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

S_MT PASS-05 — Montana bond, insurance, and alternative-security component

Fresh research session: October 25, 2026, Pacific / October 26, 2026, UTC Actual model/mode: GPT-5.6 Sol Pro, regular Chat Relationship to prior work: Focused security component following saved P1–P3. This is not an independent review. The unreviewed P4 funds work is not treated as accepted authority or relied on for any conclusion here.

Component status: PARTIAL. The governing statutory amounts, core triggers, Part 20 bond-rule adoption, and Part 21 insurance checklist are established. The current official DMP application and bond form could not be fetched; therefore, current form-specific cancellation, claim-tail, aggregate-liability, surety-authorization, and any additional DMP liability/fidelity-insurance requirements remain held.

Executive findings

Montana uses two different security instruments:

1. A provider subject to the Montana Consumer Debt Management Services Act, Part 20, must obtain a surety bond for the benefit of consumers harmed by a Part 20 violation. The statute sets $50,000 for an applicant without a staffed Montana counseling office, and ARM 23.19.1002 makes the bond for an applicant with such an office the same. The qualified current result is therefore a $50,000 bond for either model. The bond is evidence required both for initial licensing and annual renewal. Montana Code Annotated+1
2. A qualifying noncustodial Part 21 debt-settlement provider must maintain insurance covering dishonesty, fraud, theft, and other misconduct by its directors, officers, employees, and agents. The insurer must be rated at least A- or equivalent by a nationally recognized rating organization; coverage must be at least $100,000; the deductible may not exceed $10,000; and replacement requires at least 30 days’ advance written notice to the attorney general. Montana Code Annotated+1

Those instruments are not interchangeable. A Part 21 provider cannot replace its required misconduct insurance with a surety bond merely because the bond amount is substantial. A Part 20 provider cannot rely on a Part 21 misconduct policy instead of its statutory bond.

No cash deposit, letter of credit, net-worth substitution, pledged account, certificate of deposit, blanket affiliate bond, or other alternative security was verified in the operative Part 20 statute, ARM 23.19.1002 text, Part 21 statute, or accessible official checklists. Because the complete current DMP application and bond form were inaccessible, the proper conclusion is no verified alternative, not that the department is legally forbidden from ever considering one.

A. Substantive answers

1. Covered models and security triggers

Part 20 — debt management and covered credit counseling

Part 20 applies to a person providing or offering DMPs to Montana residents. The central defined DMP is a written arrangement under which a credit counseling service receives consumer money for creditor distribution. “Person” includes a qualifying nonprofit organization. The exclusions for banks, escrow businesses, attorneys, CPAs, and debt collectors are activity- and status-dependent; a nonprofit label, attorney affiliation, remote headquarters, or processor relationship is not a security exemption by itself. Montana Code Annotated+1

A Part 20 applicant must show, for initial licensing and annual renewal, that it has obtained the required surety bond. The bond is for consumers harmed by violations of Part 20. Failure to satisfy this licensing condition permits the department to refuse, suspend, or revoke the license, although the statute does not establish that suspension occurs automatically at the instant a bond lapses. Montana Code Annotated

The previously preserved standalone-counseling qualification remains unchanged: genuinely standalone counseling that never crosses Part 20’s defined DMP-provider entry point may fall outside this bond requirement, but the historical agency response is not a universal safe harbor. A mixed provider that provides or offers DMPs cannot remove its counseling operations from the licensing and security framework merely by separating labels, staff, or webpages.

Part 21 — noncustodial settlement

Part 21 defines a settlement provider as a compensated provider that does not, in its usual and regular course, hold, receive, or disburse debtor funds in connection with settlement. It excludes an entity subject to Part 20. Thus, for the same entity, a properly classified Part 20 operation is not also a Part 21 provider merely because it negotiates creditor concessions. Montana Code Annotated

Part 21’s security is misconduct insurance—not a DMP surety bond. The security trigger attaches to the debt settlement provider, and the covered misconduct actors are expressly its directors, officers, employees, and agents. The statute does not expressly impose a separate $100,000 policy for every office, employee, agent, or consumer. Nor does it affirmatively state that one provider’s policy covers separately incorporated affiliates or contractors that are themselves providers.

Hybrid or third-party arrangements

A provider handling consumer funds may lose the factual predicate for Part 21, but that does not automatically confer a valid Part 20 license or make a $50,000 bond sufficient. Classification still depends on the actual services, contracts, custody, agency, and entity structure.

Likewise:

• A processor’s insurance does not necessarily satisfy the provider’s obligation.
• A parent-company policy does not necessarily cover each subsidiary.
• An “additional insured,” fidelity-bond, crime-policy, E&O, or blanket-bond label does not demonstrate that every statutorily required actor and risk is covered.
• An independent administrator does not remove the provider’s own Part 21 insurance obligation.
• An attorney or nonprofit connection does not establish an exclusion unless the complete statutory conditions are met.

Model-by-security matrix

Claims: S_MT-P5-C001–C008, C020–C022.

2. Exact Part 20 bond requirements

Amount

Section 30-14-2004(2)(d) provides that:

• The applicant must obtain a surety bond.
• It is for consumers harmed by violations of Part 20.
• Amount, form, and duration are otherwise as required by department rule.
• An applicant without a Montana office staffed by a counselor must post $50,000. Montana Code Annotated

ARM 23.19.1002 states that the bond for a provider with a staffed Montana office is the same as for a provider without one. Combined with the statutory $50,000 figure, that produces a $50,000 bond for both configurations. Legal Information Institute

No verified provision varies the bond by:

• Consumer count.
• Enrolled principal.
• Monthly receipts.
• Maximum trust balance.
• Number of locations.
• Number of counselors.
• Prior claims.
• Revenue.
• Net worth.
• Custodial volume.

No indexing, inflation adjustment, minimum-to-maximum sliding scale, department discretion above $50,000, or waiver appears in the read statute or ARM 23.19.1002 text.

Official rule history

The official December 2005 proposal designated the parity provision as New Rule II. The January 2006 adoption notice adopted Rules I through V, making changes only to Rules I and III; New Rule II was therefore adopted as proposed. The February 2006 transfer notice renumbered former ARM 2.61.1002 as ARM 23.19.1002. Montana SOS+2

The current official Montana rules index still identifies a “Bond Requirement” in the consumer-debt-management subchapter. Its current body returned HTTP 405. A current secondary compilation reproduces the original one-clause parity rule and records a January 27, 2006 effective date and February 10, 2006 transfer. Montana Administrative Rules+1

Currentness result: The $50,000 conclusion is strongly supported, but it remains official-body access qualified. Historical adoption plus the current index and matching current secondary text are not treated as a certified export of the complete 2026 ARM.

Applicant, locations, agents, and affiliates

The statute attaches the obligation to the license applicant. It does not expressly require:

• A separate bond for every location.
• A separate bond for every counselor or employee.
• One bond per trust account.
• One bond per affiliate.
• A parent guarantee.

The historical OCP-303 specimen identifies the licensed company as principal. Its first condition states that the bond runs to the State for consumers injured by violations committed by the licensee or an agent, including an agent managing a trust account. That is useful form-history evidence, but the current form was not authenticated. BondExchange+1

Surety qualification

Neither §30-14-2004 nor the retrieved text of ARM 23.19.1002 specifies:

• A minimum financial-strength rating.
• A named rating agency.
• An admitted-insurer requirement.
• Treasury-listing status.
• A Montana certificate of authority.
• Reinsurance requirements.

Those conditions may appear in the current form, general Montana insurance law, or internal filing review, but they were not established here. Requirements from Montana’s separate escrow or telemarketing bond statutes cannot be imported into the DMP bond by analogy.

DMP professional liability, E&O, fidelity, or crime insurance

No Part 20 statutory clause or verified ARM provision read in this pass requires separate professional-liability, E&O, fidelity, or crime insurance. Section 30-14-2013’s prohibition on charging for or providing credit insurance concerns a consumer credit product and is not a provider fidelity-insurance mandate. Montana Code Annotated

A commercial bond article claims that the DMP application requests “liability or fidelity” insurance, but the article is secondary and does not state a limit. The official A-301 application PDF returned HTTP 502, and no official searchable copy of that clause was recovered. That alleged operational requirement is therefore held, not accepted and not rejected. BondExchange

3. Exact Part 21 insurance requirements

Covered conduct and actors

The provider must maintain insurance for:

• Dishonesty.
• Fraud.
• Theft.
• Other misconduct.

The statutorily identified actors are directors, officers, employees, and agents. The insurer must be rated at least A- or equivalent by a nationally recognized rating organization. The provider must make proof available to the attorney general on request. Montana Code Annotated

The statute does not call this:

• A surety bond.
• Professional liability insurance.
• Errors-and-omissions insurance.
• A fidelity bond.
• Commercial crime insurance.
• Fiduciary liability insurance.
• General liability insurance.

A policy may be marketed under one of those labels, but legal sufficiency depends on whether its operative coverage meets §30-14-2102, not its product name.

The phrase “other misconduct” does not establish that every negligent act, contract breach, fee dispute, creditor failure, cyber incident, or settlement-performance loss is insured. Actual insuring agreements, definitions, exclusions, causation provisions, and endorsements are necessary.

Amount and deductible

The statutory requirements are:

Minimum coverage=$100,000\text{Minimum coverage} = $100{,}000Minimum coverage=$100,000Maximum deductible=$10,000\text{Maximum deductible} = $10{,}000Maximum deductible=$10,000The statute itself does not say whether $100,000 is:

• Per occurrence.
• Per claim.
• Per consumer.
• Per policy period.
• Annual aggregate.
• Shared among all insured actors.

The official OCP-801 checklist, revision 02/19, instructs applicants to prove $100,000 per occurrence with a deductible no greater than $10,000 per occurrence. It also requires the insurer name, rating agency, declarations page, and a description of prior claims alleging the specified misconduct. Montana Department of Justice+1

That form-level “per occurrence” language is meaningful operational evidence. It is not silently converted into a legislative amendment or a complete aggregate-limit rule. The checklist does not state whether an annual aggregate may equal $100,000, must exceed it, or may be absent.

Insurer and rating organization

The statute requires at least an A- or equivalent rating from a nationally recognized rating organization. It does not identify a specific organization such as A.M. Best, S&P, Moody’s, or Fitch. The checklist requires the applicant to name the rating agency. Montana Code Annotated+1

Neither the statute nor the checklist passage read here expressly states:

• That the insurer must be Montana-domiciled.
• That the insurer must be admitted in Montana.
• That surplus-lines coverage is prohibited or permitted.
• That a risk-retention group is acceptable.
• That self-insurance is acceptable.
• That a captive is acceptable.

General insurance-law questions remain outside this component unless an actual proposed policy makes them material.

Financial statement, filing charge, and security

The annual financial statement and $250 filing charge are separate from misconduct insurance. A financial statement is not alternative security, and payment of the filing charge does not satisfy the insurance requirement. Likewise, no minimum net worth was identified in §30-14-2102. Montana Code Annotated

4. Current applications, forms, and operational materials

Part 20 DMP route

The DOJ’s current search-rendered page, updated October 2, 2026, tells DMP applicants to submit a $50,000 surety-bond form completed by a bonding company. The direct page was inaccessible, so this is search-rendered operational evidence rather than a freshly opened application page. Montana Department of Justice+1

The official application route identified publicly was:

https://media.dojmt.gov/wp-content/uploads/A-301-Debt-Management-Licensing-Application.pdf

It returned HTTP 502. No content from that application is treated as read. (Invalid URL)

An older official bond route was:

https://files.doj.mt.gov/wp-content/uploads/2011/05/ocp-3031.pdf

It also returned HTTP 502. (Invalid URL)

A secondary-hosted image displays page 1 of an apparent official Debt Management Licensing Surety Bond, Form OCP-303, revision 09/14. It identifies:

• The company as principal.
• A bonding company as surety.
• The State of Montana as obligee.
• Consumers injured by violations as beneficiaries.
• Licensee and agent conduct, expressly including an agent managing a trust account.
• A surety cancellation provision using 90 days’ certified-mail notice to DOJ.
• A claim period extending two years after the licensee ceases to be licensed.

Only page 1 of 2 was recovered, and its current mandatory status was not authenticated. No current conclusion about signatures, power of attorney, aggregate liability, renewal, reinstatement, rider language, or page-2 conditions rests on that specimen. BondExchange

Part 21 settlement route

The current DOJ page’s search rendering links the Debt Settlement Application and Registration Checklist. The linked official OCP-801 PDF was directly opened; it is eight pages and marked revision 02/19. Insurance Verification appears on printed page 2, zero-based PDF index 1. Montana Department of Justice+2

The form requires:

• Yes/no confirmation of misconduct insurance.
• Insurer identity.
• Confirmation of an A- or equivalent rating.
• Rating-agency identity.
• Proof of $100,000 per-occurrence coverage.
• Proof of no more than a $10,000 per-occurrence deductible.
• A declarations page.
• Details of prior misconduct claims, including date, nature, amount, and disposition or pending status. Montana Department of Justice+1

No separate official policy specimen, mandatory endorsement, certificate form, cancellation rider, replacement rider, claims form, or proof-of-loss form was found. OCP-801 requests evidence; it is not itself the insurance contract.

5. Commencement, continuity, replacement, lapse, and claims

Part 20 bond timing

The applicant must provide evidence of the bond to obtain and annually renew the license. The bond is therefore a recurring qualification, not a one-time launch document. Montana Code Annotated

The operative statute does not provide a numeric cancellation-notice period. The historical OCP-303 specimen uses a 90-day period after certified-mail notice to DOJ. Because the current form was not recovered, that 90-day term is a historical form condition, not certified 2026 form text. BondExchange

If the bond ends without compliant replacement:

• The provider no longer has evidence of a required licensing condition.
• The department may refuse, suspend, or revoke under §30-14-2004(4).
• No automatic suspension date, cure period, emergency continuation, or grace period was verified.
• No authority was found allowing consumer business to continue merely because cancellation notice remains pending. Montana Code Annotated

Part 21 insurance timing

The command is to maintain coverage. That indicates continuing coverage rather than proof only on the annual filing date. If the coverage is being replaced, the provider must provide the attorney general at least 30 days’ advance written notice. Montana Code Annotated

The statute does not expressly provide:

• A replacement grace period.
• A cancellation or nonrenewal notice period where no replacement is arranged.
• A provider-to-consumer notice.
• A policy tail.
• An extended reporting period.
• A run-off policy requirement.
• Automatic registration expiration or suspension.
• Retroactive-date requirements.

A gap between policies is not cured merely because the provider sent a replacement notice. The obligation is to maintain the insurance.

Occurrence versus claims-made

Neither §30-14-2102 nor OCP-801 identifies the policy as occurrence-made or claims-made. The checklist’s “per occurrence” limit language does not necessarily determine when a claim must be made or reported.

The following remain policy-dependent:

• Definition of “occurrence.”
• Related-acts aggregation.
• Discovery period.
• Retroactive date.
• Notice of circumstances.
• Claims-made reporting deadline.
• Tail coverage.
• Prior-acts exclusion.
• Pending-and-prior-litigation exclusion.

Who may claim on the Part 20 bond

The statutory bond is expressly for the benefit of consumers harmed by Part 20 violations. Separately, §30-14-2015 allows a person harmed by a Part 20 violation to sue the violator for actual and consequential damages or $500, whichever is greater, and allows equitable and class relief. That statutory action against the violator is not automatically the same as a direct action against the surety. Montana Code Annotated+1

The historical OCP-303 specimen says a claim must be made with the surety within two years after the licensee ceases to be licensed. It does not, on the recovered page, resolve:

• Whether filing directly with the surety is the exclusive route.
• Whether the State must be joined.
• Whether a civil judgment against the principal is required first.
• Whether claims may be assigned.
• Required proof-of-loss contents.
• Surety investigation deadlines.
• Claimant priority.
• Pro rata distribution after exhaustion.
• Replenishment after a paid claim.
• Annual versus continuous aggregate liability.

Those questions remain held.

Who may claim under Part 21 insurance

Section 30-14-2102 does not identify the consumer as:

• The named insured.
• An additional insured.
• A loss payee.
• A third-party beneficiary.
• A person with a statutory direct action against the insurer.

Section 30-14-2104 allows the attorney general or county attorney to bring enforcement actions and gives debtors the remedies available under Montana consumer-protection law and other state law. It does not state that an insurer must pay a debtor directly or waive policy defenses. Montana Code Annotated

Accordingly, the statutory requirement to maintain insurance does not itself guarantee that:

• A particular consumer may present a direct claim.
• Every adjudicated provider liability is insured.
• Restitution is within coverage.
• Civil penalties or fee refunds are covered.
• The insurer is solvent.
• The provider pays the deductible.
• A limit remains unexhausted.

Policy wording and actual claim facts are indispensable.

Cases and orders

Targeted searches were performed using:

• 30-14-2004
• 30-14-2102
• “Debt Management Licensing Surety Bond”
• “for the benefit of consumers harmed”
• “dishonesty, fraud, theft, and other misconduct”
• OCP-303
• The historical bond’s trust-account-agent language

Searches were directed to Montana court, judicial-document, DOJ, and public case-law domains. No decision or administrative order interpreting these particular bond or insurance clauses was located. This is a bounded search result, not proof that no responsive case, sealed matter, district-court decision, settlement, or unpublished order exists. No complete paid citator or all-county docket review was performed.

B. Amount, event, and recovery-boundary matrix

C. Bounded security examples

All figures are U.S. dollars. Arithmetic is exact to the cent. Each example assumes a valid claimant, covered conduct, timely compliance, a solvent issuer, and no applicable exclusion only where expressly stated. None guarantees recovery or approves a provider.

Example 1 — One valid Part 20 bond claim

Assumptions

• Provider is subject to Part 20.
• Current valid bond amount: $50,000.
• A consumer establishes a covered bond loss of $18,000.
• No competing claims.
• No form defense or exclusion.
• The current bond permits payment.

Calculation:

$50,000−$18,000=$32,000$50{,}000 - $18{,}000 = $32{,}000$50,000−$18,000=$32,000The consumer’s established loss is below the face amount. The potential payment is $18,000.

The remaining $32,000 is not established as legally restored or available for future claims, because current aggregate and replenishment terms were not verified.

No deductible was identified in the Part 20 statute or rule. A surety’s separate indemnity rights against the provider do not create a consumer deductible.

Example 2 — Multiple Part 20 claims and conditional aggregate

Hypothetical valid claims

• Consumer A: $12,000.
• Consumer B: $20,000.
• Consumer C: $25,000.

Total:

$12,000+$20,000+$25,000=$57,000$12{,}000 + $20{,}000 + $25{,}000 = $57{,}000$12,000+$20,000+$25,000=$57,000Illustrative assumption only: the current bond’s aggregate liability for all claims is limited to its $50,000 penal sum.

Then:

$57,000−$50,000=$7,000$57{,}000 - $50{,}000 = $7{,}000$57,000−$50,000=$7,000At least $7,000 lies outside the assumed bond aggregate. It may remain provider liability under other law, but recovery is not guaranteed.

This example does not decide:

• Which claimant is paid first.
• Whether payments are pro rata.
• Whether the bond replenishes at renewal.
• Whether each license year creates a separate aggregate.
• Whether related claims are combined.

Those questions require the current complete bond.

Example 3 — Part 21 deductible on a $60,000 loss

Assumptions

• Covered misconduct loss: $60,000.
• Applicable occurrence limit: $100,000.
• Applicable deductible: $10,000.
• Policy makes the provider responsible for the deductible.
• No exclusion or defense.

Potential insurer amount:

$60,000−$10,000=$50,000$60{,}000 - $10{,}000 = $50{,}000$60,000−$10,000=$50,000Potential provider-retained amount:

$10,000$10{,}000$10,000Total addressed:

$50,000+$10,000=$60,000$50{,}000 + $10{,}000 = $60{,}000$50,000+$10,000=$60,000The statutory deductible ceiling does not itself say who advances or ultimately bears the $10,000. That is an explicit policy and liability assumption.

Example 4 — Loss above the Part 21 per-occurrence form limit

Assumptions

• Covered loss: $130,000.
• $100,000 per-occurrence limit from OCP-801.
• $10,000 deductible.
• Insurer’s maximum payment is calculated after applying the deductible.
• No larger umbrella or excess policy.

Amount after deductible:

$130,000−$10,000=$120,000$130{,}000 - $10{,}000 = $120{,}000$130,000−$10,000=$120,000Insurer maximum:

min⁡($120,000, $100,000)=$100,000\min($120{,}000,\ $100{,}000)=$100{,}000min($120,000, $100,000)=$100,000Amount not funded by that policy:

$130,000−$100,000=$30,000$130{,}000 - $100{,}000 = $30{,}000$130,000−$100,000=$30,000That $30,000 consists of the assumed $10,000 deductible plus $20,000 above the assumed policy limit. Provider liability and actual recovery remain separate questions.

Example 5 — Multiple Part 21 occurrences and unknown aggregate

Hypothetical covered occurrences

• Occurrence A loss: $90,000.
• Occurrence B loss: $80,000.
• Deductible per occurrence: $10,000.

After deductibles:

$90,000−$10,000=$80,000$90{,}000-$10{,}000=$80{,}000$90,000−$10,000=$80,000$80,000−$10,000=$70,000$80{,}000-$10{,}000=$70{,}000$80,000−$10,000=$70,000Combined insurer-side calculation before any aggregate:

$80,000+$70,000=$150,000$80{,}000+$70{,}000=$150{,}000$80,000+$70,000=$150,000Branch 1 — no separate annual aggregate below that amount: potential insurer payments total $150,000.

Branch 2 — policy has a $100,000 annual aggregate: potential insurer payments are capped at $100,000, leaving:

$150,000−$100,000=$50,000$150{,}000-$100{,}000=$50{,}000$150,000−$100,000=$50,000outside the assumed aggregate, in addition to the two $10,000 deductibles already removed.

Montana’s statute and the checklist passage do not resolve which branch is correct.

Example 6 — Part 21 replacement notice and continuity

Use relative days rather than a calendar-count assumption.

• Day 0: provider gives written replacement notice to the attorney general.
• Day 20: old policy terminates.
• Day 30: new policy begins.

Although 30 days’ notice preceded the replacement date, there is a 10-day coverage gap:

30−20=10 days30-20=10\text{ days}30−20=10 daysBecause the statute requires the provider to maintain coverage, notice alone does not make the gap compliant.

A continuity-preserving illustration would keep the old policy effective through the new policy’s commencement, subject to actual policy times, cancellation provisions, and regulator treatment.

Example 7 — Part 20 historical cancellation condition

Historical-form assumption only

• Day 0: surety sends the specimen’s required certified-mail cancellation notice.
• Day 90: cancellation becomes effective under the 2014 specimen.
• Replacement bond becomes effective on Day 90 with no timing gap.

This avoids an arithmetic gap:

90−90=0 days90-90=0\text{ days}90−90=0 daysIt does not prove the current form still uses 90 days or that the agency would accept a replacement becoming effective at the last instant. If replacement instead begins Day 95, the gap is:

95−90=5 days95-90=5\text{ days}95−90=5 daysDuring that five-day interval, the provider lacks established compliance with the bond condition. Exact suspension, cessation, and cure consequences remain unresolved.

Example 8 — Custodial versus noncustodial security

Model A: covered DMP

• Provider receives consumer funds for creditor distribution.
• Part 20 applies absent an actual exclusion.
• Required security: qualified $50,000 consumer-benefit surety bond.

Model B: qualifying noncustodial settlement

• Provider negotiates settlement but does not ordinarily hold, receive, or disburse settlement principal.
• Part 21 applies absent an actual exclusion.
• Required security: $100,000 minimum misconduct insurance, deductible no more than $10,000.

A $100,000 Part 21 insurance policy does not replace Model A’s $50,000 surety bond. A $50,000 bond does not replace Model B’s insurance.

D. PASS-05 source table

E. PASS-05 claim table

F. Component coverage and gap table

G. Researcher self-check

Freshly and directly read

• Official 2025 MCA §§30-14-2002, 2003, 2004, 2013, and 2015.
• Official 2025 MCA §§30-14-2101, 2102, and 2104.
• The bounded official Montana Administrative Register pages containing:New Rule II proposal.Adoption of Rules I–V.Transfer and renumbering to ARM 23.19.1002.
• The complete relevant insurance page of official OCP-801, revision 02/19, with PDF screenshots.
• Current secondary text of ARM 23.19.1002.
• Current DOJ search-rendered operational instructions concerning the $50,000 DMP bond form.

Freshly accessed but failed or incomplete

• Current official ARM consumer-debt-management body: HTTP 405.
• Current official A-301 DMP application: HTTP 502.
• Former official OCP-303 bond PDF: HTTP 502.
• Direct current DOJ debt-management/debt-settlement page: inaccessible; only official search rendering was usable.
• Only page 1 of 2 of a secondary-hosted historical OCP-303 specimen was available.

Discovery-only or secondary material not treated as controlling

• BondExchange’s claims about DMP liability/fidelity insurance, premiums, underwriting, power of attorney, and commercial bond practices.
• Surety-company marketing descriptions.
• Search-result descriptions of current filing routes.
• The 2014 OCP-303 image as current-form proof.
• Any provider marketing statement or claimed license number.

Reused without changing prior provenance

• P1 C009’s original official 2025 §30-14-2102 read.
• P1–P3 provider-access, fee, scope, and date-correction findings.
• The qualified P2 standalone-counseling reconciliation.
• Historical P1/P2 source, claim, coverage, and example tables.

No prior access date was retroactively changed or reclassified as a fresh PASS-05 reading.

Not read or resolved

• Complete current official ARM bodies and any unpublished license conditions.
• Current complete DMP application and bond form.
• Any actual insurer policy, declaration, endorsement, binder, cancellation notice, surety power of attorney, indemnity agreement, or claim file.
• Any named provider’s bond, policy, license, registration, or claim history.
• Complete general Montana insurance law concerning admitted carriers, surplus lines, direct actions, insurer liquidation, or surety authorization.
• A complete Montana appellate/district-court citator or all-county docket review.
• A comprehensive post-2025 legislative and special-session audit.
• Full remedies, bond recovery litigation, bankruptcy, priority, collection, limitations, or contract analysis.
• P4’s unreviewed funds interpretations.

Exact individual source-fetch timestamps were not exposed and are not invented. No application, filing, quote, purchase, insurer contact, regulator contact, account change, private-data access, Chrome control, local write, provider approval, operational approval, independent review, component acceptance, Montana acceptance, parent-dossier acceptance, A066 acceptance, or publication-readiness determination occurred.

REPORT PARTIAL — the focused Montana bond, insurance, and alternative-security component is completed to the expressly stated source and access limits.

END S_MT PASS-05