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

SettleADebt S_MO PASS-02

Bounded correction and evidence reconciliation

Actual access date: October 24, 2026, Pacific time Actual mode/model: Regular Chat, GPT-5.6 Sol Pro Disposition: This correction preserves both original PASS-01 segments and their source history. It is not an independent review, whole-state acceptance, provider approval, filing program, or publication clearance.

1. Dedicated-account replacement

Replacement for P1 A4, C018 and C026

Missouri § 425.043.4 does not impose the same administrator-independence wording as the federal TSR. Missouri’s introductory clause literally refers to an account used for the adjuster’s “fees for payments” to creditors or collectors. That wording is preserved; this correction does not silently replace it with “fees and payments” or resolve whether the enacted wording contains an omission.

Missouri § 425.043.4(3) applies its nonaffiliation condition only “if the debt adjuster does not administer the account.” It therefore cannot be restated as an unconditional Missouri requirement for an independent administrator. At the same time, the conditional wording is not affirmative permission for self-administration: the statute simply does not state the conditions governing that branch. The covered federal rule is different: § 310.4(a)(5)(ii)(C) requires the entity administering the account to be unaffiliated with the debt-relief service without Missouri’s conditional opening. Missouri Revisor of Statutes+1

Missouri subsection 3 prohibits the adjuster from receiving a fee before the state conditions are met. The covered federal provision prohibits requesting or receiving a fee. Requiring money to be placed into a consumer-owned qualifying account is analytically separate from requesting or receiving the provider’s fee. No actual account administrator, account agreement, provider structure, sales channel or federal-coverage fact was examined; operational approval remains held. Missouri Revisor of Statutes+2

Exact state/federal account-condition matrix

The preserved E06 assumption remains unchanged: with $3,000 still held, no qualifying settlement, no earned fee and no other lawful charge or creditor disbursement assumed, the example showed $0 earned. PASS-02 does not add a cancellation offset.

2. Minimal replacement for MO-E05

The assumed 25% savings rate remains a contract input, not a Missouri fee ceiling.

The federal final-rule explanation also says that when a creditor requires one lump-sum payment, a provider cannot artificially divide that settlement and collect a fee after a merely partial payment. GovInfo

Exact remaining Missouri question: Does § 425.043.3(3)(b)’s reference to the amount “actually paid to satisfy” a debt permit a savings-based fee after the first payment under a bona fide installment settlement, using the total contractual settlement amount as the savings denominator, or must satisfaction/payment completion occur first? The next authoritative targets are a Missouri appellate decision, Division of Finance interpretation, formal AG opinion, operative rule or contemporaneous Missouri enactment history addressing that precise branch.

3. Federal source-attribution correction

Replacement for the federal portion of P1 C017

For a covered transaction, the operative rule text in 16 CFR § 310.4(a)(5)(i) prohibits requesting or receiving a fee until:

1. The seller or telemarketer has altered at least one debt pursuant to a settlement agreement, DMP or other valid contractual agreement executed by the customer;
2. The customer has made at least one payment under that agreement between the customer and creditor or collector; and
3. The complete proportional or uniform-savings allocation rule is satisfied.

The codified language does not itself say, in those terms, that the creditor’s agreement must be written while the customer may assent orally. That proposition must not be attributed directly to the CFR text. eCFR+1

Federal source layers

No conclusion is made here that a particular oral assent, electronic act or unsigned factual arrangement constitutes a valid agreement under the TSR, federal law or applicable state contract law. The correction is one of source attribution, not a newly recognized oral-agreement loophole. The July 2010 guide’s historical recordkeeping discussion is not adopted as a current record-retention rule in this pass.

4. Bond and public-form reconciliation

Replacement for the early A5 hold

The early PASS-01 statement that the bond amounts had not yet been read reflected the research state at that point in the first assembly. It was later superseded within PASS-01 by A6 and C023–C024 after the complete operative § 425.027 page was read. The later finding controls as to the statutory principal amounts and statutory beneficiaries:

• $50,000 if the applicant declares the operation will handle no consumer monies;
• $100,000 otherwise;
• statutory protection for debtors under either a DMP or DSP; and
• specified Division-director complaint and bond-claim powers.

That chronological reconciliation does not cure the separate operational-form, version, acceptance, renewal or registry gaps. Missouri Revisor of Statutes

Statute/agency/forms/version/gap matrix

No actual provider lookup, bond-file search, submission, filing-fee check, registry inspection, surety inquiry or Division contact was performed.

5. PASS-02 source register

Screenshots used to inspect the three PDFs are verification views of the same underlying documents, not additional independent authorities.

6. PASS-02 claim register

7. Focused correction-coverage table

8. Researcher self-check

Freshly read in PASS-02: the complete operative pages for Missouri §§ 425.043 and 425.027; the relevant operative eCFR subsections; selected July 2010 FTC Guide and October 2010 FAQ portions; relevant pages of the August 2010 Commission final-rule statement; the current Division debt-adjuster page; and both complete one-page public forms. All three PDFs were also visually inspected.

P1 history preserved: the P1 eCFR source had been explicitly reused from an earlier Oregon primary read. PASS-02’s fresh eCFR access is recorded as a new correction check and does not retroactively rewrite the P1 research history. The two Division forms had previously been links/gaps, not read authorities; their text was first substantively read here.

Search-only or discovery treatment: a narrow official-source search for the installment issue led to the Federal Register final-rule document. Search snippets, FTC complaints and stipulated orders returned during discovery were not added as claim authorities. No Missouri judicial or formal agency interpretation of incomplete installment settlements was located and read in this bounded pass.

Not read or verified: no executed bond, provider record, registry result, filing acceptance, current form revision certificate, filing fee schedule, alternate $50,000 form, renewal submission, Missouri regulation, formal Division interpretation, AG opinion, Missouri appellate decision, surety practice or private account agreement.

No application was submitted; no provider, regulator, surety, attorney or consumer was contacted. No Chrome control, Work mode, Deep Research, API, account change, private borrower data, local write or publication occurred. This remains a coordinator correction to the Missouri provider-access/fee component, not independent review, A066 acceptance, whole-state clearance or operational authorization.

END S_MO PASS-02