Check a debt-help provider’s evidence

S_ME — PASS-01

Maine provider market access and consumer fees

Actual research/access date: October 24, 2026, Pacific Time. Baseline supplied: October 22, 2026. Actual model/mode: GPT-5.6 Sol Pro in regular Chat; the owner-authorized quality-first fallback was used because GPT-6 Pro was not the selected/available model. Scope: Provider classification, market access, consumer fees, fee timing, current public registration procedure, bounded examples, and exact remaining gaps. This is not whole-state acceptance, publication approval, an A066 acceptance, or a completed Maine dossier.

Executive determination

1. Maine uses a broad, conduct-based debt-management definition. It reaches receiving or controlling consumer funds, arranging distributions without taking custody, and acting or offering to act as an intermediary to adjust, settle, compromise, discharge, or otherwise alter payment terms. A company cannot avoid coverage by calling itself a “financial coach,” “law firm partner,” “negotiator,” “software platform,” or “credit-counseling service” when its actual conduct falls within those activities. [C001–C006] Maine State Legislature
2. Covered organizations generally must obtain a Maine debt-management-service-provider registration. Traditional custodial budget planning is additionally subject to a separate statute that affirmatively prohibits the business unless the actor falls within a narrow exclusion or is registered under Title 32, chapter 80-A. Thus, registration is the statutory exception to an express prohibition for classic budget planning—not merely an optional operational credential. [C004, C007] Maine State Legislature+1
3. For-profit providers may register. Maine repealed its nonprofit-only restriction effective September 20, 2007. A nonprofit label is not a present exemption from registration. [C008] Maine Legislature
4. **Current Maine consumer-fee ceilings are:**reasonable one-time setup fee: no more than $75;then either:reasonable monthly fee: no more than $40, for a provider that actually distributes monthly payments; orreasonable settlement/term-alteration fee: no more than 15% of the amount by which debt is reduced as part of each settlement;reasonable approved consumer-education-program fee: no more than $50. These are ceilings, not automatic entitlements, and the operative consumer-fee statute contains no CPI/indexing mechanism. [C013–C019, C035] Maine State Legislature+1
5. Maine’s statute does not establish a complete standalone fee-collection timetable. It does not say that the $75 fee may be taken in advance. The 15% formula is outcome-dependent, but Maine does not separately prescribe the exact request/receipt event. When the federal Telemarketing Sales Rule applies, no fee or consideration for the debt-relief service may be requested or received until at least one debt has been altered under an executed agreement and the consumer has made at least one payment under that creditor agreement. [C020, C023–C025] eCFR+1
6. Public market access currently runs through NMLS under Maine Bureau of Consumer Credit Protection oversight. The operative rule states a $500 company application fee, $250 branch application fee, and $250 company and branch renewal fees, plus NMLS processing costs. Each business location requires a separate registration. Those company-registration fees must not be confused with the consumer-fee ceilings. [C026–C030] Midpage+1

A. Substantive answers to the seven assigned questions

1. How Maine classifies the relevant conduct

1.1 The four statutory activity categories

Maine defines “debt management service” through four alternative forms of conduct:

The definition is written around actual functions, including an offer to perform the service. It does not depend on whether the provider calls the product “debt settlement,” “credit counseling,” “debt resolution,” “hardship assistance,” “legal support,” or another marketing label. [C001] Maine State Legislature+1

1.2 Model-by-model classification

The underlying statutory definitions support the classifications above. The traditional budget-planning prohibition and its definition are separate from, but operate alongside, chapter 80-A. [C001–C006, C031–C034] Maine State Legislature+3

1.3 Consumer versus business purpose

A “consumer’s obligation” is debt incurred for personal, family, or household purposes and expressly excludes debt incurred for business or commercial purposes. Maine’s chapter does not resolve mixed-purpose debt, business cards used personally, personal cards used for a business, personal guarantees of business debt, or post-origination changes in use. Those require transaction-level facts and later interpretive research. [C002] Maine State Legislature

1.4 Remote-provider and geographic nexus

A provider includes a person “wherever located” that provides or offers debt-management services to a consumer “in this State” for a fee or other consideration. It also includes a person located in Maine that serves a nonresident for consideration. This expressly reaches ordinary telephone and online delivery into Maine. [C003] Maine State Legislature

Two nexus details remain unresolved:

• “Consumer in this State” is not separately defined as exclusively residence, physical presence, domicile, or contract location.
• The fee and education sections use the narrower phrase “consumer who is a resident of this State” in their Maine-outbound-provider carveouts. That wording difference means residence should not automatically be substituted for every occurrence of “in this State.”

A Maine-located provider serving no Maine residents remains within the provider definition, but §§6174-A(4) and 6174-B(3) say those fee and counselor/education provisions do not apply. Registration and the destination consumer’s state law remain distinct. [C012] Maine State Legislature

2. Whether each model is prohibited, registered, authorized, or exempt

2.1 General registration requirement

An organization desiring to act or continue acting as a debt-management-service provider must apply for registration or reregistration. Registration cannot issue unless the administrator finds that financial soundness and responsibility, insurance, consumer education and services, character, and fitness support a belief that the business will be operated honestly and fairly. A separate registration is required for each business location. [C007] Maine State Legislature+1

The statute defines “person” to include an individual or organization, but §6173(2) literally directs an “organization” to register. Rule 706, by contrast, expressly contemplates sole proprietors and individual applicants. Operationally, Maine provides a sole-proprietor registration route, but the statute/rule wording tension has not been resolved by a controlling decision found in this pass. [C036] Maine State Legislature+1

2.2 Traditional budget planning is affirmatively prohibited unless an exception applies

Title 17, §701 states that a person, firm, association, or corporation may not engage in budget planning for a consumer except for:

• the grandfathered attorney category;
• a supervised financial organization;
• a supervised lender; or
• an organization registered as a debt-management-service provider.

“Budget planning” is a contract under which the debtor periodically pays the provider, which distributes the money to specified creditors under an agreed plan. [C004] Maine State Legislature+1

Accordingly, a regulator webpage describing how to register does not transform unregistered budget planning into generally permissible activity. Registration is the statutory exception to the prohibition.

2.3 Debt settlement and noncustodial services

Debt settlement and noncustodial payment-arrangement services fall within chapter 80-A even when they are not “budget planning” under Title 17. Chapter 80-A’s mandatory registration language and enforcement provisions govern them. Registration is a conditional authorization to perform covered debt-management services; it is not a license to collect debts, lend money, purchase consumer debt, or take security interests. [C005–C007, C034] Maine State Legislature+1

2.4 Nonprofit status

Maine’s original 2000 law permitted only qualifying §501(c)(3) organizations to register. Public Law 2007, chapter 36 repealed that restriction and expressly allocated funds for the additional costs of permitting for-profit companies to obtain registrations. The amendment became effective September 20, 2007. Current §6173 contains no nonprofit-only condition. [C008] Maine Legislature+1

Therefore:

• a for-profit provider is not prohibited merely because it is for-profit;
• a nonprofit provider is not exempt merely because it is nonprofit;
• either must satisfy the current registration regime unless a different statutory exclusion applies.

2.5 Attorney exclusion

The attorney language is unusually narrow. It excludes only:

a person admitted to practice law in Maine as of the chapter’s effective date, except to the extent debt-management services constitute that attorney’s exclusive activity.

The chapter took effect March 15, 2000. The text does not create a general exemption for:

• lawyers admitted after March 15, 2000;
• an out-of-state attorney;
• a law firm merely employing or partnering with a Maine attorney;
• a nonlawyer debt-settlement company operating under an attorney’s name;
• an attorney whose exclusive activity is debt management.

The Granite Law administrative matter is a historical indication that the Bureau did not accept a mere Maine-attorney connection as sufficient, but the full official order was inaccessible in this session and it is not controlling appellate precedent. [C009] Maine Legislature+2

2.6 Financial-institution and lender exclusions

A “supervised financial organization” is a defined financial institution or specified supervised entity authorized to make loans and receive deposits, or a qualifying limited-purpose institution. A “supervised lender” is a person authorized to make, take assignments of, or service supervised loans under the Maine Consumer Credit Code or as a supervised financial organization. [C010] Maine State Legislature

These are entity-status exclusions. A parent, affiliate, vendor, lead generator, or separately incorporated settlement provider should not be assumed to inherit the exclusion from a bank or lender merely through a contract or common ownership.

2.7 Self-creditor activity

Maine does not provide an express “creditor collecting or modifying its own debt” exclusion in chapter 80-A. Paragraph (D)’s requirement that the provider act as an intermediary normally points away from a creditor dealing directly with its own borrower. But a creditor affiliate, separate servicing entity, common payment pool, or third-party fee-taker could implicate paragraphs (A) through (C). [C011]

Result: self-creditor treatment is a held issue. It should not be represented as a verified exemption without facts and an interpretive source.

2.8 Other prohibited combinations

A debt-management-service provider may not:

• purchase a consumer’s debt;
• lend money or provide credit to the consumer;
• obtain a mortgage or other security interest in consumer property;
• operate as a debt collector in Maine; or
• design an agreement that produces negative amortization at the end of the projected term.

These provisions are market-boundary rules, not a complete collection or secured-debt analysis. [C034] Maine State Legislature

3. Legally applicable consumer-fee structures

3.1 Current fee table

The current consolidated chapter, generated October 5, 2026 and current through October 1, 2026, carries the same consumer-fee figures enacted in 2007. The section history identifies no later amendment to §6174-A, and the statute contains no indexing or annual-adjustment clause. [C013–C019] Maine State Legislature+1

3.2 “Reasonable” is an independent limitation

Each consumer fee is described as reasonable and then assigned a maximum. Charging the maximum is not automatically lawful merely because the arithmetic falls at or below the ceiling. The provider must still have an applicable service, agreement, registration, and lawful timing basis. [C035] Maine State Legislature

3.3 Alternative service-fee tracks

Section 6174-A(2) says the provider may assess “either” the monthly-distribution fee or the settlement/reduction fee. The stronger textual reading is that these are alternative compensation tracks for the relevant consumer service, not cumulative monthly-plus-settlement compensation for the same program. [C017] Maine State Legislature

There is no controlling Maine appellate interpretation located in this pass. A hybrid model should therefore not stack the $40 and 15% fees for the same consumer without a specific legal basis and regulator/counsel confirmation.

3.4 Settlement-fee base

The Maine base is:

actual debt before the settlement − debt remaining/payable under the settlement

The ceiling is:

15% × actual debt reduction

Maine does not say the fee is 15% of:

• total enrolled debt;
• original portfolio balance;
• monthly savings-account contributions;
• the settlement payment;
• estimated future interest avoided;
• the consumer’s total program savings; or
• the amount paid to a dedicated account.

[C015] Maine State Legislature

3.5 Partial settlements and multiple debts

The statute applies the 15% calculation to the amount reduced “as part of each settlement.” Therefore:

• a partial reduction can create a fee base even when the debt is not fully extinguished;
• each separately settled debt has its own reduction and cap;
• a fee already charged for Debt A does not enlarge the reduction base for Debt B;
• there is no separate lifetime dollar cap in the statute, but the sum of settlement fees remains bounded by the reduction calculations and reasonableness.

[C015] Maine State Legislature

3.6 Interest, waived fees, and prospective concessions

Maine does not define whether “debt” for §6174-A(2)(B) includes:

• accrued interest already included in the legal balance;
• contingent collection charges;
• late fees;
• future interest that has not yet accrued;
• savings produced only if a consumer completes a long payment plan.

A settlement forgiving presently owed principal, accrued interest, or posted fees may create a measurable reduction. A prospective APR decrease with unchanged present balance does not clearly create a present “amount by which debt is reduced.” [C032]

Held conclusion: no fee should be modeled on projected future-interest savings as though Maine expressly authorized it.

3.7 Noncustodial arranger with no reduction

Paragraph §6172(2)(B) can cover a provider that merely arranges payment distributions, but §6174-A(2)(A) describes the $40 fee for a provider that distributes monthly payments. If the provider neither distributes payments nor achieves a measurable debt reduction:

• coverage may still exist;
• the $75 setup ceiling may be relevant under state law;
• no recurring $40 or 15% compensation pathway was verified;
• if the TSR applies and no debt was altered and paid, even the setup fee cannot yet be requested or received.

[C031] Maine State Legislature+2

3.8 Creditor-paid and third-party compensation

Provider status is triggered by a “fee or other consideration,” without saying the consideration must come from the consumer. By contrast, §6174-A is drafted around charges to the consumer. [C003, C033] Maine State Legislature+1

This pass did not establish whether creditor “fair-share” payments, grants, referral compensation, affiliate revenue, or lead fees:

• count against consumer fee caps;
• are independently permitted;
• create conflicts or disclosure duties;
• cause a referral entity itself to become a provider.

Silence in the consumer-fee section is not affirmative permission.

3.9 Refunds and credits

The agreement must state that either party may cancel by written notice. The chapter text reviewed does not supply a universal pro-rata fee-refund formula, a fixed refund deadline, or an express rule declaring when each type of fee becomes nonrefundable. [C021, C037] Maine State Legislature

That is distinct from:

• consumer funds held for creditors, which remain subject to statutory trust-account rules;
• unlawful or unearned fees that an agency or court may order refunded;
• federal dedicated-account funds, which may have to be returned within seven business days after withdrawal when the TSR applies.

4. When fees may be requested or received

4.1 Maine law by itself

Maine also requires the provider and consumer to execute a written agreement before the provider performs debt-management services. The agreement must describe services and fees and include the provider’s registration number and a written-cancellation right. That performance prerequisite does not itself answer when money may be collected. [C020–C021] Maine State Legislature

4.2 Federal TSR overlay when applicable

The federal rule defines a debt-relief service as a program represented to renegotiate, settle, or otherwise alter terms of unsecured debt, including balance, interest-rate, or fee reductions. “Telemarketing” generally requires a campaign involving more than one interstate telephone call. Calls initiated by consumers in response to general or direct-mail debt-relief advertising are specifically excluded from the ordinary inbound-call exemptions, so “the customer called us” does not by itself avoid the rule. [C023] eCFR+2

For a covered debt-relief service, the seller or telemarketer may not request or receive any fee or consideration until:

1. at least one debt has been renegotiated, settled, reduced, or otherwise altered under a valid agreement executed by the customer; and
2. the customer has made at least one payment under the agreement between the customer and creditor or debt collector.

When debts are handled individually, the provider must then use one of the federal individual-debt allocation methods. Under the savings method, the percentage charged cannot change from one debt to another. [C024] eCFR+1

Consequently, when the TSR applies:

• Maine’s $75 ceiling does not authorize collecting $75 at enrollment;
• relabeling the fee as “setup,” “legal,” “membership,” or “monthly” does not avoid the federal timing rule when it remains consideration for the debt-relief service;
• a genuinely optional and separate education product would require its own analysis;
• the federal rule cannot raise Maine’s lower fee ceiling.

The TSR is not necessarily applicable to every provider or transaction. Purely online programs without a covered telephone campaign, secured debts, exempt entities, and FTC-jurisdiction questions require separate analysis.

4.3 Dedicated accounts under the TSR

The TSR permits the consumer to place money in an account before a fee is earned only if, among other things:

• the account is at an insured financial institution;
• the consumer owns the funds and receives any accrued interest;
• the administrator is not owned, controlled by, or affiliated with the debt-relief service;
• the administrator does not pay or accept referral compensation involving the debt-relief service; and
• the consumer can withdraw without penalty and receive all unearned funds within seven business days after requesting withdrawal.

[C025] eCFR

That federal dedicated account is analytically distinct from Maine’s trust-account requirements for money received for payment to creditors.

4.4 Maine creditor-payment funds

When a Maine debt-management provider receives consumer funds for payment to creditors, it must:

• deposit them within two business days in a federally insured trust account for the consumer’s benefit;
• maintain separate consumer records;
• remit them to creditors within 15 business days;
• avoid commingling with operating accounts; and
• correct provider-caused misdirected payments and reimburse resulting actual creditor costs or fees.

[C022] Maine State Legislature

Those creditor-payment funds are not provider fees and should not be included in fee calculations.

5. Regulator permission, registration procedure, and public lookup

5.1 Regulator and legal authority

The administrator is the Superintendent of Consumer Credit Protection within Maine’s Department of Professional and Financial Regulation, operating through the Bureau of Consumer Credit Protection. Chapter 80-A supplies the registration authority; Rule 706 implements NMLS filing, fees, and application requirements. [C007, C026–C029] Maine State Legislature+1

5.2 Current operational path

[C026–C029] Maine State Legislature+3

5.3 Registration periods require current NMLS inspection

Rule 706 contains overlapping provisions:

• §IV(2) states registrations run January 1 through December 31;
• §IV(5)(b) says a new registration issued November 1 or later is valid through December 31 of the following year;
• §IV(7)(b) says registrations issued after the transition are valid for periods established by NMLS.

Accordingly, a provider should not infer its current expiration date from one generic rule sentence. The actual NMLS authority record and renewal status must be inspected. [C029] Midpage+2

5.4 NMLS transition and electronic surety bond

Rule 706 required the earlier transition of registrations into NMLS beginning in 2023. Separately, the current BCCP operational page states that businesses with existing Maine registrations were required to convert their surety bonds to electronic surety bonds through NMLS by January 31, 2026. These are two different transitions and should not be conflated. Midpage+2

5.5 Public authorization verification

Maine’s official license-search page directs debt-management-service-provider searches to NMLS. CSBS identifies NMLS as the system of record and describes NMLS Consumer Access as a free service for confirming whether a company or professional is authorized in the relevant state. [C028] Maine.gov+1

A defensible provider-status check should use:

• exact legal entity name;
• every DBA used with consumers;
• NMLS ID;
• Maine authority type;
• current approved/active status;
• issue and expiration dates;
• branch/location authority where applicable; and
• any public regulatory actions.

No SettleADebt.com legal entity, DBA, or named provider was checked in this pass. A website or marketing statement is not proof of registration.

5.6 Rule status and possible future changes

Chapter 706 is listed in the Maine Secretary of State’s official rule inventory. Cornell’s current reproduction reports an effective date of September 2, 2023 and filing number 2023-139. The official Maine Word document could not be fetched because the state page returned 403, so the full rule text in this report was read from two matching third-party reproductions rather than from the official downloadable file. [C029] Maine.gov+2

The Bureau’s 2025–2026 regulatory agenda says the Bureau may update Rule 706 based on experience and to correct errors. An agenda statement is neither a proposed rule nor an adopted amendment. No later effective amendment was verified in the accessible sources. [C030] Maine.gov+1

6. Worked-example conclusion

The complete examples appear in Part D. They demonstrate:

• lower-balance settlement;
• partial settlement;
• multiple debts and a previously charged debt fee;
• conservative cent rounding;
• six-month DMP;
• joint household obligations;
• prospective interest-rate concessions;
• cancellation;
• a noncustodial/no-outcome model; and
• an unregistered-provider classification hold.

No example assumes that satisfying a mathematical ceiling establishes registration, reasonableness, fee timing, or federal compliance.

7. Immediate implementation implications for SettleADebt.com

For a conventional for-profit, telephone-assisted unsecured-debt-settlement model marketed to Maine consumers, the most defensible present working classification is:

• covered intermediary service under §6172(2)(D);
• Maine debt-management-service-provider registration required before offering or providing the service;
• 15% of actual reduction per settlement as the relevant Maine service-fee ceiling;
• no additional $40 monthly-distribution fee for the same settlement program;
• $75 setup ceiling under state law, but no advance collection when the TSR applies;
• written Maine agreement and registration number before performance;
• approved consumer-education program and counselor-certification process;
• NMLS company and applicable branch authority;
• required bond and application materials; and
• fee collection only after all independently applicable state and federal conditions are satisfied.

This is a component-level implementation conclusion, not a determination that any particular operating agreement, payment processor, attorney model, dedicated account, lead arrangement, or provider is lawful.

B. Source table

C. Material claim table

D. Worked examples and scope coverage

D1. Plain-text worked examples

All examples assume a Maine-resident consumer, a properly registered provider, a personal/family/household unsecured obligation, an executed written agreement, a reasonable fee, and no other legal bar. They show arithmetic ceilings—not automatic earning or collection authority. The Maine formula is from §6174-A; federal timing is separately controlled by 16 CFR 310.4(a)(5) when applicable. Maine State Legislature+1

Example 1 — Ordinary settlement

Plain text

Debt immediately before settlement:       $10,000.00
Amount remaining/payable in settlement:     7,000.00
Debt reduction:                           $10,000.00 - $7,000.00
Debt reduction:                            $3,000.00

Maine percentage ceiling:                         15%
Maximum settlement fee:                   $3,000.00 × 0.15
Maximum settlement fee:                     $450.00

A separate setup fee could have a state arithmetic ceiling of $75, and an actually provided approved education program could have a separate $50 ceiling. Neither figure is automatically collectible at enrollment. Under the covered TSR, the settlement-fee timing conditions must occur first.

Example 2 — Lower-balance debt

Plain text

Debt before settlement:                     $300.00
Settlement amount:                          $240.00
Reduction:                                   $60.00

Maximum Maine settlement fee:
$60.00 × 15% =                                $9.00

The fact that the maximum fee is small does not permit replacing it with a flat per-debt minimum.

Example 3 — Partial reduction without full discharge

Plain text

Debt before modification:                $10,000.00
Debt remaining after binding settlement:   8,000.00
Reduction:                                 2,000.00

Maximum Maine settlement fee:
$2,000.00 × 15% =                            $300.00

This assumes the transaction legally constitutes a settlement reducing the debt by $2,000. A temporary payment pause or merely projected future savings does not establish that base.

Example 4 — Two debts and a previously assessed fee

Plain text

Debt A:
Enrolled/owed amount:                      $8,000.00
Settlement amount:                          5,000.00
Reduction:                                  3,000.00
Maximum fee:                              $3,000 × 15% = $450.00

Debt B:
Enrolled/owed amount:                      $4,000.00
Settlement amount:                          3,700.00
Reduction:                                    300.00
Maximum fee:                                $300 × 15% =  $45.00

Combined reductions:                       $3,300.00
Combined Maine settlement-fee ceiling:       $495.00

The $450 already attributable to Debt A does not increase or decrease Debt B’s Maine reduction base. If the federal savings method is used, the percentage cannot change from one individually resolved debt to another.

Example 5 — Conservative cent rounding

Plain text

Verified debt reduction:                  $1,234.57
Exact 15% product:                        $1,234.57 × 0.15
Exact product:                              $185.1855

Maine supplies no rounding rule. The conservative whole-cent amount that does not exceed the exact ceiling is $185.18. Rounding to $185.19 would exceed the mathematical 15% ceiling by $0.0045.

Example 6 — Six-month custodial DMP

Plain text

One-time setup ceiling:                      $75.00
Six monthly fees:                     6 × $40.00
Six monthly fees:                           $240.00

State arithmetic total:
$75.00 + $240.00 =                          $315.00

This assumes the provider actually distributes monthly creditor payments and a $40 fee is reasonable for every month. An approved education program could add no more than $50 if actually provided, producing a theoretical state arithmetic total of $365. The TSR may still delay the setup and service fees if the program is a covered telemarketing debt-relief service.

Example 7 — Joint obligations of spouses

Plain text

One setup fee:                               $75.00
Six monthly fees:                           $240.00
Maximum arithmetic total:                   $315.00

The provider may not double the total to $630 merely because the agreement covers joint debts of both spouses.

Example 8 — Interest-rate reduction only

Plain text

Present debt balance before agreement:     $8,000.00
Present debt balance after agreement:      $8,000.00
APR before agreement:                            24%
APR after agreement:                              8%
Accrued interest or fees expressly waived:       $0
Present verified debt reduction:             $0.00

The service is covered term-alteration activity, but the current Maine 15% base is not established by projected future interest avoidance. The conservative present fee calculation is:

Plain text

$0.00 × 15% = $0.00

A different result requires authority defining future avoided interest as “debt reduced.”

Example 9 — Cancellation after two actual DMP months

Plain text

Setup ceiling:                               $75.00
Two monthly fees:                      2 × $40.00
Two monthly fees:                            $80.00
State arithmetic ceiling to date:           $155.00
Future monthly fees after cancellation:       $0.00

This does not conclude that the $155 was earned or nonrefundable. Maine requires a written-cancellation right but does not supply a universal pro-rata refund rule in the chapter text reviewed. Unsent creditor funds remain separate trust funds. If a TSR-compliant dedicated account is involved, unearned account funds are subject to the federal seven-business-day return rule.

Example 10 — Noncustodial arranger, no distribution and no result

Plain text

Monthly creditor payments distributed by provider:   none
Executed settlements reducing debt:                  none
Verified debt reduction:                             $0.00

State classification may still exist under §6172(2)(B) or (D), but:

Plain text

Verified monthly-distribution fee pathway:           none
Verified settlement-fee base:                        $0.00
State setup-fee ceiling:                              $75.00

If the TSR applies, no fee can yet be requested or received because no debt was altered and no first creditor payment occurred.

Example 11 — Covered but unregistered provider

Plain text

Consumer debt:                             $20,000.00
Proposed settlement reduction:              8,000.00
Arithmetic 15% figure:                      1,200.00
Maine registration status:                 not established

The $1,200 calculation does not create a lawful fee pathway. An unregistered covered provider cannot use the fee ceiling as permission to operate.

D2. Component coverage and gap table

E. Researcher self-check

Actually read

• The current Maine chapter 80-A PDF, including definitions, registration, consumer fees, education, handling of funds, written agreements, prohibited activities, and current-through date.
• Current official Maine webpages for Title 17 §§701–702 and Title 9-A §1-301.
• The official 1999 and 2007 Maine session laws.
• Two matching full reproductions of Rule 706 and its reported effective-date metadata.
• Current eCFR provisions for TSR definitions, fee timing, dedicated accounts, telemarketing definition, and inbound-call exceptions.
• Current public-search descriptions of Maine’s NMLS filing and public-lookup routes.
• Search-index passages from the two historical Maine administrative orders.

Not fully read or not independently verified

• The official Maine-hosted Word copy of Rule 706: official rule-list page returned 403.
• A separate official Rule 706 adoption order beyond filing/effective-date metadata.
• The complete BCCP debt-management licensing, license-search, and ESB webpages: direct fetches returned 403.
• The dynamically generated Maine NMLS checklist: compiler exposed no checklist text.
• The full 2025–2026 regulatory-agenda PDF: search passages were available, but the PDF could not be opened/rendered.
• The full Legal Solutions Debt and Granite Law orders: only official-page indexed passages were available.
• A comprehensive paid citator or all Maine trial-court dockets.
• Any named provider’s current registration status.
• Private analytics, borrower records, contracts, payment files, or internal regulator systems.

Judicial search boundary

Targeted public searches for Maine appellate opinions using “Debt Management Services Act,” “32 M.R.S. §6174-A,” “debt management service provider,” and related terms did not locate a controlling interpretation of the material fee provisions. That is a bounded search result, not a representation that no such trial-level, unpublished, federal, or otherwise unindexed decision exists.

Arithmetic and process controls

• Worked calculations use the literal statutory bases and exact decimal arithmetic.
• No CPI adjustment was invented because no consumer-fee indexing mechanism was found.
• Regulator application fees were kept separate from consumer charges.
• State fee ceilings were kept separate from federal fee timing.
• Creditor-payment trust funds were kept separate from provider fees and TSR dedicated-account funds.
• Historical agency enforcement was not represented as controlling court precedent.
• Search snippets were used only where the underlying official route was inaccessible and were identified as such.
• No Chrome control, new browser tabs, other chats, Deep Research, Work, APIs, purchases, CAPTCHA workarounds, account or permission changes, contacts, applications, private borrower data, local writes, or publication actions were used.
• This report is not labeled an independent review and is not represented as publication-ready legal advice.

END S_ME PASS-01