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

S_NE PASS-02 — focused precision correction and current Title 433 evidence

Actual access date: October 25, 2026, Pacific time Mode/model: Regular Chat; GPT-5.6 Sol Pro Review status: Same-coordinator focused correction, not independent review. The original PASS-01 record remains intact except for the expressly replaced or qualified language below.

This addendum does not repeat the Nebraska overview, definitions, CSO framework, seven complete examples, or the original source and claim registers. It does not approve a provider, contract, account arrangement, fee model, state dossier, parent component, or A066 publication status.

A. Federal wording replacements

A1. Replacement for PASS-01 §4.4 and old claim S_NE-P1-C026

When the Telemarketing Sales Rule applies and goods or services are represented to remove derogatory information from, or improve, a person’s credit history, credit record, or credit rating, 16 C.F.R. §310.4(a)(2) prohibits requesting or receiving any fee or consideration until both of the following conditions have occurred:

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

The regulation further preserves the Fair Credit Reporting Act limitation that a consumer report may be obtained only for a specified permissible purpose. This credit-repair branch is distinct from the debt-relief fee conditions in §310.4(a)(5). Actual TSR coverage, seller or telemarketer status, representations, calls, exemptions, and FCRA permissible purpose remain transaction-specific holds. eCFR

A2. Replacement for old claim S_NE-P1-C024

When §310.4(a)(5)(i) applies, a seller or telemarketer may not request or receive payment of a debt-relief fee until and unless:

• The seller or telemarketer has renegotiated, settled, reduced, or otherwise altered the terms of at least one debt pursuant to a settlement agreement, debt-management plan, or other valid contractual agreement executed by the customer;
• The customer has made at least one payment pursuant to that agreement between the customer and the creditor or debt collector; and
• When debts are altered individually, the fee attributable to each debt is calculated by one of the regulation’s two complete allocation methods:the fee bears the same proportional relationship to the total fee as that individual debt bears to the customer’s entire debt balance, with both debt amounts measured as owed when the customer enrolled; orthe fee is a percentage of the amount saved, using the same percentage for every debt, with savings measured as the enrolled amount owed minus the amount actually paid to satisfy that debt.

The provider may not switch allocation methods from debt to debt. An allocated amount is not automatically an immediately collectible amount; all applicable state timing, amortization, contract, and federal earning conditions still apply. eCFR

A3. Dedicated-account language relevant to cancellation

When the separate-account conditions in §310.4(a)(5)(ii) apply, the customer must be able to withdraw from the account at any time without penalty, and must receive all funds in the account—except fees earned in compliance with §310.4(a)(5)(i)(A) through (C)—within seven business days after the customer’s request. This condition does not establish that every Nebraska customer uses such an account or that every Nebraska cancellation amount is federally prohibited. It does mean that a state-law cancellation ceiling, standing alone, does not establish that an amount is federally earned or may be withdrawn from a covered dedicated account. eCFR

B. Focused Example 3 and Example 4 qualifications

B1. Example 3 — cancellation qualification only

The preserved inputs and arithmetic remain:

• Nebraska pass-through base: $6,000
• Contracted fee: $900
• Contract term: 12 months
• Monthly amortized fee: $75
• Four lawful monthly periods after all applicable earning and timing conditions: 4 × $75 = $300 applied
• Remaining unamortized contracted fee: $900 − $300 = $600
• Nominal Nebraska cancellation ceiling: 25% × $600 = $150
• Possible cumulative amount under the unresolved “additional compensation” reading: $300 + $150 = $450

The four $75 amounts are assumed to have been applied during four separate lawful monthly periods after all applicable triggers. The example does not permit the provider to collect four monthly fees immediately when the first federal performance trigger occurs.

The $150 calculation is only the mathematical Nebraska ceiling derived from §69-1212. The statute still does not conclusively establish in this record whether that amount is additional to previously applied fees or represents another form of cancellation settlement. Nor does the Nebraska ceiling itself establish that the $150 is an “earned” fee for federal purposes.

When the transaction uses a dedicated account governed by §310.4(a)(5)(ii), the no-penalty withdrawal and seven-business-day return requirement independently applies, except for fees already earned under §310.4(a)(5)(i)(A) through (C). Therefore:

• the Nebraska $150 ceiling does not itself authorize a $150 withdrawal from a covered account;
• it does not convert an unearned amount into a federally earned fee;
• no exact federal refund amount can be calculated without the actual account structure, TSR coverage facts, settlement agreements, debt-level allocation, prior fee history, and cancellation provision; and
• this qualification does not assume that Example 3 used a dedicated account or that every state cancellation payment is universally unlawful.

The preserved numerical equality is correct; lawful characterization and collectibility remain partially held. Nebraska Legislature+1

B2. Example 4 — conservative initial-payment branch

The preserved inputs remain:

• Total debt enrolled for the federal proportional allocation: E = $10,000
• Debt A enrolled amount: $4,000
• Debt B enrolled amount: $6,000
• Separately assumed Nebraska money agreed to pass through the licensee: B_NE = $10,000
• Contracted fee: $1,500
• Contract term: 20 months
• Nebraska monthly amortized amount: $1,500 ÷ 20 = $75
• Fees previously requested or received: $0
• Federal proportional allocation:Debt A: $4,000 ÷ $10,000 × $1,500 = $600Debt B: $6,000 ÷ $10,000 × $1,500 = $900, contingent on Debt B later satisfying its own federal conditions.

Assuming Debt A has satisfied the complete §310.4(a)(5)(i)(A)–(C) requirements, the $600 is the fee allocation attributable to Debt A under the selected federal method. It does not authorize immediate collection of the entire $600. Nebraska’s monthly amortization remains independently relevant.

For this example only, the conservative accounting branch is expressly selected:

Any Nebraska §69-1212 initial payment of up to $25 is included within—not added to—the same $75 monthly amount.

Accordingly, the amount requested or received during that first lawful fee month is no more than $75 under this example’s selected conservative branch. The example does not approve a $25-plus-$75, or $100, first-month charge. It also does not purport to resolve the statutory treatment of the initial-payment exception for every contract.

No pre-trigger monthly fee is treated as accrued or collectible, and no catch-up amount is created merely because Debt A later satisfies the federal trigger. Debt B’s $900 allocation remains contingent on Debt B satisfying its own conditions, and the provider may not switch Debt B to the percentage-of-savings method.

If only the independently assumed Nebraska pass-through base changes from $10,000 to $6,000:

• Nebraska aggregate ceiling: $6,000 × 15% = $900
• A $1,500 contracted fee exceeds that state ceiling and is invalid on those assumptions.

A future change in the Nebraska pass-through base is not automatically a corresponding change in federal enrolled debt or federal savings. Those are distinct legal and mathematical variables. Nebraska Legislature+1

C. Current Title 433 evidence determination

C1. Narrow result

Neb. Rev. Stat. §69-1208 provides that rules issued pursuant to the Debt Management Act must be promulgated under Nebraska’s Administrative Procedure Act. That provision establishes the required procedure for such rules; it does not itself establish that a particular debt-management fee rule currently exists. Nebraska Legislature

The current codified text of §69-1212 continues to display the operative statutory provisions relevant here:

• 15% of the amount agreed to be paid through the licensee;
• amortization over the contract;
• no more than the monthly amortized amount applied during a month;
• an initial payment no greater than $25, credited against the total fee;
• cancellation compensation no greater than 25% of the remaining unamortized contracted fee;
• no fee entitlement before the program is arranged and approved; and
• no effective contract until the debtor makes a payment for creditor distribution. Nebraska Legislature

The Nebraska Secretary of State’s current public index identifies Title 433, Licensing Regulations, but the visible HTML index does not enumerate Title 433’s chapters. Its displayed licensing-guidance list contains selected guidance for athlete agents, civil-litigation funding, collection-agency work-from-home operations, and private detectives; the list’s omission of debt-management guidance is not proof that no debt-management authority exists elsewhere. Nebraska Secretary of State

The official dynamic Title 433 catalog could not be substantively read through the permitted public-web route because it returned a JavaScript application shell. The official docket route returned a JavaScript shell in this PASS-02 access; the supplied same-coordinator access record reports a separate 403 outcome. Neither access result establishes the presence or absence, effectiveness, amendment, withdrawal, or proposal of a debt-management rule. Nebraska Rules+1

The February 19, 2026 annual index was freshly inspected visually in this pass. It identifies “Licensing and Notary Public Regulations (Title 433)” and lists the same selected licensing-guidance subjects. It also identifies the website as the source updated from time to time and therefore does not prove that no later amendment, chapter, order, or guidance existed after February 19, 2026. Nebraska Legislature+1

The current Debt Management Agencies page links the roster, application materials, bond form, branch form, and Chapter 69 statutes. No separate Title 433 debt-management rule link is displayed on that page. That is evidence about the page’s current contents, not proof that no operative rule exists. Nebraska Secretary of State+1

C2. Current evidentiary conclusion

Through the accessible official materials reviewed in this focused pass, no currently effective, debt-management-specific Title 433 provision or adoption order was verified that changes, indexes, supplements, or definitively interprets:

• the 15% statutory fee base;
• monthly amortization;
• the credited $25 initial payment;
• the 25% cancellation calculation;
• “fees and costs”;
• prepayment treatment; or
• a CPI or other adjustment mechanism.

This is a verification gap, not a categorical finding that no such rule, order, interpretation, or historical provision exists. The current codified statute remains the verified operative source for the identified numbers. No adjusted amount, index calculation, separate cost authority, or rule-created fee may be invented from the inaccessible catalog.

D. Focused Title 433 source/version/status matrix

The static chapters were inspected only to identify and exclude their unrelated subject matter. They are not independent authorities for Nebraska debt management, and the three documents do not establish the completeness of Title 433.

E. Focused source register

F. Focused replacement claim register

G. Focused coverage and gap table

H. Researcher self-check

Freshly read in PASS-02

• Current 16 C.F.R. §310.4(a)(2), (a)(5)(i)(A)–(C), and (a)(5)(ii)(A)–(E).
• Current Neb. Rev. Stat. §§69-1208 and 69-1212.
• Current Nebraska Secretary of State rules/guidance HTML index.
• Current Debt Management Agencies and Debt Management Statutes pages.
• Both pages of the February 19, 2026 annual index through fresh readable screenshots.
• Opening/title material of official-hosted Title 433 Chapters 1, 4, and 5, solely to identify their unrelated subject matter.

Supplied or same-coordinator evidence expressly reused

• The original PASS-01 record and its immutable calculations.
• The prior same-coordinator federal readings identified in the assignment.
• The preserved Chapter 69, CSO, roster, application, NDBF, CROA, money-transmission, and example evidence, except where expressly qualified above.

This reuse is not a second independent review.

Search-only, inaccessible, or not substantively read

• The official Title 433 dynamic catalog returned only a JavaScript shell.
• The official docket returned a JavaScript shell in the fresh PASS-02 route; the supplied coordinator record separately reported a 403 response.
• No substantive docket entry or adoption order was obtained.
• Search-indexed or secondary chapter lists were not treated as legal authority or as proof of the complete current Title 433 chapter universe.
• Failed or unrelated static chapter routes were not converted into debt-management authority.

Not performed or claimed

• No API, Chrome control, Deep Research, Work, Codex research generation, purchase, account action, application, contact, records request, provider lookup, private borrower-data review, local write, publication, or website change.
• No complete current certified Title 433 compilation.
• No provider contract, dedicated-account agreement, account ledger, cancellation request, or fee withdrawal reviewed.
• No exhaustive citator, trial-court, administrative-enforcement, money-transmission, remote-nexus, noncustodial, remedies, collection, secured-sector, local, or tribal investigation.
• No Nebraska component, full-state dossier, parent project, A066, operational, legal, or publication acceptance.

Focused disposition: The federal claim language and Examples 3–4 are corrected as stated. Nebraska’s current codified fee figures remain verified. A current debt-management-specific Title 433 fee rule or adoption order was not verified through the accessible official record; that question remains narrowly and expressly held rather than converted into a no-rule finding.

END S_NE PASS-02.