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

SettleADebt.com — Indiana Investigation

S_IN, PASS-01: Provider market access and consumer fees

Research baseline: October 22, 2026, America/Los_Angeles Actual public-source access and currentness check: October 24, 2026 Scope: Indiana provider classification, market access, consumer fees, and fee timing only. This is not the complete Indiana dossier or a legal opinion.

Bottom-line determination

Indiana has two materially different consumer-debt service lanes:

The marketing label—“credit counseling,” “debt relief,” “law firm,” “nonprofit,” or “debt resolution”—does not decide coverage. The actual promises, debt type, money flow, customer status, and performance model do. [C001–C013]

A. Substantive answers

1. Definitions and classification boundaries

1.1 Debt management, DMP, and custodial distribution services

IC 28-1-29-1 defines a “debt management company” as a person doing business as budget counseling, credit counseling, debt management, or debt pooling—or holding itself out in comparable terms—and having a written agreement with the debtor to disburse money or anything of value. It expressly includes a person that merely holds money or an instrument for transmission. A “plan” is a written repayment program containing a payment schedule. A “concession” is creditor assent to repayment terms more favorable than the original contract. [C001] Justia Law

That definition makes the written disbursement relationship a central boundary:

• A provider that takes the consumer’s monthly payment and distributes it among creditors is squarely within the DMP lane.
• Holding a check or other payment instrument solely for onward transmission can still qualify.
• Pure education or counseling, with no compensable settlement promise and no written disbursement agreement, is not automatically shown to be a DMP by this definition.
• A noncustodial settlement provider does not escape regulation merely because the consumer retains the money; custody is not an element of Indiana’s separate debt-settlement definition. [C001–C002]

1.2 Debt settlement and principal reduction

IC 24-5-15-2.5 defines “debt settlement services” to include performing, offering, or representing—directly or by implication—that the provider will renegotiate or settle unsecured debt, or alter its payment or other terms, including reducing the balance, interest rate, or fees. A compensated person providing those services, or advice or assistance concerning them, is generally a “credit services organization.” [C002] Justia Law+1

This reaches representations, not merely completed settlements. A provider cannot avoid classification by saying that it only “facilitates,” “coaches,” “coordinates,” or “provides technology” where its actual offer implies that it will obtain creditor concessions or settlements.

1.3 Principal reduction versus an incidental DMP concession

Principal reduction is not, by itself, a complete classifier. Indiana expressly allows a creditor participating in a licensed DMP to reduce the amount owed during the plan, with a required tax-warning disclosure. The DMP statute also expects providers to identify creditors likely to participate and grant concessions. But a DMP may not settle a debt, or lead the consumer to believe a payment is a settlement, unless the creditor contemporaneously certifies that the payment is in full settlement. [C008] Justia Law+1

The practical boundary is therefore:

• Repayment/distribution program: regular consumer payments are transmitted to creditors; creditors may grant interest, fee, payment, or incidental balance concessions.
• Settlement program: the offered service itself is renegotiation, settlement, or alteration of unsecured debt, particularly a promised principal reduction or lump-sum resolution.
• Mixed model: held. The DMP definition excludes a “person” providing debt-settlement services, while the CSO definition excludes a statutory DMP. No controlling public interpretation resolving every mixed-program configuration was located. A mixed provider should not assume that either a DFI license or Attorney General bond filing cures the other classification. [C009]

1.4 Consumer versus business-purpose debt

The DMP chapter defines “debt” as an obligation arising from personal, family, or household use, and “debtor” as an individual whose principal debts are not business-purpose transactions. The CSO chapter likewise defines the buyer as an individual and defines “extension of credit” around personal, family, or household debt or avoiding foreclosure on the buyer’s residence. [C003] Justia Law+2

Accordingly:

• Consumer credit cards, consumer personal loans, and similar household obligations can fall within these chapters.
• An LLC obligation, commercial line, inventory financing, or an individual’s principally business-purpose debt is not shown to fall within these consumer definitions.
• That does not establish an unregulated business-debt-settlement safe harbor. Attorney-practice, collection, commercial-contract, deceptive-practice, and other laws remain for later passes.

1.5 Indiana-resident and remote-provider nexus

The DMP statute is unusually explicit. A person operates in Indiana when the person or an employee/agent is located in Indiana, or when the person contracts with Indiana residents or solicits them by mail, personal delivery, telephone, radio, television, internet/electronic communications, or any other communication method. Remote internet and telephone providers are therefore expressly included. [C004] FindLaw

The CSO statute says that the bond or equivalent must be filed “before doing business in Indiana,” and the current contract provision requires an Indiana agent for service of process. It does not contain the DMP chapter’s detailed remote-solicitation list. Serving an Indiana consumer through an online or telephone program presents a strong Indiana nexus, but the outer limit for remote-only activity was not conclusively resolved in the public authorities read in this pass. [C013]

1.6 Original-creditor and self-creditor activity

The CSO definition applies to services concerning an extension of credit “by another person.” Textually, an original creditor modifying its own debt appears different from a third-party CSO. That is a limited textual inference, not a verified blanket exemption for creditor affiliates, lead generators, servicing arrangements, or nominally separate entities. [C030] Justia Law

2. Prohibited, licensed, conditionally permitted, and exempt models

2.1 Debt-management companies: licensure, not mere registration

No person may operate a debt-management company in Indiana without a DFI license. A knowing unlicensed operator’s agreements are void; the debtor owes no fees, and paid amounts may be recovered. Licenses renew annually and are not freely transferable. [C005] FindLaw

The current DFI licensing page identifies a Debt Management License as an NMLS application. DFI also says that its Consumer Credit Division regulates in-state and out-of-state entities that advertise and solicit Indiana consumers. [C026] Indiana Government+1

One additional market-access restriction is unusually broad: DFI may not issue a post-August 1981 DMP license to a person who is an employee, owner, or affiliate “in any way” of a collection agency or process-serving business, subject to the old grandfather clause. [C007] Justia Law

2.2 DMP exemptions

The DMP chapter does not apply to:

1. An Indiana-authorized attorney, or persons under that attorney’s supervision and control, only to the extent the debt-management services are incidental to the attorney’s law practice.
2. A statutory depository financial institution.
3. A third-party bill-paying service used solely for the customer’s convenience, where the customer retains full control over deposited money, unless DFI determines that the structure is an evasion. [C006] FindLaw

There is no blanket nonprofit exemption in the DMP chapter. Instead, a licensee is prohibited from representing itself as nonprofit unless it is genuinely organized and operating as one, and from claiming tax-exempt status without IRS certification and proper nonprofit operation. [C031] Justia Law

2.3 Debt settlement: conditional CSO access, not an ordinary DFI license

Before doing business in Indiana, a covered CSO must:

• Obtain a $25,000 surety bond from an Indiana-authorized surety, in favor of the state for persons damaged by violations; and
• File a copy with the Indiana Attorney General.

The Attorney General may waive the bond and accept an equivalent irrevocable letter of credit, which likewise must be filed before business begins. [C010] Justia Law

The Attorney General’s current operational page uses a “Register/Submit Here” button and restates the bond/filing process. The statute, however, does not establish an ordinary DFI license or say that the filing is an affirmative merits approval of the provider. The safest classification is mandatory bond/letter-of-credit filing and chapter compliance, not ordinary licensure. Indiana Government

2.4 CSO exclusions

The CSO definition excludes, subject to each stated condition:

• A person authorized and supervised under state or federal law to make loans/extensions of credit, and certain HUD-approved lenders.
• An FDIC-insured bank or savings association and its subsidiary.
• An Indiana credit union.
• An actual Internal Revenue Code §501(c)(3) nonprofit.
• An Indiana real-estate broker acting within the license’s scope.
• A person admitted to practice law in Indiana acting within the course and scope of that person’s attorney practice.
• A registered SEC/CFTC broker-dealer acting within the regulatory scope.
• A consumer-reporting agency.
• A loan servicer acting for the holder of a consumer loan or residential mortgage.
• A statutory Indiana debt-management company. [C011] Justia Law

A marketing claim of nonprofit status does not prove §501(c)(3) status. A relationship with an attorney likewise does not establish the attorney exclusion.

2.5 Attorney exclusion: controlling narrow construction

In Consumer Attorney Services, P.A. v. State, 71 N.E.3d 362 (Ind. 2017), the Indiana Supreme Court held that the CSO attorney exemption applies to an individual who is both admitted in Indiana and acting within the person’s attorney practice. It does not extend automatically to the law firm. A Florida lawyer never licensed in Indiana could not invoke it. [C012] Justia Law

Thus, “attorney-backed,” “law-firm affiliated,” fee-sharing with counsel, or retaining an Indiana lawyer for limited work is not enough by itself.

3. Consumer fees

3.1 Licensed DMP fees

Indiana’s operative consumer-fee structure is:

The setup fee is excluded from the monthly percentage base. A provider may ordinarily charge only one setup and one close-out fee unless the consumer leaves the service for more than six months. [C014–C017] Justia Law+1

The fee values are fixed statutory amounts. No CPI or other indexing mechanism appears in §28-1-29-8.3. The official 2026 Title 28 search result continues to surface the current returned-payment and fee section, and no conflicting 2026 amendment was located in the bounded enactment check. [C020] Indiana General Assembly

There is no express aggregate lifetime consumer-fee cap in §8.3. The agreement itself cannot exceed 60 months, but that duration rule should not be restated as a statutory aggregate-dollar cap because returned-payment charges and separately approved charges can vary. FindLaw

3.2 CSO/debt-settlement fees

IC 24-5-15 contains no numerical settlement-fee percentage, enrolled-debt percentage, savings percentage, per-debt amount, monthly cap, setup cap, or aggregate cap located in the complete chapter review for this pass. That means:

• Indiana has not supplied a verified numerical settlement-fee ceiling in this chapter.
• It does not mean any price is affirmatively authorized, reasonable, or immune from other law.
• The provider must disclose the total cost before contract or receipt of value, and the contract must disclose the total amount of all payments and describe services, results, guarantees, and refund promises. [C021, C023] Midpage+1

No statutory indexing or adjusted fee notice was found because the chapter does not state an underlying consumer-fee number to index.

3.3 Regulator fees are not consumer fees

The current administrative rule lists DMP regulatory charges of:

• $1,000 application fee.
• $1,000 annual renewal fee, due December 31.
• $20 per day renewal late fee.
• $80 per examination hour.
• $20 per day late examination-payment fee.

Those are charges to the regulated entity for licensing/examination—not fees chargeable to the consumer under a DMP. [C028] Legal Information Institute

DFI’s current page links a Consumer Credit fee schedule for July 1, 2026 through June 30, 2027, but the linked DOCX was not readable through the public web reader. The prior official schedule expressly covered July 1, 2025 through June 30, 2026 and showed the same DMP amounts, but it is historical and cannot itself prove the post-June 2026 schedule. The operative administrative rule, not the expired table, supports the current amounts. Indiana Government+1

4. When fees may be requested or received

4.1 DMP state timing

A licensed DMP may not impose charges or receive payment for debt-management services until:

1. The provider and debtor have agreed on a plan and signed a compliant agreement;
2. At least one payment has been made to a creditor under the plan; and
3. All creditors have been notified of the debtor-provider relationship.

The setup fee is independently subject to the first-creditor-payment trigger. [C018] Justia Law

This is stronger than merely saying the provider has performed a consultation or opened an account. Opening the account does not by itself unlock the $50 fee.

4.2 CSO state timing

Before entering the contract or receiving money or other valuable consideration, the CSO must give the statutory written statement, including a detailed service description and total cost. Midpage

IC 24-5-15-5 identifies charging or receiving money before complete performance as a deceptive act unless the CSO has obtained the §8 bond or letter of credit. [C022] Justia Law

That bond exception must be handled carefully:

• It removes that particular state-law deceptive-act condition when its requirements are satisfied.
• It is not a numerical fee authorization.
• It does not override the contract-disclosure and cancellation provisions.
• It does not override independently applicable federal advance-fee restrictions.

4.3 Current CSO contract and cancellation timing

Effective July 1, 2026, as amended by P.L.115-2026, §24-5-15-7 requires a written, dated, signed contract; payment terms and total payments; detailed services and results; refund promises; an Indiana process agent; two cancellation forms; and delivery of the completed documents at signing. The buyer may cancel without penalty before midnight of the third business day after signing. Payments must be returned within ten days after the seller receives the cancellation notice. [C023–C024] Bill Texts+1

The 2026 amendment principally updated a statutory cross-reference following Indiana’s consumer-credit recodification; the enrolled act is the primary evidence of the July 1, 2026 effective text. Bill Texts

4.4 Federal TSR context

Where the federal Telemarketing Sales Rule applies to the seller or telemarketer, 16 C.F.R. §310.4(a)(5) independently prohibits requesting or receiving a debt-relief fee until:

1. At least one debt has actually been renegotiated, settled, reduced, or otherwise altered under a valid executed settlement, DMP, or comparable agreement;
2. The consumer has made at least one payment under that agreement; and
3. For debts resolved individually, the fee is allocated either proportionally by enrolled debt balance or as one consistent percentage of actual savings.

The TSR’s savings basis is the enrolled debt amount minus the amount actually paid to satisfy it. A qualifying dedicated account remains consumer-owned, and unearned funds must be returned within seven business days after withdrawal. [C025] eCFR

This federal provision is common context only. This pass does not determine the TSR’s application to every channel, provider, or transaction. An Indiana bond filing or absence of a numerical state fee cap does not displace an applicable federal timing prohibition.

5. Regulator permission, application, and public lookup

5.1 DMP license

Regulator: Indiana Department of Financial Institutions, Consumer Credit Division. Application route: NMLS, under “Debt Management License.” Public status route: DFI links “Find a License” and describes it as a listing of currently licensed or registered consumer-credit entities. [C026] Indiana Government+1

The current DFI pages establish the application and lookup routes. But the linked public extranet and targeted debt-management listing did not return a readable company list through the available public reader; they produced non-retryable access errors. Therefore:

• The availability of a public lookup route is verified.
• The current content of the DMP roster was not verified.
• No named provider’s Indiana license status is established in this report.

Relevant public routes:

Plain text

https://www.in.gov/dfi/licensing-and-applications/consumer-credit-licensing/
https://www.in.gov/dfi/general-information/consumer-credit-division
https://extranet.dfi.in.gov/
https://extranet.dfi.in.gov/ConsumerCredit/TypeListing?handler=LicenseTypeList
https://extranet.dfi.in.gov/ConsumerCredit/CompanyListing/7?handler=CompaniesInLicenseType

5.2 CSO bond/filing

Regulator/recipient: Office of the Indiana Attorney General. Procedure publicly verified: Obtain the $25,000 bond or receive approval for an equivalent letter of credit; file it before doing business. The Attorney General page links a “Register/Submit Here” portal. [C027] Indiana Government

The linked Salesforce portal produced only a loading/CSS-error screen in the public reader. No public searchable roster, filing-acceptance list, certificate, or named-provider status was located. A portal submission procedure is not proof that a particular provider is currently compliant. Inoag

Relevant routes:

Plain text

https://www.in.gov/attorneygeneral/consumer-protection-division/homeowner-protection/credit-services-organizationsforeclosure-consultants/
https://inoag.my.site.com/oagcounsel/s/login/

6. Fee and boundary examples

Detailed calculations appear in Part D. The decisive results are:

• A DMP receiving $400 for creditors in a month has a maximum ordinary monthly fee of $60.
• At $600, the $75 monthly ceiling controls.
• At a $20 monthly creditor-payment base, the statute permits the $5 minimum even though 15% is $3.
• A proposed percentage-of-savings or per-settlement DMP fee is not among the expressly permitted charges and remains unavailable unless DFI specifically approves it as an additional charge.
• A debt-settlement contract charging 20% of enrolled debt cannot be validated merely because IC 24-5-15 lacks a numerical cap. Its total cost, contract terms, market-access filing, timing, and any applicable TSR formula must all be satisfied.
• A timely CSO cancellation requires return of payments within ten days after receipt of the notice.
• Business-purpose debt, mixed models, and original-creditor modifications should be classified before running any consumer-fee calculation.

7. Pass boundary and required next investigations

This pass establishes the principal DMP-versus-CSO classification, the corresponding license or bond-filing route, and the verified consumer-fee rules. It does not establish complete Indiana compliance.

The next focused investigations are:

1. Retrieve a readable current Indiana NMLS Debt Management License company checklist and renewal checklist, including every financial, bond, ownership, branch, control-person, background, and document requirement.
2. Obtain a readable current DFI DMP license roster/detail page and verify status fields, effective dates, expiration dates, branches, and legal names before assessing any named company.
3. Locate a public Attorney General CSO filing roster, filing-acceptance evidence, or official public-data substitute. The current submission portal alone is insufficient.
4. Obtain a readable official copy of the July 1, 2026–June 30, 2027 Consumer Credit fee schedule and reconcile it line-by-line with 750 IAC 10-1-11.
5. Investigate Indiana decisions or official interpretations applying “doing business in Indiana” to remote-only CSOs.
6. Investigate DFI interpretations of the $5 DMP minimum in a month with a zero or near-zero creditor-payment base.
7. Search public DFI orders for any approved DMP “additional charges”; none should be presumed.
8. Complete later passes on agreements, client funds, bonds, remedies, collection/litigation, limitations, complete exemptions, secured debt, sector-specific law, local/tribal issues, contract enforceability, and broader case law.

B. Source table

C. Claim table

D. Worked examples and component-coverage table

Calculation conventions

All dollar inputs and outputs are U.S. dollars. Calculations below produce exact cents or whole-dollar results; no special Indiana statutory rounding method was located. A real provider’s rounding policy may not cause the fee to exceed the statutory ceiling.

Example IN-DMP-01 — ordinary monthly payment

Plain text

Model: Licensed Indiana DMP
Consumer funds received for creditors during month: $400.00
Setup fee included in base: No

Percentage calculation:
15% × $400.00 = $60.00

Dollar ceiling comparison:
Lesser of $60.00 and $75.00 = $60.00

Maximum monthly service fee: $60.00

Conditions: compliant plan and signed agreement, all creditors notified, and at least one creditor payment already made. [C015, C018]

Example IN-DMP-02 — monthly dollar cap controls

Plain text

Creditor-payment base: $600.00
15% × $600.00 = $90.00
Statutory monthly ceiling: $75.00

Maximum monthly service fee:
min($90.00, $75.00) = $75.00

The provider may not use the $90 percentage result because the $75 ceiling is lower.

Example IN-DMP-03 — low-payment month

Plain text

Creditor-payment base: $20.00
15% × $20.00 = $3.00
Statutory permitted minimum where calculation is below $5: $5.00

Maximum monthly service fee: $5.00
Effective fee percentage in this example: 25%

The effective percentage can therefore exceed 15% in a low-payment month because the statute expressly permits the $5 minimum. A month in which the provider receives zero for creditor payments is held because no DFI interpretation resolving the zero-base application was located. [C015]

Example IN-DMP-04 — setup and monthly fee in first chargeable month

Plain text

Creditor-payment base for month: $400.00
Monthly maximum: $60.00
Setup maximum: $50.00

Maximum combined amount for these two expressly permitted charges:
$60.00 + $50.00 = $110.00

This is available only after the first creditor payment. The setup fee is not included in the $400 monthly base and may be charged only once unless the reentry rule applies. [C014–C016]

Example IN-DMP-05 — cancellation and close-out

Plain text

Consumer money held and not yet paid to creditors: $260.00
Assumed valid disclosed close-out fee: $100.00
Prior close-out fee charged: No

Illustrative refund:
$260.00 - $100.00 = $160.00

The consumer may terminate at any time, creditor notices must be sent, and remaining trust money must be returned immediately. The example assumes the full $100 close-out charge is validly available and no separate unresolved accounting item exists. [C016, C019]

Example IN-DMP-06 — previous setup/close-out fee

Plain text

Consumer leaves program and returns after 5 months:
Second setup fee permitted? No
Second close-out fee permitted? No

Consumer leaves program and returns after 7 months:
Statute permits another setup/close-out fee? Yes
Provider required to charge them? No

The threshold is more than six months. Exactly six months does not satisfy “more than six months.” [C016]

Example IN-DMP-07 — returned payments

Plain text

Number of returned consumer payments: 2
Maximum per returned payment: $25.00

Maximum returned-payment charges:
2 × $25.00 = $50.00

Each event must be an actual returned check, EFT, negotiable order of withdrawal, or share draft described by the statute. [C017]

Example IN-DMP-08 — proposed savings fee

Plain text

Original debt: $10,000.00
Creditor reduction: $4,000.00
Proposed provider fee: 20% of savings
Arithmetic result: 20% × $4,000.00 = $800.00

Indiana DMP result:
$800.00 is not an expressly authorized DMP fee.
Chargeable now? No, absent specific DFI approval as an additional charge.

The arithmetic does not create legal permission. [C017, C020]

Example IN-CSO-01 — enrolled-debt price is not validated by absence of a cap

Plain text

Enrolled unsecured debt: $10,000.00
Contract price: 20% of enrolled debt

Arithmetic:
20% × $10,000.00 = $2,000.00

Indiana conclusion:
IC 24-5-15 supplies no verified numerical cap that validates or invalidates
$2,000 solely by amount.

The provider still needs the bond/LOC filing, precontract statement, compliant contract, cancellation rights, truthful service/result descriptions, and compliance with independently applicable fee-timing law. [C010, C021–C025]

Example IN-TSR-01 — proportional allocation

Plain text

Total debt enrolled: $10,000.00
Debt A enrolled amount: $6,000.00
Debt B enrolled amount: $4,000.00
Disclosed total program fee: $2,000.00

Debt B proportional share:
$4,000.00 ÷ $10,000.00 = 0.40
0.40 × $2,000.00 = $800.00

Debt A proportional share:
$6,000.00 ÷ $10,000.00 = 0.60
0.60 × $2,000.00 = $1,200.00

For individually resolved debts under the TSR method, the provider cannot collect Debt B’s $800 until Debt B has been altered under an executed agreement and the customer has made at least one payment under it. No fee for unresolved Debt A is unlocked merely because Debt B resolved. [C025]

Example IN-TSR-02 — partial settlement and savings method

Plain text

Debt at enrollment: $10,000.00
Amount actually paid to satisfy debt: $7,000.00

Savings:
$10,000.00 - $7,000.00 = $3,000.00

Contractual savings percentage: 25%
Fee:
25% × $3,000.00 = $750.00

The same savings percentage must be used from one individually resolved debt to another. The debt must be satisfied; an unaccepted offer or partial payment that does not satisfy the debt does not produce the shown TSR result. [C025]

Example IN-CSO-02 — three-business-day cancellation

Plain text

Amount already paid under contract: $300.00
Consumer sends timely cancellation before midnight of third business day
Seller receives cancellation notice: Day 0

Required state refund:
$300.00 within 10 days after seller receives the notice

Where the TSR independently barred the original collection, the Indiana cancellation refund does not retroactively make that collection permissible. [C023, C025]

Example IN-BOUNDARY-01 — business-purpose debt

Plain text

Borrower: Individual business owner
Debt: $40,000 business inventory line
Purpose: Primarily business

DMP classification:
Outside express personal/family/household debt and debtor definitions.

CSO classification:
Outside the reviewed personal/family/household extension-of-credit definition.

Result:
Do not invent a DMP license or CSO consumer-fee pathway.
Other Indiana law remains uninvestigated in this pass.

Component coverage and gap table

E. Researcher self-check

Actually read

• The operative readable passages of IC 28-1-29 covering definitions, exclusions, licensing/nexus, unlicensed consequences, collection-agency affiliation, concessions, agreement termination, fee limits, termination after missed payments, prohibited representations, and voluntary contributions.
• The operative readable passages of IC 24-5-15 covering buyer, extension of credit, CSO definition/exclusions, debt settlement, precontract disclosures, advance-payment treatment, current contract/cancellation text, and bond/LOC filing.
• The official enrolled text of P.L.115-2026, §28, printed pages 26–27, including page-image inspection.
• The Indiana Supreme Court’s reasoning and holding in Consumer Attorney Services.
• Current DFI licensing, division, policies/fee-schedule, and public-lookup landing pages.
• Current Attorney General CSO filing instructions.
• Current 750 IAC 10-1-11 readable rule text.
• Current eCFR §310.4(a)(5), displayed up to date through October 22, 2026.

Not successfully read or not established

• Full official 2026 code-section text through IGA’s JavaScript interface. The official current indexes and enrolled amendment were used to corroborate currentness; readable mirrors supplied the other passages.
• The July 1, 2026–June 30, 2027 DFI Consumer Credit fee-schedule DOCX, because the public reader rejected the file type.
• A current readable DFI debt-management company roster or company-detail page.
• A public searchable Attorney General CSO filing roster or filing-acceptance record.
• The generated current Indiana NMLS Debt Management License checklist.
• Any named provider’s current Indiana authorization.
• A complete mixed-model, remote-CSO-nexus, provider-specific additional-charge, or zero-base-month administrative interpretation.
• The remaining agreement, funds, bond, remedies, litigation, limitations, secured-debt, sector, local, tribal, contract, and full case-law categories.

This was a focused researcher review, not an independent legal review, experimental reproduction, state acceptance, or publication-readiness determination. I did not use Chrome control, alter permissions, submit an application, contact a regulator, access private borrower data, check another conversation, or claim a local file write.

END S_IN PASS-01.