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

S_MS PASS-02 — focused precision and currentness addendum

Actual research/access date: October 25, 2026, America/Los_Angeles. Relationship to PASS-01: bounded correction only. PASS-01 remains preserved except for the replacement language, source-use qualifications, and claim/coverage deltas below. This is not an independent review, a full Mississippi audit, provider approval, state acceptance, parent-project acceptance, or A066 acceptance.

1. Exact federal timing replacements

Replacement for A.19 and S_MS-P1-C037

When the Telemarketing Sales Rule applies to goods or services represented as removing derogatory information from, or improving, a person’s credit history, credit record, or credit rating, 16 C.F.R. § 310.4(a)(2) prohibits requesting or receiving payment until both conditions have been satisfied:

1. The entire period during which the seller represented that all of the goods or services would be provided has expired; and
2. The seller has provided the person documentation in the form of a consumer report from a consumer reporting agency demonstrating that the promised results were achieved, and that report was issued more than six months after those results were achieved.

The rule also expressly preserves the Fair Credit Reporting Act requirement that a consumer report may be obtained only for a specified permissible purpose. This is a conditional federal telemarketing rule—not universal credit-repair coverage, not Mississippi fee authority, and not a determination that CROA applies to every debt-relief representation. The separate CROA definitions, exclusions, and full-performance issue preserved in PASS-01 remain unresolved as applied to any particular model. The eCFR text was freshly read on October 25, 2026; it displayed Title 16 as current through October 22, 2026. eCFR+2

Replacement for S_MS-P1-C030

When 16 C.F.R. § 310.4(a)(5) applies, a seller or telemarketer may not request or receive a debt-relief fee until:

• The seller or telemarketer has renegotiated, settled, reduced, or otherwise altered at least one debt pursuant to a settlement agreement, debt-management plan, or other valid contractual agreement executed by the customer;
• The customer has made at least one payment pursuant to that agreement between the customer and the creditor or debt collector; and
• To the extent enrolled debts are altered individually, the fee satisfies the complete proportional-balance or uniform-percentage-of-savings allocation requirements in § 310.4(a)(5)(i)(C).

This remains conditional federal timing. It does not establish universal TSR coverage, Mississippi permission to charge a fee, or satisfaction of Mississippi’s separate for-profit exclusion. eCFR+2

Example preservation: E01–E03 remain state-only numerical illustrations and do not establish federal earning or collection timing where the TSR, CROA, or another rule independently applies. E04–E11 and all arithmetic remain unchanged.

2. HB 1265 currentness follow-up

Bounded conclusion

The present record strongly supports the qualified conclusion that the Mississippi Debt Management Services Act did not expire on July 1, 2026. The Mississippi Department of Banking and Consumer Finance’s actually read 2026 legislative summary states that HB 1265 removed the July 1, 2026 repeal date and became effective from and after July 1, 2026. The summary is an official agency enactment summary, although it is not the complete operative enrolled act. Its PDF metadata/title string referring to “2019” does not displace the document’s visible body heading, “Legislative Updates: 2026 Regular Session,” or its HB 1265 entry. MS Banking & Consumer Finance+1

Official Mississippi Legislature search rendering independently exposes the SG bill title and Section 1’s repeal of § 81-22-31; a separate official search result exposes the July 1, 2026 effective clause. The Legislature’s post-session summary search rendering also reports “Signed 3/30/26” and “Effective 7/1/26.” Those are official-domain search-rendered records, not a freshly opened status XML or signed enrolled image. Bill Status+3

The official SG PDF, SG HTML, and bill-history XML each returned 502 when directly opened on October 25, 2026. A full LegiScan-hosted reproduction, labeled “Enrolled” by the host while retaining the Legislature document heading “As Sent to Governor,” reproduces Section 1 repealing § 81-22-31, Section 3 bringing forward § 81-22-3, Section 8 bringing forward § 81-22-13, and Section 17 making the act effective July 1, 2026. That reproduction supports text comparison but is not itself an official signed session law, authenticated code page, or primary status record. LegiScan

Accordingly:

• Continuation after July 1, 2026 is strongly supported and is not held as wholly unknown.
• The exact complete current official codification of all Chapter 22 provisions has not been audited.
• No official signed/enrolled image, session-law chapter number, or usable primary bill-history/status record was recovered.
• This pass does not claim that no later amendment, order, regulation, or bulletin exists.
• Within the specifically compared text, the reproduced 2026 SG versions of § 81-22-3 and § 81-22-13 show no substantive change from the older DBCF compilation; that comparison is narrower than a complete official version audit.

Minimal version, effectiveness, and pinpoint matrix

Necessary § 81-22-3 and § 81-22-13 comparison

The complete LegiScan-hosted SG reproduction carries forward the relevant definitions and exclusions in § 81-22-3, including subsection (c)(xi), without an observed textual difference from the complete § 81-22-3 appearing in the older DBCF compilation. It likewise carries forward the complete fixed-fee text of § 81-22-13 without an observed textual difference from that older compilation. LegiScan+3

That comparison supports retaining P1’s classification and fixed-fee text. It does not establish that no legislation or regulatory action occurred after HB 1265, and it does not convert the old DBCF compilation into a current source.

3. Procedure and pinpoint qualifications

4. Focused PASS-02 source register

The FTC staff guide, CROA statutory provisions, Rigsby, and Beech remain evidence-backed P1 reuse exactly within their previously stated limits. They were not re-fetched or expanded in this correction and are not counted as newly read P2 authorities.

5. Focused claim delta table

P1 C009 and C011 are unchanged: the for-profit exclusion still requires for-profit status plus all three statutory conditions, and “regulated by the FTC” remains unresolved. Nothing in P2 converts the exclusion into a license, approval, or unlimited-fee pathway.

6. Focused coverage delta

Only the original P1 “Current effective status of Chapter 22” coverage row is replaced. The remaining entries below are P2 correction tracking, not a regeneration of the 41-row P1 coverage table.

7. Researcher self-check

Freshly read or refreshed in PASS-02

• The operative text of 16 C.F.R. § 310.4(a)(2) and § 310.4(a)(5)(i)(A)–(C), including the eCFR current-through display.
• The complete three-page DBCF 2026 legislative-update PDF, including visual inspection of its first page.
• The complete relevant §§ 81-22-3, -13, and -31 in the thirteen-page DBCF historical compilation, with visual inspection of the relevant pages.
• The full LegiScan-hosted HB 1265 SG reproduction.
• Rule 1.3(7)(a)–(d) on printed pages 5–6/PDF indices 4–5 of the twenty-page administrative PDF.
• The selected relevant first and second pages of the four-page 2026 renewal memo.
• The complete DBCF debt-management webpage body at lines 113–136.
• All 28 rows and the dated footer in the one-page February 2026 licensee list.

Search-rendered but not fully opened

• The official Mississippi Legislature HB 1265 SG PDF/HTML.
• The official 2026 Summary of General Legislation entry for HB 1265.
• The official search rendering supplied usable portions of the bill and official-summary status information, but those results were not treated as equivalent to reading a signed act or status record.

Directly attempted and inaccessible

• Official SG PDF: 502.
• Official SG HTML: 502.
• Official bill-history XML: 502.
• The supplied amendment-report failure was not repeatedly hammered.

Reused without a new PASS-02 fetch

• P1’s 2025 secondary code mirror.
• The previously coordinator-read FTC staff guide.
• The previously coordinator-read CROA §§ 1679a and 1679b materials.
• Rigsby and selected portions of Beech.
• Their prior limitations remain intact; none was upgraded to a fresh Mississippi read or a merits holding.

Process and mode

This addendum was completed in regular Chat using GPT-5.6 Sol Pro, the actual available quality-first model. No Deep Research, Work mode, Codex generation, Chrome control, browser-tab creation, API, purchase, account change, contact, private borrower data, application filing, site change, local-write claim, or publication action was used.

END S_MS PASS-02.