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

S_MS PASS-03 — Mississippi consumer-money custody, escrow, processor, and return component

Fresh public-source access: October 25, 2026, Pacific / October 26, 2026, UTC. Relationship to prior work: focused continuation of S_MS PASS-01 and PASS-02. Their supported findings, examples, IDs, and access limits remain preserved. This is not an independent review and does not reopen the provider-fee menu, federal overview, § 81-22-3(c)(xi) interpretation, or failed official HB 1265 routes.

Component conclusion

Mississippi’s debt-management statute imposes a short-cycle creditor-payment architecture on a covered provider that receives consumer money: deposit the money within two business days into a federally insured escrow account for the consumer’s benefit, keep consumer-level records, keep escrow separate from provider operating accounts, and remit the money to creditors within fifteen business days. It also requires correction of provider-caused misdirection and reimbursement of resulting actual creditor charges. That structure does not read like authority for a licensed provider or its processor to accumulate creditor-payment principal for months. MS Banking & Consumer Finance+1

The statute reaches more than literal possession. Debt-management service includes arranging payments and exercising or arranging direct or indirect control over consumer funds. Its processor definition reaches an entity that holds, has access to, can effectuate possession of, distributes, or participates in the chain of distribution of consumer money. A “consumer-owned,” “dedicated,” “escrow,” “FBO,” or “independent” account label therefore does not answer the Mississippi classification question; the actual access, instruction, transfer, withdrawal, affiliate, and contract rights must be examined. LegiScan+1

Chapter 22 gives the consumer a written cancellation right, but the relevant clauses read for this pass do not state a general Mississippi deadline for returning remaining principal after cancellation, a failed plan, a rejected settlement, provider cessation, or account closure. The federal seven-business-day return rule applies only when the Telemarketing Sales Rule and all of its dedicated-account conditions apply. Mississippi’s separate Money Transmission Modernization Act may supply a conditional ten-day refund rule, but only if that separate statute covers the entity and transaction and none of its refund exclusions or exceptions applies. MS Banking & Consumer Finance+3

A. Substantive findings

1. Account-model and control matrix

The 2026 carried-forward text preserves the broad direct/indirect-control definition, the complete § 81-22-9 custody duties, and the processor definition and architecture. DBCF’s official 2026 summary supports continuation of Chapter 22 after July 1, 2026, while the complete official signed/current-codification chain remains held as described in PASS-02. LegiScan+2

2. Chapter 22 custody, escrow, and ledger requirements

2.1 Receipt and deposit

For money received from or on behalf of a consumer for payment to creditors, the provider must deposit all such money:

• Within two business days of receipt.
• Into a federally insured escrow account.
• For the benefit of the consumer.
• In a supervised financial organization. MS Banking & Consumer Finance

2.2 What the statute expressly protects

The escrow account is expressly:

• Free from trustee process.
• Unavailable to creditors of the debt-management provider. MS Banking & Consumer Finance

Those words do not, without additional authority, establish:

• Immunity from a consumer’s own judgment creditors.
• Immunity from garnishment directed at the consumer.
• Immunity from bank setoff.
• Federal deposit-insurance pass-through to every consumer subledger.
• Bankruptcy ownership or priority beyond the statutory wording.
• Protection from processor creditors.
• NCUA rather than FDIC eligibility.
• A particular bank-account title.
• Consumer ownership of interest.
• A required Mississippi bank location.

“Supervised financial organization” is not defined in the Chapter 22 definitions actually read. No published DBCF construction resolving the institution or insurance mechanics was located in this pass. S_MS-P3-C009, C034.

2.3 Segregation and individual accounting

The provider must maintain a separate record of account for each consumer and cannot commingle consumer-benefit escrow accounts with the provider’s operating accounts. The text does not expressly require a different bank account number for every consumer; a pooled escrow with accurate consumer subledgers is not textually foreclosed, but that is a limited textual inference, not approval of any actual pooled structure. MS Banking & Consumer Finance

At least quarterly, the provider must give the consumer a written report accounting for:

• Funds received for obligations listed in the agreement.
• Disbursements to each listed creditor since the preceding report. MS Banking & Consumer Finance

The provider must keep compliance books, accounts, and records separate from its other businesses and retain each consumer’s records for six years after the final transaction. MS Banking & Consumer Finance

The statute does not expressly prescribe, in the clauses read:

• Daily reconciliation.
• A daily positive-pay or zero-balance test.
• A shortage-cure deadline.
• Consumer online access.
• Monthly rather than quarterly statements.
• Pending-ACH treatment.
• Check-clearing assumptions.
• Reversal or chargeback allocation.
• Interest allocation.
• An express permission to deduct provider fees from creditor-payment principal.

A fee deduction therefore requires an independently lawful fee, valid agreement authority, and actual earning/timing support. A ledger entry or available balance is not itself legal permission to withdraw the fee.

2.4 Creditor remittance

The provider must remit money received from or for the consumer to creditors within fifteen business days of receipt. The wording is tied to receipt of funds, not creditor acceptance of a proposal or settlement success. MS Banking & Consumer Finance

For direct custody, this prevents treating the account as an open-ended settlement reserve. If an amount is being held for many months, the operator must establish a different lawful characterization and account architecture rather than relying on the ordinary § 81-22-9 creditor-payment escrow provision.

The statute does not define:

• Whether “receipt” means initiation, provisional credit, settled funds, or collected funds.
• How rejected or reversed ACH entries affect the clock.
• How weekends and financial-institution holidays are counted beyond “business days.”
• Whether a consumer’s post-receipt written instruction to suspend payment changes the original deadline.

Those questions remain held.

2.5 Misdirected payments

If the provider causes a payment to be misdirected, it must:

1. Correct or remedy the misdirection; and
2. Reimburse the consumer for actual costs or fees imposed by a creditor because of that misdirection. MS Banking & Consumer Finance

This is not automatically a command to pay the consumer the misdirected principal as an additional cash refund. The provider must correct the principal movement and separately reimburse proven resulting creditor charges without double-paying the same amount.

2.6 Fair-share credits

Where the provider receives creditor “fair share” contributions, its records must show that the consumer received credit for the full amount of the payment due, not the amount net of the creditor’s contribution. Verification may be through the creditor’s statement or a monthly or quarterly consumer statement. MS Banking & Consumer Finance

3. Chapter 22 processor architecture

3.1 Functional processor definition

A statutory third-party payment processor is an entity that, under contract with the licensee:

• Holds consumer money.
• Has access to it.
• Can effectuate possession of it by any means.
• Distributes it.
• Is in the chain of distribution to creditors. LegiScan

Entities that solely provide electronic routing and settlement, and their sponsoring banks, are excluded from that definition. “Solely” matters: account administration, transfer discretion, payee control, custody, fee withdrawal, or funds-release authority may move an entity beyond that narrow description.

3.2 Ten-day notice and disclosed information

Before using a processor, § 81-22-28 requires ten days’ written notice to DBCF. The notice must include:

• Processor name and address.
• Description of services.
• Contract or agreement.
• Highest daily amount of consumer funds to be held or transmitted.

On request, the processor must provide the prior month’s highest daily amount held or transmitted. LegiScan

The literal subsection says money of “another licensee’s consumers.” The same unusual wording appears in the 2026 carried-forward reproduction. No published interpretation was located explaining whether that wording limits the subsection, refers to consumers assigned among licensees, or reflects drafting language. It should be preserved rather than silently rewritten as “the licensee’s consumers.”

3.3 Security and pre-use confirmations

The processor must ordinarily file:

• A $50,000 surety bond for the first licensee.
• An additional $50,000 for each additional licensee.
• A maximum required processor bond of $150,000.

Cash, a certificate of deposit, or government bonds may be filed instead. A licensee may not use the processor until it receives DBCF’s written confirmation that the department has received the processor’s bond or substitute assets. MS Banking & Consumer Finance+1

Before services begin, the processor must also:

• Authorize DBCF in writing to examine money-related books, records, documents, and electronic material.
• Receive DBCF’s written confirmation that the authorization is sufficient.

The licensee pays the examination cost. If the licensee itself elected the statutory cash, CD, or government-bond alternative, subsection (7) removes the processor’s separate bond/deposit requirement. MS Banking & Consumer Finance+1

This pass traces those amounts only to explain the custody architecture. Beneficiaries, bond-claim procedure, aggregate recovery, cancellation, priority, and consumer claim rights remain for the full bond pass.

3.4 Contract termination

Every processor contract must require thirty days’ written termination notice to the party being terminated. The licensee must immediately notify DBCF in writing when termination notice is given. LegiScan

Section 81-22-28 does not itself state:

• A consumer-notice deadline.
• A migration protocol.
• A deadline to return processor-held principal.
• A successor-processor procedure.
• A bank-account closure process.
• A continuing reconciliation or statement schedule after notice.
• A processor insolvency waterfall.

Those matters require the contract, bank agreement, other statutes, and later remedies/bond work.

3.5 Provider responsibility is not displaced

Section 81-22-9 places the deposit, remittance, accounting, commingling, and misdirection duties on the debt-management provider. Section 81-22-28 regulates use of a processor but does not expressly transfer or eliminate those provider duties. Whether the provider is contractually or legally responsible for every processor-caused loss, reversal, cyber event, or unauthorized transfer remains a later agency, contract, and remedies issue; the provider cannot establish compliance merely by pointing to the processor. MS Banking & Consumer Finance+1

DBCF’s current application page reinforces the operational importance of that relationship by requiring the applicant to submit third-party servicing/outsourcing contracts and a narrative explaining how client payments will be processed. Those application materials support procedure, not approval of a specific structure. MS Banking & Consumer Finance

4. Cancellation, termination, failed plans, cessation, and returns

4.1 Consumer cancellation

The agreement must state that either party may cancel by written notice. It must also identify the federally insured institution, list covered obligations and creditors, state the scheduled consumer remittances and creditor payments, and authorize disclosure of escrow records to DBCF during an examination. MS Banking & Consumer Finance

The cancellation clause does not specify:

• When cancellation becomes effective.
• Whether notice is effective on sending or receipt.
• Whether scheduled payments already transmitted can be recalled.
• Whether pending creditor payments should be completed or returned.
• A general deadline for returning remaining principal.
• A statutory fee-proration or refund formula.
• A required form of return.
• A required recipient when a creditor payment is already committed.

Therefore, cancellation of the service, revocation of ACH authorization, closure of a bank account, and return of held money are distinct legal and operational events.

4.2 Rejected proposal or failed plan

Chapter 22 does not supply a special “settlement rejected” or “plan failed” exception to the fifteen-business-day remittance rule. For money already received as creditor-payment principal, ordinary remittance duties remain facially applicable unless the consumer’s authorization is lawfully changed, the money is returned under another applicable rule, or another primary authority changes the result. MS Banking & Consumer Finance

The absence of an express Chapter 22 return deadline is not a universal no-return rule. It means the answer may depend on:

• Account ownership and custody.
• Consumer instructions.
• Pending or completed payment commitments.
• Contract terms.
• The money-transmission statute.
• The federal dedicated-account rule.
• General contract, restitution, consumer-protection, insolvency, and remedies law reserved for later passes.

4.3 Provider insolvency or regulatory cessation

A Chapter 22 licensee must report a bankruptcy or reorganization filing to DBCF within fifteen days, and insolvency is a statutory ground for suspension or revocation. The clauses read do not provide a complete consumer-funds wind-down, transfer, or distribution procedure. MS Banking & Consumer Finance+1

No Chapter 22 clause read establishes:

• A one-day or seven-day consumer notice.
• Automatic account freezing.
• Appointment of a successor servicer.
• A consumer-principal distribution waterfall.
• Priority over a processor’s creditors.
• Treatment of pending electronic items.
• Return of unearned fees.
• A bond draw on insolvency.

Those remain open.

4.4 Federal dedicated-account return

Only when the TSR applies and the account satisfies every condition in § 310.4(a)(5)(ii):

• It is at an insured financial institution.
• The customer owns the funds and any accrued interest.
• The administrator is not owned, controlled by, or affiliated with the debt-relief service.
• No referral compensation is exchanged.
• The customer may withdraw from the debt-relief service at any time without penalty.

The customer must then receive all account money other than fees actually earned in compliance with every element of § 310.4(a)(5)(i)(A)–(C), within seven business days after the request. eCFR

This does not:

• Establish that every Mississippi debt service is telemarketing.
• Establish that § 81-22-3(c)(xi) is satisfied.
• Resolve whether the provider receives, holds, or indirectly controls Mississippi funds.
• Permit subtraction of a contracted but unearned fee.
• Authorize switching between the proportional and savings methods.
• Mean the bank account itself must be closed.
• Automatically revoke ACH instructions or stop an already completed creditor payment.

5. Separate Mississippi money-transmission gateway

5.1 Why the gateway matters

Mississippi’s Money Transmission Modernization Act defines money transmission to include receiving money or monetary value for transmission from a person located in Mississippi. A person may not conduct, advertise, solicit, or hold itself out as conducting money transmission unless licensed, acting within a written authorized-delegate appointment, or within a statutory exemption. MS Banking & Consumer Finance+1

A Chapter 22 processor notice, bond, or DBCF confirmation is not listed as a Title 75-16 exemption. A processor can therefore require two separate analyses:

1. Chapter 22 processor architecture; and
2. Title 75-16 license, authorized-delegate, or exemption status.

A debt-management provider exclusion also does not automatically pass through to its account administrator, processor, affiliate, or ACH operator.

5.2 Material exemptions

The potentially relevant exemptions are narrow:

5.3 Authorized-delegate architecture

Under the current-readable 2026 amendment text, a money-transmitter licensee must have policies, perform a risk-based background review, and execute a written delegate contract. The contract must:

• Appoint the delegate to transmit on the licensee’s behalf.
• Define the relationship, rights, and duties.
• Require legal compliance.
• Govern remittance and handling.
• Impose a trust, net of fees, for the benefit of the licensee.
• Require records.
• Consent to examination.
• Recognize DBCF’s authority over the designation. LegiScan

The delegate:

• Holds money net of fees in trust for the licensee.
• Is subject to a statutory trust amount even if it commingles the money with its own property.
• Cannot use a subdelegate.
• Must immediately stop acting as delegate when the principal license is suspended, revoked, surrendered, or expires.
• Must be notified by the licensee, with documentation to DBCF, within five business days of such a license event. LegiScan+1

That trust is not the same as Chapter 22’s consumer-benefit escrow and does not establish consumer ownership, federal deposit insurance, or a direct consumer claim.

5.4 Records and reconciliation

A money-transmitter licensee must retain for at least five years:

• Each money-transmission obligation.
• A monthly-posted general ledger.
• Bank statements and bank-reconciliation records.
• Records of outstanding obligations.
• Records of obligations paid.
• Its authorized-delegate list.

Out-of-state records must be made accessible to the commissioner on seven business days’ written notice, and the records are open to inspection. MS Banking & Consumer Finance

Those duties are more specific about general ledgers and bank reconciliation than Chapter 22’s consumer-funds provisions. They apply only if the money-transmission statute covers the entity.

5.5 Timely transmission and refunds

A covered money-transmitter licensee must forward money according to the sender agreement unless it reasonably suspects fraud, crime, or another legal violation. If it does not forward the money, it must generally answer the sender’s inquiry unless legally prohibited. MS Banking & Consumer Finance

The refund provision generally requires refund to the sender within ten days after a sufficient written request, unless:

• The transaction is subject to the federal Remittance Rule.
• The money was received under a written licensee-payee agreement to process payment for goods or services.
• The money has been forwarded within ten days after receipt.
• Instructions have committed an equivalent amount within that period.
• The agreement specifies later transmission and the later time has not arrived.
• There is a reasonable crime or legal-violation basis.
• The request does not identify the sender or transaction sufficiently. MS Banking & Consumer Finance+1

Whether payment of an existing debt under a creditor-processing agreement falls within the “goods or services” exclusion was not resolved. The wording must not be assumed to include or exclude every debt payment.

5.6 Receipts and current delegate disclosures

For covered personal, family, or household money transmission outside the specified exceptions, the licensee or delegate must give a retainable receipt with sender, recipient, date, transaction ID, licensee/NMLS/contact information, amount, fees, and taxes. MS Banking & Consumer Finance

Effective July 1, 2026, an authorized delegate must prominently identify itself and each principal licensee, state that it acts as agent for the licensee, provide complaint information, and display the prescribed fraud warning. DBCF published both a June 12, 2026 implementation memorandum and Form 001. MS Banking & Consumer Finance+3

5.7 Money-transmitter permissible investments and statutory trust

A money-transmitter licensee must maintain permissible investments with market value at least equal to all outstanding money-transmission obligations. In specified insolvency, bankruptcy, receivership, dissolution, reorganization, or nonbeneficiary-creditor events, those investments are held in statutory trust for purchasers and holders of outstanding obligations, protected from nonbeneficiary attachment, and administered pro rata and equitably across applicable states. MS Banking & Consumer Finance+2

This is not:

• An ordinary-times consumer-owned bank account.
• A guarantee that every obligation is paid in full.
• Proof of deposit insurance.
• A Chapter 22 escrow substitute.
• A determination of claims, administration costs, multistate allocation, or priority among competing legal rights.

6. Reconciliation of the state and federal account rules

B. Bounded ledger examples

Unless stated otherwise, each example assumes no interest, pending checks, pending ACH transfers, reversals, chargebacks, returned items, bank holds, or unrecorded transactions. Calculations use dollars and cents. They demonstrate ledger consequences, not provider approval or complete legal liability.

Ledger 1 — direct provider custody and the fifteen-business-day clock

Inputs

Plain text

Consumer creditor-payment money received:       $1,000.00
Completed lawful creditor remittance:               700.00
Provider fee withdrawn from this principal:           0.00
Pending/reversed items assumed:                        0.00

Current held principal

Plain text

$1,000.00 - $700.00 = $300.00

Result

• The original $1,000 must be placed in the qualifying escrow within two business days.
• The remaining $300 is still consumer creditor-payment principal.
• In the ordinary custody model, the remaining $300 must be remitted within the original fifteen-business-day receipt period.
• Cancellation before that deadline changes the required factual analysis, but Chapter 22 does not itself supply a general return deadline or recipient rule.
• If, separately, this is a qualifying TSR dedicated account and the consumer withdraws with no earned fee, the conditional federal return amount is $300 within seven business days. MS Banking & Consumer Finance+1

Ledger 2 — current balance already reflects prior lawful earnings

Inputs

Plain text

Confirmed current held balance:                    $495.00
Prior creditor remittances:        already reflected in $495
Prior fee assumed lawfully earned
and already deducted:                              $180.00
Additional unpaid earned fee:                        $0.00
Pending/reversed items:                              $0.00

Return candidate

Plain text

$495.00 - $0.00 = $495.00

Result

The return candidate is $495, not $315 and not $420. Deducting the prior $180 again would double-subtract it. Substituting the $75 setup ceiling for the assumed prior fee would improperly reopen the prior transaction and create a fictional $420 result. The state return timing remains held; the conditional TSR deadline would be seven business days if all federal account predicates apply.

Ledger 3 — provider-caused misdirection

Inputs

Plain text

Consumer money received:                           $800.00
Sent to intended creditor:                          300.00
Sent by provider error to wrong creditor:            500.00
Current cash still held:                               0.00
Actual late fee imposed by intended creditor:         35.00

Ledger

Plain text

Principal requiring correction/remedy:              $500.00
Separate actual creditor-fee reimbursement:           35.00

Result

The provider must correct or remedy the $500 misdirection and reimburse the $35 actual creditor charge. The statute does not automatically require a $535 cash payment to the consumer in addition to correcting the $500 transfer. The correction path must avoid double payment. MS Banking & Consumer Finance

Ledger 4 — pooled escrow and consumer subledgers

Book balance

Plain text

Consumer A subledger:                             $1,200.00
Consumer B subledger:                              3,300.00
All other consumer subledgers:                     5,500.00
                                                   --------
Total consumer subledgers:                       $10,000.00
Bank escrow balance:                              10,000.00
Difference:                                           $0.00

This is numerically reconciled. It does not by itself establish deposit insurance, legal title, valid pending-item treatment, correct creditor allocations, or overall compliance.

Shortage variant

Plain text

Total consumer subledgers:                       $10,000.00
Actual bank balance:                               9,850.00
                                                   --------
Unexplained shortage:                               $150.00

The reviewed Chapter 22 provisions require separate consumer records and no operating-account commingling but do not specify a shortage-cure deadline. The $150 discrepancy therefore requires immediate factual reconciliation, while the exact statutory remedy remains outside this component. MS Banking & Consumer Finance+1

Ledger 5 — consumer-owned dedicated account with provider instructions

Inputs

Plain text

Consumer deposits:                               $1,500.00
Completed creditor transfer:                        900.00
Current account balance:                             600.00
Lawfully earned but unpaid fee:                        0.00

Classification

If the provider or affiliate can instruct the administrator to transfer the $900, select payees, release money, redirect a transfer, or trigger a fee debit, the consumer-owned label does not eliminate possible indirect control or processor-chain status.

Conditional federal withdrawal

Plain text

$600.00 - $0.00 = $600.00

If all TSR account conditions and federal coverage apply, the consumer receives $600 within seven business days after withdrawing from the service. Mississippi’s separate control, receipt, holding, and exclusion questions remain unresolved. LegiScan+2

Ledger 6 — conditional money-transmitter refund

Assumptions

• Entity is a covered licensed money transmitter.
• Transaction is not within the federal Remittance Rule.
• No written licensee-payee goods/services processing exclusion applies.
• Sender submits a sufficient written request.
• No money has been forwarded.
• No equivalent amount has been committed.
• No later-forwarding agreement or crime exception applies.

Plain text

Money received for transmission:                    $900.00
Forwarded or committed:                                0.00
Refund due under assumptions:                       $900.00

Result: $900 within ten days after receipt of the written request. If the money was forwarded or equivalently committed within the statutory period, or an exclusion applies, that result changes. MS Banking & Consumer Finance

Ledger 7 — fair-share contribution

Plain text

Consumer payment due to creditor:                   $400.00
Amount remitted and credited to consumer:            400.00
Separate voluntary creditor contribution
paid to provider:                                     20.00
Correct consumer credit:                             400.00
Incorrect net consumer credit:                       380.00

The consumer must receive the full $400 account credit. The separate $20 creditor contribution cannot reduce the consumer’s credited payment. MS Banking & Consumer Finance

Ledger 8 — money-transmitter permissible-investment shortfall

Inputs

Plain text

Aggregate outstanding obligations:              $100,000.00
Market value of permissible investments:          95,000.00
                                                  ----------
Statutory coverage shortfall:                       5,000.00

Assume, solely for arithmetic, a triggering insolvency event and one qualifying holder with a $1,000 obligation:

Plain text

Holder share = $1,000 ÷ $100,000 = 1%
Illustrative gross pro-rata share = 1% × $95,000
                                 = $950.00

The statute requires investments at least equal to outstanding obligations, so the $5,000 shortfall fails the numeric requirement. The $950 figure is only a simplified gross pro-rata illustration; actual claim allowance, asset valuation, letters of credit, multistate allocation, administration expenses, recoveries, and priority remain unresolved. MS Banking & Consumer Finance+1

C. PASS-03 source register

D. PASS-03 claim register

D.1 Chapter 22 custody and processor claims

D.2 Money-transmission and federal-overlay claims

E. PASS-03 component coverage and gap table

F. Researcher self-check

Actually read in this pass

• The complete relevant carried-forward portions of the 2026 HB 1265 “As Sent to Governor” reproduction: §§ 81-22-3, -9, -11, -15, -25, and -28.
• The complete corresponding clauses in DBCF’s thirteen-page historical Chapter 22 compilation, including visual page inspection.
• DBCF’s official 2026 legislative summary for HB 1265 and HB 1596.
• The complete materially relied-on sections of the DBCF-hosted seventy-five-page HB 1428 SG:Definitions.Exemptions.Licensing gateway.Event reports.Records.Authorized-delegate architecture.Unauthorized activity.Timely transmission.Refunds.Receipts.Permissible investments and statutory trust.Transition and effective clauses.
• The relevant current-readable HB 1596 amendments to §§ 75-16-51, 75-16-65, and new § 75-16-89.
• DBCF’s June 12, 2026 authorized-delegate memorandum and Form 001, including visual inspection.
• The relevant DBCF application-page payment-processing requirements.
• Rule 1.3(6) and Rule 1.3(7)(a)–(d) on printed pages 5–6/PDF indices 4–5 of the organizational rules.
• The preserved operative federal dedicated-account clauses in 16 C.F.R. § 310.4(a)(5)(i)–(ii).

Reused with preserved limits

• PASS-02’s conclusion that Chapter 22 continuation after July 1, 2026 is strongly supported but the full official signed/current-codification chain remains incomplete.
• PASS-01/PASS-02 classifications, fee rules, federal coverage limitations, and prior examples.
• The for-profit exclusion continues to require for-profit status plus all statutory conditions. Nothing in this pass defines “regulated by the FTC,” turns the exclusion into a license, or establishes an unlimited-fee path.

Not read or not established

• No official signed HB 1265 image, complete official bill-status record, authenticated current-code page, or complete later-amendment chain was recovered. Previously failed HB 1265 routes were not retried.
• No actual provider, bank, processor, administrator, sponsoring-bank, ACH, NMLS, bond, or account record was examined.
• No private contract, consumer statement, ledger, bank statement, reconciliation, processor confirmation, or regulator examination report was accessed.
• No exhaustive administrative-order, declaratory-ruling, unpublished agency-letter, trial-court, bankruptcy-docket, or paid-citator search was performed.
• No published authoritative construction was located for “supervised financial organization,” independent dedicated accounts under § 81-22-9, or “another licensee’s consumers.”
• No FDIC or NCUA pass-through determination was made.
• No bankruptcy ownership, garnishment, bank-setoff, UCC, unclaimed-property, restitution, MCPA, or bond-priority conclusion was made.
• No conclusion was made about an actual provider’s or processor’s license, exemption, delegate status, solvency, custody, fee earning, or compliance.
• No application, filing, contact, account change, private-data access, site action, or publication action occurred.

Process

This was completed in the original regular Chat using public web research. No Deep Research, Work mode, Codex research generation, Chrome control, other Chat, API, purchase, CAPTCHA workaround, security bypass, filing, contact, private borrower data, or local-write/publication-readiness claim was used.

END S_MS PASS-03.