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

S_MS PASS-01 — Mississippi provider market access and consumer fees

Research/access date: October 24, 2026, Pacific. Earlier baseline: October 22, 2026 was treated only as the requested baseline, not as the current-verification date. Scope: Mississippi provider classification, market access, consumer fees, and materially necessary state/federal timing boundaries only. This is not the full Mississippi dossier.

Component conclusion

Mississippi has two materially different pathways:

1. A person that, for a fee or other consideration, receives or controls consumer funds, arranges their distribution, negotiates or settles obligations, or offers credit-improvement services is generally a covered debt management service provider. When dealing with Mississippi-resident consumers, the provider must hold a Mississippi license unless a statutory exclusion applies. Provider location is not the controlling fact. Justia Law+1
2. Mississippi expressly excludes a narrow category of for-profit providers from the provider definition, but only when all three conditions are met: the provider does not receive or hold consumer funds; does not receive a fee before the consumer approves a settlement; and is “regulated by the Federal Trade Commission.” That is a definitional exclusion—not a Mississippi license, registration, approval, or endorsement. The meaning of the FTC-regulation condition remains materially unresolved. Justia Law

For the licensed/covered branch, Mississippi uses a closed dollar-fee menu: $75 one-time setup, $30 monthly maintenance after free initial counseling, $15 individual or $25 joint credit-report charge, up to $50 for optional educational courses/products, and a narrowly qualified $50 bankruptcy consultation. The statute does not list a separate percentage-of-debt, percentage-of-savings, per-debt, or settlement-success fee. Justia Law

For a provider that truly satisfies the for-profit exclusion, Chapter 22 supplies no fee-amount formula or percentage ceiling. It supplies only the state exclusion’s delayed-receipt condition. That does not mean an unlimited fee is lawful: general consumer-protection, contract, attorney, credit-repair, and other potentially applicable laws remain unreviewed in this component.

When the federal Telemarketing Sales Rule applies, it independently prohibits both requesting and receiving the debt-relief fee until at least one debt has been altered through a valid agreement, the consumer has made at least one payment under that agreement, and the fee is allocated using one of the permitted methods. Mississippi settlement approval alone is not enough. eCFR+1

The Act remains effective. In 2026, HB 1265 removed the former July 1, 2026 repeal date, effective July 1, 2026. Mississippi Banking & Consumer Finance+1

A. Substantive findings

1. How Mississippi classifies the relevant conduct

Mississippi’s statutory definition is based on what the business actually does, not whether it calls itself credit counseling, debt resolution, legal services, financial wellness, payment processing, or settlement.

A.1 Classification matrix

The operative clauses separately reach custody, payment arrangement, indirect control, and negotiation. A provider therefore cannot avoid coverage merely by having the consumer pay creditors directly or by placing funds with a separate processor. Justia Law+1

A.2 Consumer versus commercial purpose

Chapter 22 repeatedly uses “consumer,” but the chapter materials read for this pass do not define that word or add an express “personal, family, or household” qualifier to “obligation.” The existence of an exclusion for bona fide trade or mercantile associations arranging debts with business establishments suggests that at least some business-related conduct was contemplated, but it does not establish a general rule for LLC debts, sole-proprietor debts, mixed-purpose cards, guarantees, or business credit.

Result: no commercial-purpose fee or market-access conclusion should be published from this pass. Obtain an official DBCF interpretation or controlling Mississippi decision before treating business debts as categorically included or excluded.

A.3 Resident and remote-provider nexus

Section 81-22-3(c) addresses services offered to a consumer “in this state,” while § 81-22-5 expressly forbids unlicensed activity with respect to consumers who are Mississippi residents. The clear case is therefore a remote provider offering covered services to a Mississippi resident: the provider’s out-of-state office does not eliminate the Mississippi license requirement. A nonresident temporarily located in Mississippi presents a narrower unresolved wording issue not needed for the ordinary market-access conclusion. Justia Law+1

2. Which models are licensed, prohibited, or excluded

Mississippi does not generally prohibit debt management or settlement as a business category. It uses a license-or-exclusion framework.

A.4 Core market-access results

A.5 The for-profit settlement exclusion

Section 81-22-3(c)(xi) requires all of the following:

1. For-profit status.
2. The provider does not receive or hold consumer funds.
3. The provider does not receive a fee before the consumer approves a settlement.
4. The provider is regulated by the FTC.

Failure of any condition leaves the business inside the provider definition unless another exclusion applies. Justia Law

Important limitations:

• This is not a special Mississippi debt-settlement license.
• It does not certify the provider’s contracts, advertising, fee amount, performance, or federal compliance.
• It does not say that every for-profit entity is “regulated by the FTC.”
• It does not define “settlement,” “approved,” or “regulated.”
• It does not say whether a noncustodial DMP concession qualifies as a “settlement.”
• It addresses receiving a fee, not expressly requesting one.
• It does not establish proportional allocation among multiple debts.

The phrase “regulated by the Federal Trade Commission” is the largest unresolved permission issue. No Mississippi regulation, published DBCF interpretation, or merits decision defining that phrase was located. General FTC Act jurisdiction, actual TSR coverage, and the Mississippi phrase should not be assumed to be coextensive.

A.6 Other statutory exclusions

These conditions appear in § 81-22-3(c)(i)-(x). Justia Law+1

A.7 Nonprofits

A nonprofit label is not an exclusion. The DBCF application page expressly asks a nonprofit applicant for its IRS exemption letter, which is operational evidence that nonprofits can be license applicants. The statute also confines the $50 bankruptcy consultation charge to a nonprofit credit-counseling agency approved under 11 U.S.C. § 111. Mississippi Banking & Consumer Finance+1

A genuinely free nonprofit service might fall outside the provider definition because no fee or other consideration is received. That conclusion cannot be made merely from “free to the consumer”: creditor fair-share contributions, affiliate compensation, grants tied to accounts, or other value may matter.

A.8 Attorneys

There are three attorney-related provisions, and they should not be collapsed into a blanket lawyer exemption. Two depend on work being performed incidentally or within lawful Mississippi law practice; the third refers to licensed attorneys engaged in lawful practice. The actual bar authorization, attorney-client relationship, scope of representation, supervision, fee recipient, nonlawyer ownership/fee sharing, and whether the debt service is genuinely legal practice remain factual questions.

In Rigsby, the Mississippi Court of Appeals described a Florida lawyer, a $75 action-plan fee, a $29 monthly retainer, and a separate company receiving and forwarding DMP payments. The court expressly treated the Debt Management Services Act violations and illegal-fee assertions as allegations and decided only the forum-selection dispute. It did not validate the lawyer arrangement or decide the licensing and fee merits. Justia Law+1

A.9 Original creditors and institutions

Mississippi does not reproduce the express original-creditor exclusion found in federal CROA. A creditor modifying only the debt owed directly to itself usually does not look like an “intermediary between a consumer and one or more creditors,” but that is a textual inference rather than a located Mississippi ruling. An affiliated settlement company, multi-creditor platform, separately compensated servicer, or provider marketing services to the consumer may produce a different result.

The institutional exclusion also should not be extended automatically to contractors, affiliates, lead generators, or law firms merely because a bank is somewhere in the transaction.

3. Consumer fees and fee bases

A.10 Covered/licensed-provider fee schedule

Section 81-22-13 states that a debt management provider may charge only the listed consumer fees. The current amounts carried forward after HB 1265 are:

A.11 Percentage, savings, settlement, and aggregate fees

For the licensed branch:

• No separate percentage-of-enrolled-debt fee appears.
• No percentage-of-savings fee appears.
• No per-creditor or per-settlement charge appears.
• No settlement-success charge appears.
• No debt-size-based aggregate ceiling appears.
• No CPI or other indexing clause appears.

Because § 81-22-13 says a provider may only charge the enumerated fees, a covered provider cannot use Chapter 22 as authority for an additional 15%, 20%, 25%, per-debt, or savings-based settlement fee. A business that wants such a fee cannot simply call itself licensed; it would have to establish that it is outside the provider definition, including every § 81-22-3(c)(xi) condition, and then satisfy all other applicable law.

For the excluded § 81-22-3(c)(xi) branch, Chapter 22 does not provide an amount cap, savings formula, proportional formula, or aggregate fee ceiling. This pass therefore does not establish a state-only lawful percentage. Any example using a percentage below is expressly conditional on the federal TSR and is not Mississippi approval of that amount.

A.12 Currentness and indexing

HB 1265 removed the former repeal provision and took effect July 1, 2026. DBCF describes the statutory change as removal of the repeal date, and the official bill search rendering identifies the carried-forward Debt Management Services Act. No amendment to the fee amounts or indexing formula was identified. Mississippi Banking & Consumer Finance+1

Accordingly:

• $75, $30, $15/$25, $50, and $50 are the verified fixed statutory maxima for this component.
• No annual inflation calculation should be performed.
• No historical DBCF chart or obsolete repeal heading should override the 2026 continuation legislation.

A.13 Fair-share contributions

A “fair share contribution” is a voluntary creditor payment to the licensee for collecting client funds. It is not one of the enumerated consumer fees. When a licensee participates in fair-share contributions, the consumer’s account must receive credit for the full payment due, not merely the net amount after the creditor contribution. Justia Law+1

Whether a creditor payment constitutes “other consideration” for determining provider status in a nominally free program was not interpreted by an authority located in this pass.

A.14 Provider/government charges are not consumer charges

The $750 initial license fee, $475 annual renewal fee, bond/deposit requirements, NMLS processing charges, examination fees, and late-renewal penalties are expenses of the provider or licensee. They are not additions to the consumer fee menu.

The 2026 renewal memo stated a $475 debt-management renewal charge, a $1 electronic-online-charge fee, and a then-current $120 NMLS company processing charge. Those are dated 2026-cycle amounts and should not be presented as the 2027 renewal schedule without a new memo. Mississippi Banking & Consumer Finance

4. When fees may be requested or received

A.15 Mississippi timing for a licensed provider

A covered provider may not perform debt management services until the consumer and provider have executed a written agreement. The agreement must describe the services, every consumer fee or contribution, the cancellation right, covered obligations, creditor information, and—in a custodial arrangement—the payment schedule and insured institution. Justia Law+1

Verified state timing rules:

• The initial counseling session must be free before a monthly maintenance fee is charged.
• Services cannot be performed before the written agreement.
• The setup-fee provision does not state a separate completion, earned-fee, or elapsed-time trigger.
• The credit-report fee is tied to obtaining the report but contains no more specific receipt date.
• The educational category must be optional.
• The bankruptcy consultation fee has entity and approval conditions.

The absence of a more specific Mississippi timing clause is not affirmative authorization to collect before performance where federal law or another state law applies.

A.16 Mississippi timing under the for-profit exclusion

To remain within § 81-22-3(c)(xi), the provider must not receive a fee before the consumer approves a settlement.

Consequences:

• Receiving an enrollment, setup, monthly, legal, or administrative fee before settlement approval defeats that exclusion condition.
• A provider that instead operates as a licensed provider may potentially charge the enumerated setup and monthly fees, but it does not thereby gain authority for an additional percentage success fee.
• “Settlement approved by the consumer” is not defined.
• The provision does not state whether one approved settlement permits receipt of the entire contracted fee.
• The provision does not prescribe allocation when multiple debts are enrolled.
• It does not expressly address a mere request for payment.

The FTC’s business guide explains, in the federal TSR context, that the creditor agreement must be written while the customer’s approval may occur orally. That staff guidance does not interpret Mississippi’s separate word “approved” and is not a binding Mississippi construction. Federal Trade Commission+1

A.17 Federal TSR timing—only when the TSR applies

The federal TSR defines a debt-relief service as a represented program that renegotiates, settles, or otherwise alters debt terms with one or more unsecured creditors or debt collectors. “Telemarketing” generally requires a plan, program, or campaign using more than one interstate telephone call to induce a purchase. eCFR+1

Ordinary inbound advertising and direct-mail exemptions do not exempt calls responding to debt-relief advertisements. Other exclusions and exemptions—including certain unsolicited calls, face-to-face transactions, and business-to-business calls—still require factual analysis. eCFR+2

When the debt-relief advance-fee rule applies, a seller or telemarketer may not request or receive a fee until:

1. At least one debt has been renegotiated, settled, reduced, or otherwise altered pursuant to a settlement agreement, DMP, or other valid agreement executed by the customer.
2. The customer has made at least one payment under that agreement.
3. For debts resolved individually, the fee uses either the proportional-enrolled-balance method or a uniform percentage-of-savings method. eCFR+1

Proportional method

Earned fee for debt=total contracted fee×that debt’s enrolled balanceall enrolled balances\text{Earned fee for debt}

\text{total contracted fee} \times \frac{\text{that debt's enrolled balance}} {\text{all enrolled balances}}Earned fee for debt=total contracted fee×all enrolled balancesthat debt’s enrolled balance​The balances are measured when the debts were enrolled.

Savings method

Savings=enrolled balance−amount actually paid to satisfy the debt\text{Savings}

\text{enrolled balance}

\text{amount actually paid to satisfy the debt}Savings=enrolled balance−amount actually paid to satisfy the debtEarned fee=uniform contracted savings percentage×savings\text{Earned fee}

\text{uniform contracted savings percentage} \times \text{savings}Earned fee=uniform contracted savings percentage×savingsThe percentage cannot change from one debt to another. eCFR

Dedicated accounts

The TSR permits requiring deposits into a dedicated account only if the account is at an insured institution; the customer owns the funds and interest; the account administrator is independent and unaffiliated; no referral compensation is exchanged; and the customer can withdraw without penalty and receive all funds other than properly earned fees within seven business days. eCFR+1

A TSR-compliant dedicated account does not automatically prove the Mississippi provider “does not receive or hold consumer funds.” The state phrase and the broader state control-of-funds language have not been authoritatively reconciled.

A.18 State and federal rules must be kept separate

Thus, the controlling operational rule for a covered telemarketing model is the later and more restrictive applicable trigger, not whichever rule permits collection first.

A.19 Credit-repair overlap

Mississippi’s own definition includes offering to improve a credit record, history, or rating. Separately, federal CROA generally covers a person using interstate commerce or the mails, for consideration, for the express or implied purpose of improving an individual consumer’s credit record, history, or rating or advising on such activity. Federal CROA excludes qualifying § 501(c)(3) nonprofits, creditors restructuring their own debts, and qualifying depository institutions and credit unions. U.S. Code

CROA prohibits charging or receiving consideration for an agreed credit-repair service before that service is fully performed. If telemarketing representations concern removing derogatory information or improving credit, the TSR’s separate credit-repair rule also requires expiration of the represented service period and a consumer report issued more than six months after the claimed result. These are separate from the debt-relief settlement trigger. eCFR+1

Beech involved allegations that a debt-forgiveness program would repair credit and improve the consumer’s score while charging $296.95 monthly. The court denied class certification based on individualized contract and Rule 23 problems; it did not adjudicate Mississippi Chapter 22 market access or validate the fees. Justia Law+2

5. Regulator permission, application, and public lookup

A.20 Issuing regulator and legal authority

The regulator is the Mississippi Department of Banking and Consumer Finance, Nonbank Division, acting through the Commissioner of Banking and Consumer Finance. Section 81-22-5 requires a license for covered activity involving Mississippi-resident consumers. The Commissioner must evaluate financial soundness, responsibility, insurance coverage, consumer education, character, and fitness before issuance. Action is due within 30 days after the application is accepted as complete, subject to the statutory hearing mechanism. Justia Law+1

A.21 Current public application procedure

DBCF currently directs debt-management applications and renewals through NMLS. Its published minimum requirements include:

• $750 initial application fee and $475 renewal fee.
• $50,000 surety bond, or $50,000 cash, certificate of deposit, or government bond in lieu.
• Most recent fiscal-year financial statement.
• Mississippi Secretary of State registration as required by law.
• Description of proposed transactions and activities.
• IRS exemption letter for a nonprofit applicant.
• Consumer agreement.
• Applicant fee schedule.
• Third-party servicing or outsourcing contracts.
• Narrative explaining how client payments are processed.
• Education/course/product list with costs.

The license period is January 1 through December 31 and is not prorated. Mississippi Banking & Consumer Finance+3

These instructions demonstrate a functioning licensing pathway. They do not override the statutory exclusions or establish that an applicant or named company has been approved.

A.22 Remote-provider access

The DBCF list dated February 10, 2026, and expressly current “as of 02/09/2026,” contains 28 licensee entries, most located outside Mississippi. It therefore confirms that Mississippi licenses remote providers rather than limiting the license to Mississippi offices. Mississippi Banking & Consumer Finance

The list is not current enough to establish anyone’s authority on October 24, 2026. A company could have surrendered, expired, been suspended, changed name, or been newly approved after February 9.

A.23 Public license verification

DBCF links to:

• Its own dated PDF list of debt-management licensees.
• NMLS for applications.
• NMLS Consumer Access for public license searches.

NMLS/CSBS describes Consumer Access as the public service for confirming whether a financial-services company or professional is authorized in a state. Nationwide Licensing System+1

The direct DBCF-linked Consumer Access route did not return a usable searchable company record through this research interface. No specific provider name or NMLS ID was supplied, so no provider-specific status conclusion is made. Current authorization must be verified in the company’s NMLS record and, where necessary, against a newly dated DBCF list or direct public agency record.

A.24 Regulation and examination material

Mississippi Administrative Code Title 5, Part 4, Rule 1.3(7) authorizes complaint investigation, voluntary compliance, Attorney General referral, reasonable regulations, licensee examinations, and investigation of suspected unlicensed activity. It provides a $300–$600 in-state-office examination charge plus actual expenses for records located outside Mississippi, generally no more than one examination in two years absent cause. Those are licensee examination costs, not consumer fees. Mississippi Secretary of State

No separate Mississippi administrative rule, bulletin, or published interpretation changing § 81-22-13’s consumer fee amounts or construing § 81-22-3(c)(xi) was located in the official resources searched.

6. Worked fee and boundary examples

These examples are illustrations of the verified structures, not provider approvals or legal opinions about a specific contract. Dollar calculations round to the nearest cent.

Example 1 — Licensed custodial DMP, first service month

Facts

• Mississippi-resident consumer.
• Provider is currently licensed.
• Four debts totaling $18,000.
• Free initial counseling completed.
• Written agreement executed.
• Individual credit report actually obtained.
• First monthly service period begins after counseling.
• No optional course or bankruptcy consultation.

Calculation

Plain text

One-time setup fee:                 $75.00
First monthly maintenance fee:      30.00
Individual credit-report fee:       15.00
                                   -------
First-cycle consumer fees:         $120.00

Result: maximum illustrated first-cycle fees are $120. The $18,000 balance and four-debt count do not increase the statutory caps. If the consumer separately elects qualifying optional education at the $50 maximum, the illustrated total becomes $170. Claims C021-C024. Justia Law+1

Example 2 — Lower-debt licensed DMP

Facts

Same lawful licensed structure, but enrolled debt is only $400.

Plain text

Setup:                              $75.00
First monthly maintenance:          30.00
Individual report:                  15.00
                                   -------
Total:                             $120.00

$120 ÷ $400 = 0.30 = 30%

Result: Chapter 22 does not supply a debt-relative aggregate cap that reduces the enumerated maxima merely because the debt is small. That does not establish that every $120 low-balance transaction is fair, nondeceptive, contractually earned, or lawful under other Mississippi law; those issues remain outside this pass.

Example 3 — Licensed DMP cancellation after three months

Assumptions

• Free counseling completed.
• Setup and report services occurred.
• Contract provides monthly fees only for months of active service.
• Written cancellation is delivered before month four.

Plain text

Setup fee:                          $75.00
Individual report:                  15.00
Three monthly fees: 3 × $30 =       90.00
                                   -------
Total previously charged:          $180.00
Fourth-month fee under assumption:   $0.00

Result: no fourth-month fee under the stated contract assumption. Mississippi requires the agreement to contain a written-cancellation right, but this pass did not locate a statutory refund or prorated-credit formula for the $180 already paid. Whether any portion must be returned depends on performance, contract terms, and other law. Claim C025. Justia Law

Example 4 — Excluded settlement model plus TSR proportional allocation

Facts

• Provider establishes every § 81-22-3(c)(xi) condition.
• TSR applies.
• Debt A enrolled balance: $6,000.
• Debt B enrolled balance: $4,000.
• Total enrolled balance: $10,000.
• Total contracted portfolio fee: $2,000.
• The $2,000 is illustrative, not a Mississippi ceiling or approval.
• Debt A is altered under a valid creditor agreement, consumer approves, and consumer makes the first payment.
• Debt B remains unresolved.
• No earlier fee was received.

Calculation

Plain text

Debt A proportion = $6,000 ÷ $10,000 = 0.60

Debt A earned fee = $2,000 × 0.60
                  = $1,200.00

Debt B fee now = $0.00

Potential remaining contract allocation:
$2,000 - $1,200 = $800.00

Result: under the federal proportional method, $1,200 is the maximum fee allocated to Debt A after all triggers. The remaining $800 cannot be collected merely because Debt A performed; it remains contingent on Debt B satisfying its own trigger. Claims C027-C031. eCFR+1

Example 5 — TSR savings method

Facts

• Debt A enrolled at $6,000.
• It is ultimately satisfied for $3,600.
• Contract uses 25% of savings for every individually resolved debt.
• Required agreement, approval, and first payment have occurred.

Calculation

Plain text

Savings = $6,000 - $3,600
        = $2,400

Earned fee = 25% × $2,400
           = $600.00

Result: $600 for Debt A. An unresolved Debt B produces no current fee. The 25% rate is illustrative and must be the same savings percentage applied to every debt under that fee method. It is not a Mississippi-established percentage cap. eCFR

Example 6 — Consumer approves settlement but makes no payment

Facts

• Consumer approves a creditor proposal.
• No payment has yet been made.
• TSR applies.

Plain text

Mississippi exclusion timing:
Consumer approval has occurred.

Federal TSR fee:
No first payment = $0.00 requestable or receivable.

Result: the applicable federal result is $0. Mississippi’s approval condition cannot be used to override the later federal trigger. If the TSR does not apply, Mississippi Chapter 22 alone does not answer the amount, portfolio allocation, or general-law validity of the fee.

Example 7 — Fee received before settlement approval

Facts

• For-profit settlement provider receives a $495 “enrollment” fee immediately.
• Provider does not hold settlement funds.
• No settlement has been approved.

Classification

Plain text

Noncustody condition:               Satisfied
Delayed-fee-receipt condition:      Failed
FTC-regulation condition:           Not reached / unresolved
Section 81-22-3(c)(xi) exclusion:   Not established

Result: the provider cannot rely on § 81-22-3(c)(xi). It falls back into the covered-provider analysis and would need a license unless another exclusion exists. A licensed provider might charge a setup fee only within the $75 statutory maximum; licensing does not authorize the $495 settlement enrollment fee.

Example 8 — Noncustodial DMP

Facts

• Consumer pays creditors directly.
• Provider negotiates lower rates and payment schedules.
• Provider charges $30 monthly.

Result: noncustody does not remove coverage. The provider is arranging payments and acting as an intermediary under § 81-22-3(b)(ii)/(iv). It needs a license unless it establishes every condition of an exclusion. The monthly fee can fit the licensed menu only after free counseling and subject to the written agreement. Whether a DMP concession constitutes a “settlement” for § 81-22-3(c)(xi) was not resolved. Justia Law+1

Example 9 — Lawyer label without established lawful-practice facts

Facts

• A national debt company negotiates the debts and collects fees.
• An out-of-state lawyer’s name appears in the agreement.
• No Mississippi bar status, actual representation, supervision, or lawful-practice facts are established.

Result: attorney exclusion is not established. Classification remains covered/held. Rigsby does not validate such a structure; its merits were not decided. Justia Law+1

Example 10 — Business-purpose obligation

Facts

• Borrower is an LLC.
• Debt financed business inventory.
• Provider proposes to negotiate a reduction.

Result: no lawful consumer-fee path is claimed from this pass. The undefined “consumer” boundary and business-purpose coverage must be resolved before applying the license or fee provisions. The federal TSR’s ordinary business-to-business exemption is a separate federal issue and does not resolve Mississippi coverage.

Example 11 — Prior-fee consistency under the proportional method

Use the same facts as Example 4. Debt A’s total permitted allocation is $1,200.

Case A: prior $500 was lawfully earned after the trigger

Plain text

Debt A total allocation:            $1,200
Previously earned/received:           500
                                    ------
Amount remaining for Debt A:          $700

The remaining $800 of the $2,000 contract fee still belongs only to Debt B’s contingent allocation.

Case B: prior $500 was taken before the trigger

The arithmetic $1,200 - $500 = $700 is numerically correct but does not cure the earlier violation. The provider may not retroactively characterize a prematurely received fee as lawful merely by taking only $700 later. The analysis must separately address:

• Numeric equality.
• Consistency of the allocation method.
• Whether the prior $500 was lawfully earned.
• Whether it was lawfully requested or received.
• Whether the state exclusion remained available.
• Any required remedy for the premature fee.

7. Component boundaries

This pass establishes a usable provider-access and fee framework, but it does not imply completion or acceptance of the full Mississippi dossier.

In particular:

• The Chapter 22 license is a real lawful pathway for covered businesses.
• Section 81-22-3(c)(xi) is a conditional exclusion, not a special settlement license.
• No named provider is declared currently authorized.
• No excluded provider’s percentage fee is declared lawful.
• No complete contract, bonding, funds, remedies, collection, secured-debt, limitation, local, tribal, or sector-specific analysis is supplied.

B. Source register

C. Claim register

C.1 Classification and exclusions

C.2 Licensing and state fees

C.3 Federal timing, processors, cases, and remaining verification

D. Scope coverage and gap register

E. Researcher self-check

Actually read

• The relevant statutory passages in the DBCF-hosted Mississippi Debt Management Services Act PDF, including definitions, licensing, funds, agreement, fees, reporting, enforcement framework, and processor provisions.
• The DBCF 2026 legislative update confirming HB 1265’s removal of the July 1, 2026 repeal date.
• The DBCF Consumer Finance application and licensing page.
• The complete one-page February 2026 debt-management licensee list.
• The relevant portions of the 2026 renewal memorandum.
• Mississippi Administrative Code Title 5, Part 4, Rule 1.3(7).
• The relevant opinions in Rigsby and Beech.
• The exact current eCFR debt-relief definition, telemarketing definition, advance-fee trigger, allocation clauses, dedicated-account safeguards, and relevant exemptions.
• The current federal CROA definition, exclusions, and advance-payment prohibition.
• The FTC business-guide passages used for limited approval/timing context.

Search-rendered or reconstructed locators, not fully opened

• Official Mississippi HB 1265 SG text: official search rendering was available, but direct PDF and HTML requests returned 502.
• Official 2018 HB 792 and 2022 HB 687 legislative pages: official search-rendered text/history was available, but full pages were not freshly opened.
• Those bill locators were not treated as if their complete text had been read. Current Chapter 22 status instead rests principally on the actually read DBCF 2026 enactment summary, with the agency-hosted statute text and carried-forward section text used for the operative provisions.

Not read or not verified

• No usable authenticated current Lexis section display was obtained from the Mississippi public-code link.
• No live NMLS company record was opened because no named provider or NMLS ID was supplied and the direct Consumer Access route did not expose a usable search through this interface.
• No nonpublic licensing file, examination report, application, bond, or regulator correspondence was accessed.
• No provider was contacted.
• No application was filed.
• No CAPTCHA or access control was bypassed.
• No exhaustive paid-database citator or docket search was performed.
• No unpublished DBCF interpretive letter or declaratory ruling was found.
• No conclusion was made about a named provider’s current license.
• No exact lawful percentage fee was inferred for the excluded branch.
• No current 2027 renewal memo was assumed from the dated 2026 memo.
• No full Mississippi remedies, contract, funds, bond, secured-debt, collection, local, tribal, or sector analysis was performed.

Process and mode

This research was completed in regular Chat using GPT-5.6 Sol Pro, the available quality-first fallback, with public web tools. No Deep Research, Work mode, Chrome control, other Chat, API, purchase, account change, private borrower data, contact, application, site change, or publication action was used.

This is not an independent review, provider authorization, qualified legal opinion, complete Mississippi dossier, or publication-readiness determination. No local file write is claimed.

END S_MS PASS-01.