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

S_MN PASS-06 — Minnesota DMP fees, initial-payment allocation, and necessary funds ledger

Research/access date: October 27, 2026, America/Los_Angeles. Scope: Debt-management-plan origination and maintenance fees; initial and periodic-payment allocation; advance-payment restrictions; necessary custody, distribution, cancellation, and refund accounting; and the directly relevant federal Telemarketing Sales Rule (TSR).

Disposition: The statutory limits can be reconciled for several conditional models, including one that permits both origination and maintenance fees. No authority was established for deducting $50 plus $45 from the same ordinary $300 periodic payment. The genuinely separate, fee-only initial-payment theory remains unresolved rather than approved.

P01’s original examples and access history remain preserved. P02 and P04 are separate reviewed components. P05’s unreviewed settlement-performance findings are not premises for this report.

Throughout, S001 means S_MN-P06-S001. Claim identifiers C001–C045 belong exclusively to this pass.

A. Answers to the central questions

A1. Can origination and maintenance both be taken from an initial payment?

Yes, conditionally—but each fee’s individual ceiling is not the entire test.

Section 332A.13 separately provides an origination allowance, a maintenance ceiling and reasonableness condition, and a restriction on all authorized fees retained from any periodic payment. The initial-payment provision contains no express statement exempting an initial payment that is also a periodic plan payment from that retention restriction. [C009–C011; S001, subdivisions 1–4.] MN Revisor

That produces these distinct results:

These are applications of the text, not holdings from a Minnesota appellate decision. No responsive published majority opinion or binding administrative interpretation was located and read that supplies an initial-periodic-payment exception. The practical conclusion is therefore narrower than a universal pronouncement about every conceivable initial payment: the stated $95-from-$300 transaction has not been justified. [C011–C012, C036.]

A2. What remains unresolved about a separately paid origination fee?

The statute distinguishes an “initial amount” from a “periodic payment,” but the relevant definitions do not expressly define those terms or establish how to classify a separate fee-only transfer. Two constructions remain materially different:

Neither construction permits treating labels as decisive. A “nominal enrollment charge,” separate invoice, second debit, or different accounting code does not itself establish an exception. The written agreement, actual obligation, purpose, timing and funds flow matter. [C012; S001–S003.] MN Revisor+2

Federal timing is an additional issue. For the covered DMP model discussed below, moving the origination charge into a separate payment before the qualifying DMP enrollment and first payment does not solve the federal advance-fee problem. Moving it afterward may resolve that federal timing issue, but does not resolve Minnesota’s payment-classification question. [C030–C032.] Federal Register

A3. Does Minnesota impose the settlement chapter’s “fully performed” test on every DMP fee?

This pass does not import that test. Chapter 332A supplies its own fee, service-reasonableness, agreement, advance-payment, consent and funds rules. The relevant cancellation language also distinguishes origination fees from fees earned before cancellation or default. It does not provide a universal definition of when every maintenance fee is earned. [C010, C015–C017, C025; S001.] MN Revisor

For a particular DMP fee, the questions are instead:

• Is the charge authorized by the signed agreement and the applicable statutory fee category?
• Is the maintenance amount reasonable for services actually provided?
• Do the monthly and per-payment limits both permit it?
• Does the advance-payment restriction prohibit receipt or retention at that time?
• Have any independently applicable federal predicates been satisfied?
• Is the proposed transfer authorized, correctly recorded, and compatible with timely creditor distribution?

A provider’s receipt of money, a numerical ceiling, a bank debit, and a lawful fee transfer are four different events.

B. Version, enactment, and adjustment findings

B1. Current statutory version and material historical changes

The retrieved Revisor section pages are labeled 2025 Minnesota Statutes. The targeted 2026 regular-session statutes-changed entries for Chapter 332A identify the previously reviewed accreditation-definition repeal and application amendment. They do not list an amendment to the fee or funds provisions examined here. That is a targeted regular-session index finding, not a fully consolidated October 2026 or all-later-session certificate. [C001; S011.] MN Revisor

The fee provision’s material enacted history was checked directly:

The 2009 limitation does not conceal an assumed date: the models use the retrieved current bodies, not a claim that a historical version governed a particular 2009 transaction. [C002–C003; S008–S010.] MN Revisor+3

B2. No DMP inflation adjustment established

The complete §332A.13 body contains no indexing formula for its $50 and $75 amounts. Commerce’s current July 1, 2026 Consumer Credit Code adjustment notice expressly concerns Chapter 56 and §47.59—not these DMP fee caps. It cannot be imported into Chapter 332A. No applicable DMP adjustment notice was located in the bounded search. [C004; S001, S017.] mn.gov // Minnesota's State Portal

Accordingly, the calculations below use the displayed $50 origination and $75 maintenance figures. No inflation calculation was invented.

Provider registration charges, renewal charges and bond costs are not additional consumer-fee categories established by this analysis. Their separate existence does not authorize passing them through as an extra debtor charge. [C013; S001, subdivision 3.]

C. State fee and funds rules applied together

C1. Classification and agreement prerequisites

Minnesota’s DMP definition focuses on receiving debtor funds and distributing periodic payments to creditors for full repayment of personal, family or household debt. Provider and delegated-service provisions, and holding oneself out as providing the service, also matter. A business cannot establish a noncustodial exclusion merely by having an associated processor receive the money. [C005–C006; S002, subdivisions 8–10, 12.] MN Revisor

A genuinely direct-creditor arrangement—where the consumer pays creditors without provider receipt or distribution—requires its own classification. It does not automatically inherit §332A.13’s fee permissions, and a concession-negotiation service may still meet the federal debt-relief definition even without provider custody.

Section 332A.10 requires the executed written agreement before DMP services or plan funds, together with the required pre-agreement assessment and disclosures. Fee amounts, services, anticipated charges, refund policy, cancellation terms and creditor participation are material to this ledger. [C007–C008; S003, subdivisions 1–3.] MN Revisor+1

C2. Joint fee calculation

For a periodic receipt PjP_jPj​, define:

• OjO_jOj​: origination amount retained from that receipt;
• MjM_jMj​: maintenance amount retained from that receipt;
• MmonthM_{\text{month}}Mmonth​: total maintenance attributed to the month;
• PmonthP_{\text{month}}Pmonth​: the relevant monthly payment amount under the agreement.

The combined textual constraints are:

Plain text

Total origination fee ≤ $50.

Monthly maintenance must be reasonable for the services provided, and:
M_month ≤ lesser of (15% × monthly payment amount) or $75.

For each periodic payment:
O_j + M_j + any other purported fee retention ≤ 15% × P_j.

Creditor allocation from that periodic payment:
P_j − lawful fee retention ≥ 85% × P_j.

This is a combined reading of subdivisions 1–4, not a statutory formula expressly printed in this notation. A lower contractual fee remains lower; unused statutory capacity is not automatically earned. [C009–C011; S001, S008.] MN Revisor+1

For weekly or biweekly schedules, the monthly maintenance ceiling is not a fresh $75 allowance for every installment. The provider must reconcile both the month and every individual receipt. The precise treatment of irregular months, unspecified monthly amounts, and a missed month’s possible contractual fee receivable requires the actual agreement and potentially additional interpretation. [C041–C042.]

C3. Charges that cannot be supplied by changing the label

The reviewed provisions do not establish separate provider charges for handling a late payment, returned payment, cancellation, statement, modification, or “enrollment donation.” Section 332A.14 also prohibits demanding or collecting a purported voluntary contribution from the debtor. A bank’s independently imposed charge is a different issue and is not converted into a provider surcharge by this report. [C013; S001, subdivision 3; S006, clauses (5), (7), (8), (16).] MN Revisor

The “recurring payments” no-fee rule has a specific listed subject matter: current living and support obligations such as rent, mortgage, utilities, telephone, child support and insurance. It should not be misread to mean that every recurring monthly DMP installment is fee-free. Conversely, handling current rent does not enlarge the fee-bearing DMP base merely because the same transfer also includes plan money. [C014; S001, subdivision 4.]

Additional or separate agreements do not authorize another origination charge. Modifications have their own signed-writing rule and limited exceptions; they do not create an unrestricted new fee. [C027; S003, subdivision 5.] MN Revisor

C4. Advance-payment restriction and exceptions

Subdivision 5 expressly overrides inconsistent provisions of the chapter. The restriction concerns fees for advance payments; it is not itself a complete rule about whether funds may be accepted, how long they may be held, or when creditors must receive them. [C015–C017; S001, subdivision 5; S008, article 3, §56.] MN Revisor+1

For an unspecified-amount agreement with previous regular payments of $100, $150 and $200:

Plain text

Average prior payment = ($100 + $150 + $200) ÷ 3 = $150.
Twice that average = $300.
New $400 payment: $100 is deemed advance payment.

That classification still needs the applicable date and 30-day-intent analysis. It is not a self-executing permission to charge on the entire $400.

C5. Custody, availability and creditor distribution use different clocks

The necessary trust rules require available payments to enter the separate trust account. Disbursements to the debtor, creditors and provider originate there, subject to the limited debtor/creditor disbursement-account route. The narrow minimum-bank-balance commingling allowance does not turn debtor funds into operating revenue. [C020; S001, subdivision 8; S009, §8.] MN Revisor+1

The distribution deadline is measured from receipt, not automatically restarted when funds become available: creditors must be paid within 42 days, or earlier where their agreement requires it. The statute contains specified longer-holding circumstances, including reasonable accumulation of a sum certain and a returned payment or another reason making withholding in the debtor’s net interest. These are factual exceptions, not a general 42-day float or permission to accumulate provider fees. [C021; S001, subdivision 9.]

A returned check may require both a provisional-credit reversal in the bank reconciliation and a separate debtor-ledger notation. It does not become a creditor payment. If no cash ever became available, the available-cash model below records zero receipt and separately records the failed attempt.

C6. Consent, insufficient payments and withdrawal

The provider must actively seek all creditor consent. Minnesota permits evidence of consent through acceptance of a plan payment as well as express writing. Failure to obtain consent has a ten-day notice requirement; withdrawal or refusal has a prompt-notice requirement with a fifteen-day outside limit. The notices include the specified cancellation information. Where both provisions potentially apply, a provider should not use the longer outside limit to disregard the shorter applicable requirement. [C018–C019; S001, subdivisions 6–7.] MN Revisor

A short payment does not make its full scheduled amount available. For example, if $100 is received against a $400 scheduled payment, the receipt-level retention ceiling is $15. Whether a maintenance receivable otherwise exists depends on the agreement, service and monthly-base interpretation; it is not established simply because the contract originally contemplated $400. [C011, C042.]

The statute does not supply a general instruction to stop paying creditors while a fee balance accumulates. The related prohibitions against encouraging or condoning stopped creditor payments and plans involving negative amortization remain relevant. [S006, clauses (3), (4), (9), (13).] MN Revisor+1

C7. Cancellation, termination and fee refunds

These events require different ledgers:

The protection in §332A.13(6) for origination and previously earned fees is not treated as validating an originally unlawful charge or overriding the distinct material-violation rescission provision. Nor does this report invent a universal DMP “immediate excess-fee refund” rule borrowed from the settlement chapter. [C023–C026; S001, S004, S007.] MN Revisor+2

Monthly and cancellation/termination statements must distinguish receipts, creditor disbursements and deducted fees. The provider must maintain the relevant records for the statutory period. [C022; S005.] MN Revisor

D. Essential federal interaction—DMP-specific, not settlement-derived

D1. Coverage assumptions

The positive models below assume a nonexempt for-profit provider selling an unsecured consumer-debt concession DMP through a covered telephone campaign involving interstate calls. That fits the relevant federal debt-relief and telemarketing definitions on the stipulated facts, not merely because the service is called a DMP. [C028; S012.] eCFR

The following distinctions remain necessary:

These distinctions come from the freshly read definitions and exemptions. No actual provider’s nonprofit, institutional or other jurisdictional status was adjudicated. [C028–C029; S012, S014.] eCFR+1

D2. What the Commission specifically says about DMPs

The operative rule requires a qualifying alteration under a customer-executed agreement and a payment under that agreement. Its individual-debt allocation provision applies to the extent debts are altered individually. [C030; S013, §310.4(a)(5)(i).] eCFR

The Commission’s final-rule explanation addresses DMPs directly. At 75 FR 48489, section III.C.5(a), and footnote 431, it describes:

• a customer-executed plan with altered terms binding the applicable creditors;
• evidence of the consumer’s first payment to the credit-counseling agency for distribution to creditors;
• a DMP model in which eligible debts are renegotiated together, rather than individually; and
• subsequent periodic servicing fees after the qualifying enrollment and first payment.

Thus, that described DMP does not need to wait until all principal is repaid before any fee may be collected. [C031–C032; S015.] Federal Register+1

This is the Commission’s published explanation of its rule—not a Minnesota fee interpretation and not a blanket exception for any business using a DMP label. If creditors join at different times, terms are not binding, or debts are individually altered, the factual premise for the footnote’s treatment must be re-examined.

D3. Separate state and federal predicates

No federal predicate increases Minnesota’s dollar ceiling, creates a state fee category, or supplies an exception to the periodic-retention restriction. [C030–C034.] eCFR+1

D4. Account accumulation is not the same as ordinary DMP distribution

The dedicated-account provision has insurance, consumer ownership, administrator independence, referral-compensation and withdrawal/return conditions. A provider-controlled Minnesota trust account is not automatically the independent account contemplated by that federal provision. [C033; S013, §310.4(a)(5)(ii).] eCFR

The models do not use a pre-trigger savings account to pay an advance fee. They assume a binding DMP before the first scheduled plan payment and postpone fee transfers until after the qualifying event. The specific federal treatment of an alternative pre-trigger custody arrangement remains held.

The models also use consumer-initiated payments, not a claim that an automatic debit arrangement has been approved. Other payment-rail or bank-account rules remain outside this limited review. CROA and TSR credit-repair applicability remain separate boundaries if actual representations make them relevant.

E. Actor-and-event decision table

These are evidence and accounting tests derived from the cited provisions, not a complete account-control or compliance manual. [C007–C035.] MN Revisor+4

F. Fourteen fresh fictional postures

All are hypothetical. None concerns an actual provider or debtor.

Authorities: C007, C009–C027, C028–C034, C041–C042. The numerical comparisons are original calculations; their legal conditions remain those stated above.

G. Fully worked joint funds models

Common assumptions and accounting convention

These are conditional demonstrations, not approvals.

For positive branches, assume a legally eligible registrant; a valid written agreement; required assessment and disclosures; reasonable actual services; unsecured consumer debts; customer-executed concessions binding both creditors before the first receipt; a covered for-profit interstate telephone-sales campaign; and no applicable exemption.

For transparent debt arithmetic, creditors agree to 0% interest and no additional charges during the illustrated period. This is a fictional contract fact, not a prediction. Real creditor balances must incorporate actual interest, charges and application of payments.

All positive cash receipts are consumer-initiated and available on the stated date. No automatic-debit compliance is assumed. Fee transfers occur after the federal DMP trigger; maintenance is transferred after the modeled services.

Plain text

Opening custody
+ available receipts
− lawful provider-fee transfers
− creditor payments
− returns to debtor
= closing custody.

Creditor debt balances are calculated separately. A provider fee or debtor refund is never also counted as a creditor payment.

All selected amounts calculate exactly to cents. No statutory cent-rounding method was located. These examples do not round a fee upward beyond a computed ceiling.

M01 — The $300 adversarial test and a different, conditionally compliant contract

Inputs

• Debts: A $2,000; B $4,000; total $6,000.
• Agreement executed September 7, 2026.
• Gross plan payment: $300 monthly, due on the tenth.
• Creditor payments due on the fifteenth.
• Creditor allocation: one-third to A, two-thirds to B.
• Opening custody: $0.

Rejected proposal: $50 plus $45

Plain text

Maintenance ceiling:
min(15% × $300, $75) = min($45, $75) = $45.

All-fee retention ceiling for this periodic payment:
15% × $300 = $45.

Proposed fees:
$50 + $45 = $95.

Retention percentage:
$95 ÷ $300 × 100 = 31.6667%.

Proposed creditor remainder:
$300 − $95 = $205.

Minimum creditor allocation under the 15% restriction:
$300 − $45 = $255.

Difference:
$255 − $205 = $50.

Even taking only the full $50 origination from this ordinary $300 periodic payment exceeds the $45 collective retention ceiling. The independent $50 allowance has not been shown to override that ceiling. [C037.]

Alternative branch—not a retroactive cure

A separately stipulated agreement instead sets origination at $30 and monthly maintenance at $15. There is no additional $20 origination receivable.

Plain text

Cash:
$0 + $300 − $45 − $255 − $0 = $0.

Monthly maintenance:
$15 ≤ $45.

Combined fee retention:
($30 + $15) ÷ $300 = 15%.

Creditor balances:
A: $2,000 − $85 = $1,915.
B: $4,000 − $170 = $3,830.
Total: $5,745.

Before September 30, the remaining $15 is still custody money awaiting the modeled lawful fee transfer—not already spent revenue. After completion, closing custody and presently unearned held fees are zero.

Result: The original $95 proposal is not supported. The different $45-total contract is numerically and conditionally reconcilable; reasonableness and the other assumed predicates are not established for any actual provider.

M02 — Both maximum component fees fit a larger initial periodic payment

Inputs

• Debts: A $4,000; B $6,000.
• Agreement executed September 1, 2026.
• Gross monthly payment: $1,000, due on the fifth.
• Creditor payments due on the fifteenth.
• Origination $50; reasonable monthly maintenance $75.
• Creditor allocation: 40% to A, 60% to B.

Plain text

Maintenance ceiling:
min(15% × $1,000, $75) = $75.

All-fee retention ceiling:
15% × $1,000 = $150.

Actual first-cycle fee total:
$50 + $75 = $125.

Retention percentage:
$125 ÷ $1,000 = 12.5%.

Creditor remainder:
$1,000 − $125 = $875.

Minimum creditor amount:
85% × $1,000 = $850.

Actual creditor amount exceeds that minimum by $25.

Plain text

Cash:
$0 + $1,000 − $125 − $875 − $0 = $0.

Creditor balances:
A: $4,000 − $350 = $3,650.
B: $6,000 − $525 = $5,475.
Total: $9,125.

The unused $25 of retention capacity is not another fee allowance. It remains part of the creditor allocation. No second origination fee is assumed for a later payment.

Result: This provides an initial-payment fact pattern permitting both component fees without needing an exception to the periodic-retention rule. It does not establish that $75 is reasonable for every provider’s services. [C038.]

M03 — Separate fee-only candidate: accounting balance does not establish legality

Inputs and disputed alternatives

• Debts: A $2,000; B $4,000.
• Scheduled monthly plan payment: $300.
• Reasonable maintenance: $45.
• Proposed additional origination payment: $50.

Candidate A: Collect $50 before the qualifying DMP enrollment/first-payment event. The modeled federal rule does not permit this merely because it is called origination.

Candidate B: Collect $50 separately after the qualifying event. Federal timing may no longer be the obstacle, but Minnesota classification remains unresolved.

If the two amounts are one $350 periodic payment in substance:

Plain text

15% × $350 = $52.50 maximum collective retention.
Proposed $50 + $45 = $95.
Difference = $42.50.

If the $50 is genuinely nonperiodic, the statute’s separate-initial-payment interpretation must be established rather than assumed.

The following equation can balance physically while remaining legally unsupported:

Plain text

$0 + $350 − $95 − $255 = $0.

That is why bank reconciliation alone cannot validate the fee.

Demonstrated no-origination path

For this actual hypothetical ledger, the agreement waives origination. The consumer mistakenly sends an additional $50, which is never treated as earned and is returned.

Plain text

Cash:
$0 + $350 − $45 − $255 − $50 = $0.

Creditor balances:
A = $1,915.
B = $3,830.
Total = $5,745.

The $50 return does not reduce creditor debt and is not counted as a provider-fee refund because the model never treats it as a fee. Its return follows the stipulated waiver and mistaken-payment facts; it is not a holding that every separately paid origination fee must be refunded.

Result: A lawful-looking cash balance does not resolve the separate-fee theory. The demonstrated branch avoids that unresolved theory rather than approving it. [C039.]

M04 — Missed payment, partial receipt and cancellation

Inputs

• Debts: A $3,000; B $5,000.
• Agreement executed July 1, 2026.
• Gross payment $400 monthly, due on the fifth.
• Creditor payment due on the fifteenth.
• Origination waived.
• Maintenance $30 for a funded cycle, expressly waived by the contract for a missed or underfunded cycle.
• Creditors allocate payments 37.5% to A and 62.5% to B.
• For this illustration only, creditors preserve the zero-interest/no-extra-charge terms during the missed-payment interval.

The maintenance waiver is a contractual fact—not a universal statutory requirement.

July: funded cycle

Plain text

Maintenance ceiling = min(15% × $400, $75) = $60.
Contractual maintenance = $30.
Receipt retention = $30 ÷ $400 = 7.5%.
Creditor distribution = $370.

A receives $138.75; B receives $231.25.

August: failed payment

The attempted $400 payment is returned before funds become available. It is recorded as a failed transaction, not a $400 available-cash receipt. If a bank statement had shown provisional credit, the bank reconciliation would also show its reversal.

September: partial receipt and cancellation

The debtor gives written notice August 31. September 10 is stipulated as the effective cancellation date; this is not a legal notice-service computation.

A $100 partial payment becomes available September 5. The contractual underfunded-cycle fee waiver applies. The next creditor due date is September 15. The $100 is returned September 12, with creditor notification and a closing statement.

Plain text

Combined cash:
$0 + $500 − $30 − $370 − $100 = $0.

Creditor balances:
A: $3,000 − $138.75 = $2,861.25.
B: $5,000 − $231.25 = $4,768.75.
Total = $7,630.

The attempted August payment does not reduce debt. The September return does not reduce debt. Missed installments are not added a second time as new principal.

Ordinary cancellation does not automatically require repayment of the assumed-lawful July $30 fee. If a material violation and statutory rescission were separately established, the fee-return analysis would change; the $30 would be a provider-fee return, not another creditor payment. The main model does not assume such a violation.

Result: Closing custody is zero; creditor debt remains $7,630; no unearned funds remain held; no missed-cycle fee receivable exists because the stipulated contract waived it. [C040.]

H. Concise effect crosswalk to P01

No original example, source-access date or reviewed record is rewritten. [C043–C044.]

I. Source register

Access convention: All “fresh” entries below were accessed during this October 27, 2026 research session. Individual fetch timestamps were not exposed and are not invented. Statutory sections within one chapter are separate retrieved bodies, not independent corroborating legal systems.

Interpretation search and unsuccessful/discovery routes

The bounded search used the exact statute and combinations including:

"332A.13" "origination" "periodic" court "332A.13" "initial" "fee" interpretation "332A.13" site:mncourts.gov "332A.13" site:mn.gov/commerce "332A.13" site:revisor.mn.gov/rules "332A.13" "opinion" "332A" "fee" "inflation" site:mn.gov

No responsive published judicial-majority opinion or binding agency interpretation was located and opened resolving the separate-initial-fee classification or supplying an exception to the periodic-retention limit. Some searches returned irrelevant material; those results are not evidence of nonexistence.

No unpublished opinion, party argument, headnote or search snippet is used as law. No operative administrative rule was relied upon without its body being read. The missing interpretation is a research gap, not an identified inaccessible decision whose contents are presumed.

P01 E05/E06 and the coordinator’s review history are supplied historical context, not fresh public-source readings. P02/P04 operational and registration conclusions were not used to establish fee earning.

J. Atomic claim register

“High—text” means the retrieved wording directly supports the claim, within the source-version limits. “Conditional” means application depends on stipulated or missing facts. “Held” identifies an unresolved interpretation.

K. Granular coverage and remaining evidence

L. Researcher self-check and final disposition

Actually read: The complete §332A.13 body; necessary Chapter 332A definitions, agreement, cancellation, records, prohibitions and rescission provisions; the material 2007 and 2008 fee/funds enactments; selected 2009 historical amendments; targeted 2026 index entries; the current Commerce adjustment notice; fresh operative federal definitions, debt-relief fee/account conditions and exemptions; and the Commission’s DMP-specific final-rule explanation. The relevant official Federal Register PDF pages were visually inspected.

Not established: A controlling Minnesota interpretation approving a genuinely separate fee-only initial payment, an exception allowing $95 from a $300 ordinary periodic payment, a universal definition of maintenance earning in missed or irregular months, a complete historical 2009 date chain, or exhaustive later-law/rule/case coverage. No actual contract, account or provider record was supplied or examined.

The ledgers distinguish available custody cash, fee transfers, creditor credits and debtor returns. Their calculations were checked; their legal assumptions remain explicit. No local artifact or publication is claimed.

Bottom line: Both origination and maintenance can fit within one initial periodic payment when the combined retention limit is respected. The $1,000 model demonstrates that without inventing an exception. The $300/$95 proposal does not. A separate fee-only transfer remains an unresolved legal classification, not an accounting workaround. Federal DMP timing must be tested on the DMP’s actual structure, while Minnesota’s fee, custody, distribution and cancellation requirements continue independently.

No component, state, parent, operational, publication or A066 acceptance is implied.

END S_MN PASS-06