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

S_NE PASS-01 — Nebraska provider market access and consumer fees

Actual research/access date: October 24, 2026, Pacific time Execution: Regular Chat with public-web browsing; actual available model was GPT-5.6 Sol Pro under the authorized quality-first fallback. No Deep Research, Work, Chrome control, APIs, purchases, account changes, contacts, other chats, private borrower data, applications, or publication actions were used.

Component status: Substantive provider-access and consumer-fee research completed with explicit holds. This is not Nebraska-wide approval, a provider authorization opinion, A066 acceptance, or completion of the remaining Nebraska dossier.

Executive determination

Nebraska’s specific Debt Management Act is best read as a custodial debt-management statute, not as an all-purpose license for every business calling itself a debt-settlement company. Its definition requires both:

1. fee-based planning and management of a qualifying debtor’s financial affairs; and
2. receipt from that debtor of money or “evidences thereof” for distribution to creditors.

A business satisfying those elements must obtain a Nebraska Secretary of State debt-management license before operating. A licensed model may include creditor concessions and principal-reduction compromises; principal reduction does not move an otherwise covered custodial program outside the Act. Nebraska Legislature+2

The Act’s principal consumer-fee limit is:

Total contracted fee ≤ 15% × the amount of money agreed to be paid through the licensee.

That is not a verified 15%-of-enrolled-debt rule, a savings-based fee, or an across-the-board authorization for negotiation-only debt settlement. The fee must be amortized over the contract, a credited initial payment may not exceed $25, and cancellation compensation may not exceed 25% of the remaining unamortized contracted fee. Nebraska Legislature

A provider that negotiates but never receives or controls debtor funds appears, under the text’s conjunctive wording, to fall outside the specific Chapter 69 definition. But this investigation did not establish that such a model is affirmatively authorized in Nebraska. “Evidences thereof,” third-party dedicated-account control, payment authority, remote-provider nexus, and possible application of the Nebraska Credit Services Organization Act remain material classification questions. Federal TSR compliance does not create Nebraska permission.

Model disposition matrix

A. Substantive answers to the numbered scope

1. Definitions and classification

1.1 Nebraska “debt management”

Neb. Rev. Stat. §69-1201(1) defines debt management through a conjunctive set of activities:

• planning and managing the financial affairs of a debtor;
• for a fee from the debtor; and
• receiving from the debtor money or “evidences thereof” for distribution to creditors in payment or partial payment of obligations.

The qualifying “debtor” is a wage earner whose principal income comes from wages, salary, or commission. “Creditor” is framed in terms of a person for whose benefit money is collected and disbursed by the licensee. C001–C002. Nebraska Legislature

This produces four important boundaries:

1. Custody/distribution is part of the definition. Financial advice or negotiation alone does not plainly satisfy the entire definition.
2. A marketing label is not decisive. A business calling itself “credit counseling,” “debt resolution,” “debt settlement,” “financial wellness,” or “legal support” is covered if its actual conduct satisfies the statutory elements.
3. The statute does not separately define DMP and debt settlement. Those labels must be classified by actual conduct.
4. “Evidences thereof” creates an unresolved perimeter. No Nebraska court or official interpretation was located explaining whether it includes ACH authority, withdrawal authority, a payment instruction, control of a consumer-owned account, or another noncash instrument.

1.2 DMP and concession services

A conventional DMP in which the provider:

• performs a budget analysis,
• arranges creditor concessions,
• receives the consumer’s monthly payment, and
• remits funds to creditors

falls squarely within the Chapter 69 model. The Act requires a separate debtor-benefit account and generally requires remittance to creditors within 15 days—seven days for cash—with a maximum 35-day holding period where reasonable accumulation is needed. C001, C010. Nebraska Legislature+1

1.3 Principal-reduction settlement

Principal reduction is not excluded. Section 69-1213(5) expressly states that when a licensee arranges a compromise with one or more creditors, the debtor must receive the full benefit of the compromise. Thus, a custodial program does not cease being licensed debt management merely because it negotiates less-than-full-balance settlements rather than only interest or payment concessions. C003. Nebraska Legislature

That does not mean every negotiation-only settlement service is licensed under Chapter 69. The receipt/distribution element still has to be addressed.

1.4 Noncustodial negotiation-only service

The strongest textual reading of §69-1201 is that a provider that only negotiates and never receives debtor money or an “evidence thereof” for creditor distribution does not satisfy the whole Chapter 69 definition. This is an interpretation from the conjunctive text—not a located Nebraska judicial holding.

Accordingly:

• The Chapter 69 license and 15% fee formula cannot safely be treated as an affirmative license or fee authorization for that model.
• An independently administered, consumer-owned dedicated account may reduce custody risk, but the federal dedicated-account rule does not resolve Nebraska’s broader “evidences thereof” language.
• A provider’s contractual power to direct payments, approve disbursements, debit fees, replace the account administrator, or condition settlements on account balances could materially change the classification.
• No Nebraska court decision or Secretary of State interpretation resolving those facts was located.

Disposition: Chapter 69 coverage is uncertain to unlikely on a truly noncustodial fact pattern, but public market access remains held rather than approved. C007, C025, C031.

1.5 Conditional Credit Services Organization Act overlap

Nebraska separately defines a “credit services organization” as a person who, for payment and with respect to credit extended by others, provides or represents that it will provide:

• improvement of a buyer’s credit record, history, or rating;
• obtaining an extension of credit; or
• advice or assistance concerning either activity.

“Buyer” means an individual, and “extension of credit” is limited to credit primarily for personal, family, or household purposes. C018. Nebraska Legislature

Therefore, a noncustodial settlement provider does not automatically become a CSO merely because settlement may eventually affect a credit score. The trigger is the service actually provided or represented. Statements such as these would materially increase CSO/CROA risk:

• “We improve your credit.”
• “Our program repairs your credit history.”
• “We remove negative debt entries.”
• “We help you qualify for new credit.”
• “Enroll now so your score recovers.”

A debt-management licensee is expressly exempt from Nebraska’s CSO Act. Thus, a properly licensed Chapter 69 provider ordinarily does not need duplicate CSO registration for conduct within the debt-management license. C019. Nebraska Legislature

1.6 Consumer versus business purpose

The two Nebraska regimes use different boundaries:

• Debt Management Act: “debtor” is a wage earner whose principal income derives from wages, salary, or commission. The Act does not expressly say the obligations must be personal, family, or household debts. A business entity is not naturally a “wage earner,” but application to an individual’s business-purpose obligations was not resolved by a located decision. C002.
• CSO Act: the credit must be offered or granted primarily for personal, family, or household purposes, and the buyer must be an individual. C018.
• Federal TSR: telemarketing calls between a telemarketer and a business to induce a business purchase are generally exempt, subject to the rule’s stated exceptions. That federal provision does not determine Nebraska Chapter 69 coverage. eCFR

Hold: Do not categorically treat sole-proprietor or personally guaranteed business debt as included or excluded from Chapter 69 without fact-specific Nebraska analysis.

1.7 Nebraska resident and remote-provider nexus

The Act requires a license to engage in debt-management business “in this state,” but the reviewed statute does not provide an express resident-customer, internet solicitation, remote-office, or choice-of-law test. Section 69-1201 defines an “office” as each physical location where debt management occurs, while the application statute requests the exact office location. C008. Nebraska Legislature+1

The July 9, 2026 active roster contains many licensees with addresses outside Nebraska. That proves that out-of-state entities can and do use the Nebraska license. It does not independently prove the exact threshold at which an out-of-state company serving a Nebraska resident is deemed to conduct business “in this state.” Nebraska Secretary of State+2

Remote nexus remains unresolved. The conservative provider-access assumption is that delivering a covered custodial program to Nebraska wage earners creates licensing risk even without a Nebraska office, but this pass did not locate a controlling nexus interpretation.

2. Prohibited, licensed, registered, or exempt models

2.1 Covered debt management is licensed—not merely registered

Section 69-1203 makes it unlawful to engage in debt-management business without first obtaining the required license. Section 69-1205 directs the Secretary of State to investigate responsibility, experience, character, fitness, felony history, and prior defaults in accounting for money before issuing the license. Knowing or willful unlicensed operation is a Class II misdemeanor. C004. Nebraska Legislature+2

The principal licensing conditions relevant to this component include:

• written application to the Secretary of State;
• $200 main-office license fee within each county;
• $100 for each additional office;
• $200 initial investigation fee;
• $10,000 bond;
• filing a blank copy of the intended debtor contract;
• notice of contract changes within 30 days;
• expiration on December 31;
• renewal application by December 1 with a $100 renewal fee and bond;
• separate application for each office.

These are government/provider charges, not consumer-fee permissions. C016. Nebraska Legislature+1

2.2 Chapter 69 exemptions

The Act excludes the following only when they act in the regular course of their respective businesses or professions:

• attorneys at law;
• duly authorized/admitted banks, fiduciaries, financing institutions, and lending institutions performing credit and financial adjusting in the regular course of their principal business;
• title insurers and abstract companies while doing escrow business;
• employees of licensed debt managers; and
• judicial officers or others acting under court orders. C005. Nebraska Legislature

Important failures of exemption:

• There is no express nonprofit exemption in §69-1202.
• Forming a 501(c)(3) does not by itself exempt a custodial debt-management program.
• Having an attorney as owner, advisor, vendor, or nominal program participant does not establish that the business itself is an attorney acting in the regular course of the legal profession.
• A financial institution is not exempt for every affiliate or outsourced service merely because it has a regulated institution somewhere in the structure.
• The person asserting a CSO exemption bears the burden under that separate statute; Chapter 69 does not contain an equivalent burden clause, but its exemptions remain activity-limited. C005–C006.

2.3 Credit-services registration and bond

A covered Nebraska CSO must, before conducting business in the state:

• file a registration statement with the Secretary of State;
• disclose specified ownership and Nebraska governmental litigation/complaint information;
• update material registration information within 90 days;
• permit a buyer to inspect the registration;
• obtain a $100,000 surety bond or establish a qualifying $100,000 surety account; and
• provide the statutory precontract disclosure and written contract.

The Secretary may charge a filing fee up to $100. That is a government filing charge, not a consumer-fee cap. C020. Nebraska Legislature+3

2.4 CSO exemptions

The CSO Act exempts, among others:

• regulated lenders;
• insured banks and qualifying subsidiaries;
• credit unions;
• §501(c)(3) nonprofits;
• Nebraska real estate licensees within their licensed scope;
• attorneys licensed in Nebraska acting within their legal practice;
• specified securities professionals within scope;
• consumer reporting agencies;
• certain real-estate-secured lenders;
• Nebraska collection agencies and solicitors acting within their licensed scope; and
• Nebraska debt-management licensees.

The claimant bears the burden of proving the exemption. C019. Nebraska Legislature

2.5 Money-transmission crossover

Effective July 18, 2026, Nebraska’s Money Transmitters Act expressly exempts a person licensed in Nebraska and acting within the state within the scope of a:

• collection-agency license;
• CSO license/registration; or
• debt-management license.

That exemption does not establish that an unlicensed or out-of-scope settlement model is exempt from money-transmission regulation. It also does not answer whether a particular dedicated-account structure constitutes money transmission in the first place. C029. Nebraska Legislature+1

3. Applicable consumer fees and present limits

3.1 Licensed Chapter 69 debt-management fees

The operative fee language appears in §69-1212; the 36-month limit appears in §69-1209; the separate-account and remittance provisions appear in §§69-1210 and 69-1213; and prohibited fee forms and referrals appear in §69-1214. C009–C014, C034. Nebraska Legislature+4

3.2 Statutory base—not “enrolled debt”

The exact current statutory base is:

the amount of money agreed to be paid through the licensee.

No authority reviewed converts this into:

• gross enrolled balance;
• starting account balance;
• amount forgiven;
• amount saved;
• settlement amount when the settlement funds do not pass through the licensee; or
• a generic 15% fee for every Nebraska debt-settlement customer.

The statute does not expressly resolve whether “money agreed to be paid through the licensee” excludes the licensee’s own fee or means only creditor-bound funds. Sections 69-1201, 69-1210, and 69-1213 strongly associate the pass-through money with creditor distributions, but no controlling interpretation was located. The exact denominator should therefore be stated in the contract and treated conservatively. C011, C031.

3.3 No verified indexing or adjusted amounts

Section 69-1212 still states:

• 15%;
• $25 initial payment; and
• 25% of the remaining unamortized fee on cancellation.

The statute contains no CPI or periodic adjustment formula. No debt-management fee adjustment bulletin, order, or verified regulation changing those figures was located. The official dynamic rules catalog could not be fully retrieved through the permitted non-JavaScript route, so the narrower finding is:

• No statutory indexing exists.
• No current adjustment notice was verified.
• A categorical statement that no relevant regulation has ever existed remains held pending a fully accessible Title 433 and rulemaking-docket review. C015, C030.

The Nebraska Department of Banking and Finance consumer article saying settlement companies “often charge 15–25% of enrolled debt” is general educational content, not the Chapter 69 fee formula or a Nebraska fee authorization. C032. Nebraska Banking and Finance

3.4 Nebraska CSO fees

The Nebraska CSO Act does not provide a general consumer percentage or dollar cap.

Its state-law timing rules are:

1. For services other than obtaining credit, no money may be charged or received before all agreed services are completed unless the CSO has the required bond or surety account.
2. For obtaining or attempting to obtain credit, no money may be charged or received before the credit is obtained.
3. No fee may be charged solely for referring a buyer to a retail seller offering substantially the same credit generally available to the public.
4. No brokerage or other fee whatsoever may be charged in connection with a loan governed by the Nebraska Installment Loan and Sales Act.
5. The total cost and payment terms must be disclosed in the precontract statement and contract. C021. Nebraska Legislature+2

The state bond exception is not an answer to federal CROA or TSR advance-fee rules.

3.5 Nebraska CSO cancellation refund

A buyer may cancel a Nebraska CSO contract before midnight of the third day after signing. The Nebraska text says “third day,” not “third business day.” If the buyer cancels, the CSO must return any payment within ten days after receiving the cancellation notice. C022. Nebraska Legislature

Federal CROA separately provides a three-business-day period and bars the provision of services during that period. The stricter applicable requirement governs.

4. When fees may be requested or received

4.1 Nebraska Chapter 69 timing

A licensed debt manager is not entitled to a fee or charge until the debt-management program has been:

1. arranged; and
2. approved by the debtor.

The contract is not effective until the debtor makes a payment to the licensee for distribution to creditors. Fees must then be applied no faster than the contractual monthly amortization, subject to the credited initial-payment language. C014. Nebraska Legislature

The statute does not cleanly resolve the sequence between:

• the credited $25 initial payment;
• program arrangement and approval;
• the first creditor-distribution payment; and
• contract effectiveness.

A conservative implementation would not treat the $25 as earned before the program is arranged and approved, and would not treat the Chapter 69 contract as effective before a separate creditor-distribution payment occurs. Federal law may delay any fee still further.

4.2 Federal TSR debt-relief timing—separate common context

When the Telemarketing Sales Rule applies to the transaction, a seller or telemarketer may not request or receive a debt-relief fee until:

1. at least one debt has actually been renegotiated, settled, reduced, or otherwise altered under a settlement agreement, DMP, or other valid agreement executed by the customer;
2. the customer has made at least one payment under that agreement; and
3. for individually resolved debts, the fee is allocated using one consistent permitted method:the same proportional relationship as the debt’s enrolled amount bears to total enrolled debt; orthe same percentage of savings for every debt.

The two methods cannot be switched opportunistically from debt to debt. C023–C024. eCFR+1

The TSR’s definition reaches services represented to alter terms of unsecured debt, including balance, interest, or fees. Its telemarketing definition requires a plan, program, or campaign involving more than one interstate telephone call. Calls responding to general advertisements and direct mail do not receive the ordinary inbound-call exemption when the advertisement concerns debt-relief services. Business-to-business calls are separately treated. C023. eCFR+2

Accordingly:

• Nebraska’s $25 initial-payment provision is not federal advance-fee authorization.
• Nebraska’s monthly amortization does not permit a fee before the TSR trigger.
• After a TSR trigger, Nebraska’s monthly cap can remain the tighter limit.
• No authority was located allowing retroactive collection of several missed Nebraska monthly installments immediately after the first TSR trigger.

4.3 Federal dedicated accounts

The TSR permits a provider to require deposits into a dedicated account only when:

• funds are held at an insured institution;
• the customer owns the funds and receives any interest;
• the administrator is independent of the debt-relief service;
• no referral compensation is exchanged; and
• the customer can withdraw without penalty and receive all unearned funds within seven business days.

This federal safe structure does not establish that Nebraska will regard every such account as noncustodial. Nebraska’s “money or evidences thereof” language and the provider’s actual contractual authority remain decisive unresolved facts. C025. eCFR

4.4 Separate TSR credit-repair timing

Where the seller or telemarketer represents that it will remove derogatory information or improve a person’s credit history, record, or rating, 16 C.F.R. §310.4(a)(2) separately bars payment until:

• the represented service period has expired; and
• the seller has provided a consumer report demonstrating the promised result, issued more than six months after the result was achieved.

That is distinct from the debt-relief trigger in §310.4(a)(5). A business making both settlement and credit-improvement representations may need to satisfy both applicable branches rather than selecting the easier one. C026. eCFR

4.5 Federal CROA overlap

Federal CROA conditionally applies where a person uses interstate commerce or the mails, for payment, for an express or implied purpose of improving a consumer’s credit record, history, or rating—or provides advice concerning such improvement.

CROA:

• bars charging or receiving payment for an agreed service before that service is fully performed;
• requires a written contract;
• prohibits service during the first three business days;
• grants cancellation without penalty before midnight of the third business day; and
• contains specific exemptions, including qualifying §501(c)(3) nonprofits, a creditor restructuring its own debt, and depository institutions or credit unions and qualifying affiliates.

A Nebraska CSO bond does not create a federal CROA advance-fee exception. C027. U.S. Code+3

5. Actual regulator access, application, and lookup

5.1 Debt-management regulator and procedure

The issuing regulator is the Nebraska Secretary of State.

Its public Debt Management Agencies page links:

• the licensed-agency roster;
• license application;
• personal/corporate financial statement;
• officer interrogatory;
• bond form;
• branch-office application; and
• governing statutes. C017. Nebraska Secretary of State

The application form operationally requests entity and office information and supporting organizational documents, and reflects the statutory initial fee and investigation fee. The statute—not the form—is the controlling source of legal permission. Nebraska Secretary of State+1

5.2 Debt-management public roster

The opened roster is titled “Active Debt Management Agency Licensees,” dated July 9, 2026, and states that all listed licenses expire December 31, 2026. It contains both Nebraska and out-of-state addresses. C017. Nebraska Secretary of State+2

Limitations:

• It is a dated snapshot, not proven real-time status on October 24.
• It does not display license numbers or disciplinary history in the extracted fields.
• No named provider was submitted or tested.
• Presence on the roster establishes listed status as of the roster’s date—not permission for conduct outside the license’s scope.
• Absence from the roster should be rechecked against the agency’s current public record before making a provider-specific conclusion.

5.3 CSO regulator and lookup

The Secretary of State’s Credit Services Organizations page links the active registration roster, registration form, bond form, and statutes. The opened active roster is dated July 9, 2026. The registration form reflects the $100 filing fee and $100,000 bond/account structure. C020. Nebraska Secretary of State+4

Again, registration procedure is distinct from a conclusion that a particular company is currently registered or that its particular debt-settlement model is within the registration.

5.4 Rules and guidance status

The Secretary of State’s official index lists Title 433 as “Licensing Regulations.” Its current public licensing-guidance list names guidance for athlete agents, civil-litigation funding, collection-agency work-from-home operations, and private detectives; it does not list debt-management guidance. The February 19, 2026 annual index shows the same general structure. C030. Nebraska Secretary of State+2

However:

• the official Title 433 catalog and proposed-rule docket returned only a JavaScript shell through the permitted route;
• no API, Chrome-control workaround, or account action was used;
• several directly indexed Title 433 chapter documents were opened and identified as other licensing subjects, but a fully consolidated current Title 433 package was not available;
• therefore, this report does not make the categorical claim that no debt-management regulation, adoption order, pending amendment, or historical interpretation exists.

The current statute and publicly available operational materials are sufficient to identify the statutory license and fee structure, but not to close the regulation-history gap.

6. Worked fee and boundary examples

All monetary figures are dollars. Percentages are converted to decimals for multiplication. No rounding is needed except where stated. These examples show legal ceilings and boundaries; they do not establish a particular provider’s authorization.

Example 1 — Standard 12-month licensed custodial DMP

Inputs

• Money contractually agreed to be paid through licensee: B = $6,000
• Contract term: n = 12 months
• Contracted fee: F = statutory maximum
• Nebraska percentage: r = 15%

Operator

• Aggregate ceiling = B × r
• Monthly amortized amount = F ÷ n

Intermediate

• $6,000 × 0.15 = $900
• $900 ÷ 12 = $75 per month

Result

• Maximum total contracted fee: $900
• Maximum monthly amount applied while contract remains active: $75
• Initial payment: up to $25, credited against the $900—not added on top of it.

Timing conditions

• Program must first be arranged and approved.
• Contract is not effective until a payment is made for creditor distribution.
• If TSR applies, no fee—including the $25—may be requested or received before the federal performance trigger.

Initial-payment ambiguity

The statute does not expressly say whether the $25 is:

• part of the first $75 installment; or
• a separate initial application followed by later installments reduced so total fees remain $900.

The conservative first-month treatment is $25 initial plus no more than $50 additional fee that month. A provider using $25 plus the full $75 in month one should obtain authoritative support and ensure later amortization prevents total fees exceeding $900.

Example 2 — Lower balance where $25 exceeds nominal monthly amortization

Inputs

• B = $1,200 through the licensee
• n = 12 months
• r = 15%

Operator and intermediate

• Total ceiling = $1,200 × 0.15 = $180
• Nominal monthly amount = $180 ÷ 12 = $15

Result

• Total fee cannot exceed $180.
• Nominal monthly amortization is $15.
• The statute separately allows a credited initial payment up to $25.

Boundary

Because the text introduces the $25 with an exception to the monthly rule, a $25 initial payment is textually plausible even though it exceeds $15. But the exact later-month adjustment is not specified.

Two possible accountings are:

1. count only $15 as a first-month charge and treat the remaining $10 as unearned debtor money until later; or
2. apply $25 initially, then reduce later installments so cumulative fees never exceed $180.

No controlling interpretation was located. It would be unsafe to charge $25 plus twelve additional $15 installments because that equals $205 and exceeds the lawful total by $25.

Example 3 — Cancellation after four lawfully applied monthly fees

Inputs

• B = $6,000
• Total contracted fee F = $900
• n = 12 months
• Monthly amount = $75
• Four monthly amounts were lawfully applied after all applicable state and federal triggers.

To keep the scenario internally consistent, assume either:

• the TSR does not apply; or
• an executed DMP altered all covered debts together, the debtor made the required payment, and the four fees were collected only afterward.

Intermediate

• Fees already applied = 4 × $75 = $300
• Remaining unamortized fee = $900 − $300 = $600
• Cancellation ceiling = $600 × 0.25 = $150

Result

• Previously applied fees: $300
• Maximum cancellation amount under the apparent additional-charge reading: $150
• Maximum cumulative total under that reading: $450

Interpretive hold

Section 69-1212 does not expressly state whether the 25% amount:

• is an additional cancellation charge on top of already earned fees; or
• is the complete remaining settlement on cancellation.

The $150 ceiling is mathematically correct, but the legal characterization remains unresolved.

Example 4 — Individually settled debt under the TSR proportional method, with Nebraska monthly cap

Inputs

• Total debt enrolled for TSR allocation: E = $10,000
• Debt A enrolled amount: A = $4,000
• Debt B enrolled amount: $6,000
• Amount agreed to pass through Nebraska licensee: B_NE = $10,000
• Total contracted fee: F = $1,500
• Contract term: 20 months
• TSR method selected: proportional enrolled-debt method for every debt
• Prior fees before any settlement trigger: $0

Nebraska calculations

• Nebraska ceiling = $10,000 × 0.15 = $1,500
• Monthly cap = $1,500 ÷ 20 = $75

TSR Debt A allocation

• Debt A proportion = $4,000 ÷ $10,000 = 0.40
• Maximum fee attributable to Debt A = 0.40 × $1,500 = $600

Performance facts

• Debt A is settled under an executed agreement.
• Customer makes the first required payment under that agreement.
• Debt B has not yet been settled.

Result at the first trigger

• TSR permits earning against Debt A up to the allocated $600, subject to all applicable conditions.
• Nebraska allows no more than the current monthly amount of $75.
• Therefore, the presently collectible fee is no more than $75, not $600.
• Cumulative fees attributable to Debt A cannot exceed $600.
• Fees attributable to Debt B remain unearned under the individual-debt TSR rule until Debt B satisfies its own trigger.
• The provider cannot switch Debt B to a percentage-of-savings method.

No catch-up assumption

Because prior fees were $0, the example does not invent earlier “earned” installments. No Nebraska authority was located allowing an immediate catch-up of all pre-trigger monthly amounts.

Changed state-base failure case

If the actual amount agreed to pass through the licensee were only $6,000, the Nebraska aggregate ceiling would be:

• $6,000 × 0.15 = $900

A $1,500 fee contract would then exceed Nebraska’s cap even though the federal proportional arithmetic was otherwise correct.

Example 5 — Noncustodial 25%-of-enrolled-debt proposal

Inputs

• Enrolled debt = $10,000
• Proposed fee = 25% of enrolled debt
• Provider never receives debtor funds and claims no control of the independent account.

Arithmetic

• $10,000 × 0.25 = $2,500

Legal result

• The Chapter 69 15% formula cannot be used to validate or invalidate the $2,500 fee automatically because the provider may not fit Chapter 69’s custodial definition.
• No affirmative Nebraska statute or license authorizing a 25%-of-enrolled-debt negotiation-only model was established.
• If the transaction is telemarketed debt relief, the TSR may control when the fee can be earned—but federal timing compliance does not create Nebraska market access.
• If credit-improvement representations are made, the Nebraska CSO Act, CROA, and possibly the TSR credit-repair rule may apply.

Disposition: HOLD—no lawful Nebraska fee pathway established on these facts.

Example 6 — Nebraska CSO plus federal CROA

Inputs

• Total advertised credit-improvement fee = $500
• Provider is registered and has the Nebraska $100,000 bond.
• Service expressly promises to improve the buyer’s credit history.
• Interstate communications are used.
• Buyer signs Monday.

Nebraska state result

• Nebraska does not supply a general percentage cap.
• The bonded CSO may appear eligible for the state-law precompletion exception for non-credit-obtaining services.
• Buyer may cancel within three days as stated in Nebraska law.
• Any payment must be returned within ten days after cancellation notice.

Federal CROA result

• No service may be provided during the first three business days.
• Consumer may cancel through the federal three-business-day period.
• No portion of the $500 may be charged or received for an agreed service until that service is fully performed.

Result

The Nebraska bond does not authorize an advance fee prohibited by federal CROA. The currently lawful advance fee is $0 on the stated facts.

Example 7 — CSO obtaining a Nebraska Installment Loan and Sales Act loan

Inputs

• Provider offers to obtain a loan governed by that Act.
• Proposed “application/brokerage fee” = $300.

Operator

Neb. Rev. Stat. §45-804(8): no brokerage fee or other fee or charge whatsoever in connection with that loan.

Result

• Lawful provider fee on this branch: $0
• The bond exception does not change the result.

B. Source table

C. Claim register

D. Component coverage and gap table

Exact next investigations

The following should be separate Nebraska passes rather than silently folded into this component:

1. Title 433 completion: obtain and inspect every currently effective Title 433 chapter, amendment certificate, effective date, and pending/adopted order through October 24, 2026.
2. Noncustodial classification: locate administrative correspondence, enforcement pleadings, AG opinions, trial orders, or appellate decisions addressing “evidences thereof,” payment authority, independent accounts, and remote settlement providers.
3. Approved-contract evidence: examine publicly obtainable approved or filed Chapter 69 contracts for treatment of the $25 payment, monthly amortization, cancellation charge, prepayment, costs, and rounding—without treating private forms as law.
4. Remote nexus: determine what Nebraska conduct, consumer location, solicitation, account location, or creditor nexus constitutes business “in this state.”
5. Money-transmission pass: analyze unlicensed, dedicated-account, payment-processor, agent-of-payee, and settlement-disbursement structures under the current July 18, 2026 Money Transmitters Act.
6. Enforcement/case pass: paid and nonpaid docket/citator research for administrative actions, trial-level orders, consent judgments, and historical AG opinions; no purchase was made in this pass.
7. Remaining dossier categories: full agreements, bonds/trust, remedies, limitations, collections, litigation, secured debt, creditor types, local/tribal issues, choice of law, electronic contracting, unauthorized practice, UDAP, advertising, referral arrangements, and federal/state enforcement overlap.

E. Researcher self-check

Actually opened and read

• Official Nebraska Legislature pages for the material portions of §§69-1201 through 69-1215.
• Official Nebraska Legislature pages for §§45-802 through 45-808.
• Current §8-2703, including the 2026 source history and July 18, 2026 operative date.
• Nebraska Secretary of State debt-management and CSO licensing pages.
• SOS debt-management statute index.
• Debt-management active roster PDF, both pages, including visual inspection.
• Debt-management application PDF, including visual inspection.
• CSO active roster and registration-form PDFs, including visual inspection.
• SOS HTML rules/guidance index.
• February 19, 2026 annual rules/guidance index PDF, including visual inspection.
• Current eCFR text of 16 C.F.R. §§310.2, 310.4, and 310.6.
• Current U.S. Code text of 15 U.S.C. §§1679a, 1679b, 1679d, and 1679e.
• Nebraska Department of Banking and Finance consumer-education pages, used only for contrast and not as licensing authority.

Discovery/search-rendered or limited-access material

• The official dynamic Nebraska rules catalog and rulemaking docket returned JavaScript shells through the permitted public-web route. They were not treated as substantive proof.
• Directly indexed Title 433 chapters located in official search were inspected sufficiently to identify several other licensing subjects, but no claim is made that every chapter or amendment was retrieved.
• Exact-citation and act-name searches were run across public Nebraska appellate and official sources. No on-point decision was located, but this was not an exhaustive paid citator or docket investigation.
• A state court route involving a charge was not purchased or used.

Not read or not performed

• No private provider contracts, internal regulator files, nonpublic applications, examination reports, or private borrower data.
• No application, registration, complaint, contact, or records request.
• No named-provider license determination.
• No comprehensive trial-court docket or commercial citator search.
• No complete historical legislative-intent review.
• No full Nebraska Collection Agency Act, consumer-protection, money-transmission, remedies, limitations, secured-debt, local, tribal, tax, bankruptcy, or litigation analysis.
• No representation that the work was independently reviewed, locally written, regulator-approved, legal advice, or publication-ready.

Bottom-line provider-access hold: A properly licensed custodial DMP or custodial compromise program has a verified Nebraska pathway and a specific pass-through-based fee regime. A noncustodial negotiation-only debt-settlement company does not obtain Nebraska permission merely by following the federal TSR or charging a familiar percentage of enrolled debt. That model remains held pending a defensible Nebraska classification and any conditionally applicable CSO, money-transmission, credit-repair, and remote-nexus analysis.

END S_NE PASS-01.