration as of that date. The director may, rather than must, reinstate an expired license during the immediately following 60 days if the director finds that the applicant meets the chapter’s licensing requirements and the applicant submits a complete renewal application, the renewal fee unless previously paid, and the $50 reinstatement fee. |
| Sources and pinpoints |
S010 § 26-2231(1)–(3). |
| Conditions / limits |
Reinstatement is discretionary and conditional, not an automatic right merely because the filing occurs within 60 days. No calendar rollover, filing-date scenario, or provider-specific reinstatement determination is made. S010 is a secondary 2025 reproduction subject to C035. |
| Confidence |
High for the reproduced text; official-current-text comparison remains held. |
The reproduced section uses “may reinstate,” conditions reinstatement on a licensing finding and the listed submissions, and separately makes expiration automatic for failure to renew by December 31. Justia Law
4. Wall source status and pinpoint replacements
4.1 Replacement S014 source-status cell
| Field |
Replacement |
| Source ID |
S_ID-P1-S014 — retained; no duplicate document ID |
| Document |
Wall & Associates, Inc. v. State of Idaho, Department of Finance, Consumer Finance Bureau, Idaho Supreme Court, Docket No. 51310, opinion filed August 21, 2025 |
| Actually used URL |
https://cases.justia.com/idaho/supreme-court-civil/2025-51310.pdf?ts=1755796372 |
| Official route attempted |
https://isc.idaho.gov/opinions/51310.pdf |
| Status |
The official route returned 404 during P2 and was not read. The cited opinion text was read from the 20-page Justia-hosted PDF mirror. Selected passages—not every page and not a citator—were reviewed. The mirror provenance from P1 is preserved. (Invalid URL) |
| Use limits |
The opinion supports its holdings and reasoning at the printed-page pinpoints below. P2 does not claim full subsequent-treatment validation, current company authorization, or review of a settlement instrument. Any agency press release concerning a later settlement is not itself the settlement instrument or proof of present license status. |
4.2 Replacement C008 source/pinpoint cell
| Field |
Replacement |
| Claim ID |
C008 — original ID retained |
| Assertion |
Tax-debt settlement falls within the debt-counselor classification addressed in Wall; enrolled-agent status does not displace Idaho licensing through conflict preemption. |
| Correct source/pinpoint |
S014 printed p. 11 for the conclusion that taxes are included as debt/indebtedness and that Wall falls within the debt-counselor definition; printed pp. 12–13 for the enrolled-agent/conflict-preemption reasoning. |
| Limit |
Selected passages only; no complete 20-page validation or citator review. |
Printed page 11 states the tax-debt conclusion, while printed pages 12–13 explain that the Idaho license does not prevent enrolled agents from practicing before the IRS and that compliance with both regimes is possible. Justia Law+2
4.3 Replacement C009 and §1.4 pinpoint cells
| Field |
Replacement |
| Claim ID |
C009 — original ID retained |
| Assertion |
Secured debt may remain within ICAA licensing coverage, but § 26-2229(3)(b)’s 20% unsecured-debt ceiling is inapplicable to services involving secured debt; P1 did not establish a substitute fee amount. |
| Correct sources/pinpoints |
S008 § 26-2229(3)(b); S014 printed pp. 10–11. |
| Conditions / limits |
The opinion rejects using the word “unsecured” in the fee subsection to limit the entire Act. It does not establish a replacement secured-debt fee ceiling. No broader secured-debt fee conclusion or subsequent-treatment claim is added. |
For P1 §1.4, replace the existing Wall citation range with:
[C009; S008 §26-2229(3)(b); S014 printed pp. 10–11]
Printed pages 10–11 set out the argument and hold that the particular unsecured-debt fee provision does not apply to secured-debt services while the Act is not thereby limited to unsecured debt generally. Justia Law+1
4.4 Replacement C034 source/pinpoint cell
| Field |
Replacement |
| Claim ID |
C034 — original ID retained |
| Assertion |
The restoration of fees, restitution, or disgorgement discussed in Wall was an enforcement remedy based on the record and the director’s statutory remedial authority; it is not an alternative lawful provider-fee schedule. |
| Correct source/pinpoint |
S014 printed pp. 15–18, especially the discussion of § 26-2244(2)(b), the rejection of blanket restoration, the client-specific record analysis, and affirmance of the restoration order. |
| Conditions / limits |
The holding is tied to the administrative record and abuse-of-discretion review. It does not establish that every fee violation requires identical restoration or that the restored amounts constitute allowable compensation. No full remedial or subsequent-treatment analysis is claimed. |
The opinion’s sanctions section begins on printed page 15, addresses discretionary restoration and client-specific fee analysis on pages 16–17, and affirms restoration on page 18. Justia Law+3
5. Minimal completion qualifier
5.1 Replacement for the P1 introductory status sentence
Replace “Substantively completed for provider classification, public market access, consumer-fee ceilings, and applicable fee timing” with:
Component status: P1 supplies bounded, conditional findings for the provider-classification, public-access-route, consumer-fee-ceiling, and applicable-timing questions addressed from the sources actually read. It does not establish complete current provider coverage or final Idaho acceptance. The exact official current section text and 2026 amendment/session-law comparison remain held under C035, and the exact current Idaho NMLS application/renewal checklist remains held under C033. Provider-specific authorization also requires an actual registry result.
5.2 Global qualifier for P1 coverage rows
Apply this qualifier to every P1 coverage cell marked “Answered”:
“Answered” means answered for the bounded issue and evidentiary record stated in P1. It does not override C033, C035, source-version limits, provider-specific factual conditions, definitional exclusions, exact statutory exemptions, or the need for an actual license-search result. It is not state acceptance, A066 acceptance, or publication readiness.
No original coverage status is silently converted to broader completion.
6. Minimal document/source-usage and version table
| P1 source |
P2 use status |
Version/provenance and limitation |
| S001 — IDOF Statutes and Rules index |
Freshly opened in P2 |
Official agency index. It states agency guidance lacks force and effect of law and lists ICAA section links. It is not the operative section text and does not cure C035. Department of Finance+1 |
| S002 — § 26-2222 reproduction |
Freshly read in P2 |
Complete relevant § 26-2222(5)(a)–(c) text read from the 2025 Justia reproduction. Secondary, expressly nonofficial/currentness-disclaimed. Justia Law |
| S004 — § 26-2224 reproduction |
Freshly read in P2 |
Complete subsections (1)(a)–(l) and (2)(a)–(c) read from the 2025 Justia reproduction. Secondary; official-current-text hold preserved. Justia Law |
| S010 — § 26-2231 reproduction |
Freshly read in P2 |
Complete subsections (1)–(3) read from the 2025 Justia reproduction. Secondary; reinstatement is discretionary and conditional. Justia Law |
| S014 — Wall opinion |
Selected passages freshly read and visually inspected in P2 |
Justia-hosted mirror used. Printed pp. 10–13 and 15–18 inspected. Official PDF route returned 404. No full opinion audit or citator. (Invalid URL) |
| S020 — September 2026 alert |
Original P1 researcher access retained; not freshly verified in P2 |
Later coordinator fetch failure remains part of the provenance. It is not used to prove operative statutory text. |
| S025 — IDOF license-search page |
Freshly opened in P2 |
Search landing page only. No provider name or NMLS identifier searched. Department of Finance |
| S026–S029 and S031 — federal authorities |
Reused, not freshly fetched in P2 |
Stable aliases corrected as shown above. Prior read status and exact conditional federal coverage limitations remain unchanged. |
| Official Idaho section text / 2026 amendment comparison |
Not recovered |
P1 failed official routes and C035 remain controlling. No secondary reproduction is promoted to official current law. |
| Exact Idaho NMLS checklist |
Not recovered |
C033 remains open. No checklist contents, filing calendar, or provider authorization were inferred. |
7. Corrective PASS-02 claims
| Corrective claim ID |
Corrective assertion |
Supporting record |
Conditions and limits |
| S_ID-P2-C001 |
S025 is the IDOF license-search page; S026, S027, and S028 are respectively 16 C.F.R. §§ 310.2, 310.4, and 310.6; S029 and S031 are respectively 15 U.S.C. §§ 1679a and 1679b. The listed P1 inline references are corrected without changing document identities. |
Immutable P1 source register and §1 replacement table above; S025 landing page freshly opened. Department of Finance |
Clerical/source-attribution correction only; no federal merits rerun. |
| S_ID-P2-C002 |
The § 26-2222(5) definition contains the complete exclusions stated in subsections (a)–(c), including the cross-referenced CRA, contractual-resale/monitoring, and access-facilitation branches. |
S002 § 26-2222(5)(a)–(c). Justia Law |
Secondary 2025 text; exact official-current comparison held. No extension beyond the text. |
| S_ID-P2-C003 |
The § 26-2222(5)(a)–(c) exclusions are definitional exclusions, distinct from § 26-2239 exemptions. A provider qualifies for neither inclusion nor exclusion merely by label, accreditation, nonprofit description, or an asserted CRA relationship. |
S002 § 26-2222(5); P1 S003 and S013 retained. Justia Law |
Actual facts and every textual element are required; subsection (5)(c) applies only “to the extent” specified. |
| S_ID-P2-C004 |
Under the accessible § 26-2224 text, application information other than advertisements and solicitations must be updated; the 60-day incomplete-application clock runs from the specified deemed-receipt event in subsection (2)(a)–(c). |
S004 § 26-2224(1)(l), (2)(a)–(c). Justia Law |
No actual-receipt requirement is added; no calendar calculation or checklist completion claim. |
| S_ID-P2-C005 |
Section 26-2231 allows, but does not compel, the director to reinstate within 60 days after expiration when the licensing finding and listed submissions are satisfied. |
S010 § 26-2231(1)–(3). Justia Law |
No automatic reinstatement right or provider-specific determination. |
| S_ID-P2-C006 |
The precise Wall pinpoints are printed pp. 10–11 for the secured/unsecured fee issue, pp. 12–13 for enrolled-agent conflict preemption, and pp. 15–18 for restoration and sanctions. The official PDF route failed; the Justia mirror supplied the selected text. |
S014 and the printed-page screenshots. (Invalid URL) |
Selected-passages review only; no citator or broad subsequent-treatment conclusion. |
| S_ID-P2-C007 |
P1 remains conditional rather than complete provider-access acceptance because C033 and C035 remain unresolved and no named-provider lookup was performed. |
P1 C031, C033, C035; S025 landing-page status. Department of Finance |
No state, A066, provider, or publication acceptance. |
All 35 original P1 claims remain stable. The P2 corrective claims identify source mapping, qualifications, and unresolved evidentiary limits; they do not replace the P1 substantive fee formulas or examples.
8. Focused coverage patch
| P1 component |
Patched status |
Corrective claims |
Remaining hold / next investigation |
| Inline federal source references |
Corrected |
P2-C001 |
No federal merits rerun required; retain conditional coverage facts from P1. |
| Credit-repair definition |
Partial / qualified |
P2-C002, P2-C003 |
Compare against official current § 26-2222 text and any 2026 amendments when accessible; apply exclusions to actual provider facts. |
| Credit-repair exemptions |
Qualified boundary established |
P2-C003 |
Keep § 26-2222(5) exclusions distinct from § 26-2239 exemptions and federal CROA exclusions. |
| Application-information updating |
Answered from accessible 2025 reproduction, currentness held |
P2-C004 |
Official-current-text comparison remains C035. |
| Incomplete-application 60-day clock |
Answered from accessible 2025 reproduction, currentness held |
P2-C004 |
No actual notice event or calendar computation; exact NMLS checklist remains C033. |
| Renewal expiration |
Answered from accessible 2025 reproduction, currentness held |
P2-C005 |
Exact official-current-text comparison remains C035. |
| Reinstatement |
Answered / qualified as discretionary |
P2-C005 |
Actual director finding and complete submission package required; no provider-specific result. |
| Wall secured-debt pinpoint |
Corrected |
P2-C006 |
Printed pp. 10–11; substitute secured-debt fee amount remains unresolved. |
| Wall enrolled-agent pinpoint |
Corrected |
P2-C006 |
Printed pp. 12–13; no broader federal-practice or sector analysis added. |
| Wall restoration pinpoint |
Corrected |
P2-C006 |
Printed pp. 15–18; full remedies pass remains open. |
| Official Wall PDF provenance |
Partial |
P2-C006 |
Official route returned 404; mirror used; no citator or settlement-instrument review. |
| Exact Idaho NMLS checklist |
Unresolved |
P2-C007; original C033 |
Obtain the current Idaho company-license new-application and renewal checklists through an accessible official/NMLS route. |
| Official current statutory text and amendment comparison |
Unresolved |
P2-C002–C005, P2-C007; original C035 |
Recover official section text and compare relevant 2026 session laws. |
| Named-provider authorization |
Unresolved / not attempted |
P2-C007; original C031 |
Search the exact legal name or NMLS identifier and preserve the actual result. |
| P1 fees, refund formula, timing conclusions, numerical examples |
Unchanged |
Original P1 claims |
Coordinator reports 28 quantities and five comparisons matched; P2 performed no whole-math or example rerun and found no correction requiring one. |
| Overall provider-access/fees component |
Partial / conditional, not accepted complete |
P2-C007 |
C033, C035, provider-specific facts, and all expressly deferred state categories remain open. |
9. Self-check
Freshly read or checked in PASS-02
- The relevant complete exclusion language in the 2025 reproduction of § 26-2222(5)(a)–(c).
- The complete relevant application/update/deemed-receipt language in the 2025 reproduction of § 26-2224(1)(a)–(l) and (2)(a)–(c).
- The complete renewal and reinstatement language in the 2025 reproduction of § 26-2231(1)–(3).
- The IDOF statute index and the IDOF license-search landing page.
- Selected Wall passages on printed pages 10–13 and 15–18, including visual PDF inspection.
- The official Wall PDF route, which returned 404.
Reused rather than newly read
- P1’s remaining Idaho statutes and fee provisions.
- P1/prior coordinator review of eCFR §§ 310.2, 310.4, and 310.6.
- P1’s current-through-Public-Law-119-120 OLRC readings of §§ 1679a and 1679b.
- The September 2026 IDOF alert’s original researcher access; no fresh P2 verification is claimed.
- P1’s complete fee structures, federal conditions, formulas, refund analysis, and seven examples.
Not recovered or not performed
- Official current 2026 text for the affected Idaho sections.
- A complete 2026 Idaho session-law amendment comparison.
- The exact current Idaho NMLS application or renewal checklist.
- Any named-provider registry result.
- The official Idaho-hosted Wall PDF.
- A full reading or citator treatment of all 20 Wall pages.
- Any settlement instrument, current-company approval, private contract, borrower data, regulator contact, filing, application, publication, or whole-state review.
This is the same-coordinator bounded correction described by the request, not an independent review. P1 remains preserved except for the expressly identified replacement references, qualification cells, source-status limits, and case pinpoints. No Idaho state acceptance, A066 acceptance, provider authorization, or publication readiness is claimed.
END S_ID PASS-02.