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

S_NE PASS-06 — Nebraska mandatory agreement, disclosure, and execution component

Actual fresh research date: October 26, 2026, Pacific time / October 26, 2026 UTC Mode/model: Regular Chat; GPT-5.6 Sol Pro Review status: Same-coordinator continuation, not independent review.

This pass is limited to mandatory agreement content, precontract disclosures, execution, copies, electronic assent, cancellation notices, contract changes, assignment, waiver, and the narrow arbitration/choice-of-law boundary. PASS-04 funds and PASS-05 security remain saved but unreviewed and are not accepted or relied upon here for their new findings. Prior fee, federal TSR, funds, bond, and Title 433 qualifications remain unchanged.

Executive determination

Nebraska’s two potentially relevant agreement regimes are materially different:

1. Licensed Chapter 69 debt management has a short but mandatory agreement architecture. Before accepting the account, the licensee needs a written, thorough budget analysis showing that the debtor can reasonably make the required payments. The contract must be written, fully completed before execution, list all adjusted obligations and creditors, state total charges and beginning/expiration dates, stay within 36 months, clearly state the cancellation/prepayment settlement, and be copied to the debtor immediately. The program must be arranged and approved by the debtor, and the contract does not become effective until the debtor makes a payment to the licensee for creditor distribution. Nebraska requires the blank contract form to be filed with the Secretary of State and form changes reported within 30 days, but filing is not statutory approval of the contract. Nebraska Legislature+4
2. A covered Nebraska credit-services organization, when no exemption is proved, faces much more prescriptive requirements. Before contract execution or receipt of value, it must provide a written disclosure statement with detailed services, total cost, bond/account rights, credit-report rights, dispute rights, obsolescence information, and nonprofit-counseling availability. It must retain an exact buyer-signed acknowledgment for two years. The contract must be written, dated, signed by the buyer, contain specific payment, service, duration, address, refund-promise, and cancellation language, and have two detachable cancellation notices attached. The buyer receives all signed documents when signed. State cancellation lasts three days, and any payment must be returned within ten days after the provider receives timely cancellation notice. Nebraska Legislature+3
3. Nebraska’s 1991 CSO disclosure text contains an outdated description of federal credit-report rights: it refers to a 30-day post-denial free-report period and a charge at other times. Current FCRA text provides a 60-day post-adverse-notice free-report period and an annual free disclosure. A form that merely copies the old Nebraska language cannot safely be treated as the complete and accurate current federal-rights disclosure separately required by §45-807. No formal Nebraska reconciliation was located. Nebraska Legislature+1
4. Electronic formation is legally possible, but an email, click, typed name, or portal checkbox is not automatically enough. Nebraska UETA requires agreement to transact electronically, intent and attribution, a retainable record, and preservation of any prescribed method or format. When federal E-SIGN’s consumer-disclosure provisions apply, the provider also needs affirmative electronic consent after disclosures about paper options, consent scope, withdrawal, contact updates, copies, fees, and hardware/software, plus an electronic process reasonably demonstrating access. Neither statute cures omitted agreement terms, a blank creditor list, missing cancellation forms, or untimely delivery. Nebraska Legislature+7
5. Neither Chapter 69 nor the CSO Act categorically prohibits arbitration. Under Nebraska law, a standardized agreement making binding arbitration the sole remedy ordinarily needs the special arbitration notice adjoining the signature block. Nebraska’s Supreme Court held that the Federal Arbitration Act preempts that special notice when the agreement involves interstate commerce. The U.S. Supreme Court separately held that CROA does not categorically bar arbitration. Actual formation, commerce, voluntariness, nonwaiver, remedy preservation, and clause terms remain contract-specific. Nebraska Legislature+5
6. The current public Nebraska regulator pages link applications, security forms, rosters, and statutes, but no public model DMP agreement, CSO consumer disclosure, cancellation packet, electronic-consent form, or contract-approval letter was located. The DMP application confirms that blank contract forms and later form changes are filed. The CSO registration form does not function as a consumer-contract checklist. The incomplete Title 433 record remains an express current-rule gap, not a finding that no supplemental rule exists. Nebraska Secretary of State+3

A. Model-by-agreement matrix

B. Chapter 69 agreement requirements

B1. Pre-acceptance suitability

A Chapter 69 licensee may not accept an account unless a written and thorough budget analysis indicates that the debtor can reasonably meet the payments required by that budget analysis. This is a suitability gate, not merely a recordkeeping suggestion. The reviewed statute does not specify:

• mandatory budget categories;
• income-verification documents;
• household-expense assumptions;
• debt-to-income thresholds;
• who must prepare or sign the analysis;
• whether the debtor must receive a copy;
• whether creditor acceptance must already exist;
• how often the analysis must be updated; or
• a separate educational or counseling curriculum. Nebraska Legislature

No current authenticated Title 433 rule was available to fill those details. Therefore, “thorough” and “reasonably meet” remain fact-dependent standards rather than verified numeric tests.

B2. Mandatory DMP contract clauses

The mandatory DMP provisions appear principally in §§69-1209, 69-1212, 69-1213, and 69-1214. Nebraska Legislature+3

B3. Signature and assent

Chapter 69 does not contain the same direct formulation as the CSO Act—“written, dated, and signed by the buyer.” It nevertheless:

• requires a written contract between licensee and debtor;
• prohibits execution of a contract “to be signed by the debtor” unless fully completed;
• requires debtor approval of the arranged program; and
• delays effectiveness until the creditor-distribution payment.

The better bounded conclusion is:

A debtor signature is strongly contemplated, and assent and approval must be provable, but the reviewed Chapter 69 text does not separately prescribe a signature block, provider signature, witness, notarization, date of signature, or specific signature method.

An electronic signature can potentially satisfy any signature requirement, but only through the UETA/E-SIGN conditions addressed below.

B4. Immediate true copy

The licensee must “immediately” furnish a true copy of the contract. A copy supplied only after the first creditor payment, after a cooling-off period, or on later request would not satisfy the ordinary sequence of the statute unless another authority established otherwise.

For electronic delivery, the record must at minimum:

• accurately reflect the completed agreement;
• be capable of retention by the debtor at receipt;
• not block printing or storage; and
• remain reproducible where retention is required.

A transient browser display or portal screen that cannot be saved or printed is not enough under Nebraska UETA. Nebraska Legislature+2

B5. Contract effectiveness

The statute separates several stages:

Plain text

Budget analysis supports ability to pay
        ↓
Program arranged
        ↓
Debtor approves program
        ↓
Completed written contract furnished
        ↓
Debtor makes payment to licensee for creditor distribution
        ↓
Contract becomes effective

The statutory creditor-distribution payment is not interchangeable with:

• a signature alone;
• an electronic-consent checkbox;
• a provider fee;
• a deposit into an account not shown to be received by the licensee for creditor distribution; or
• an unenforced promise to fund later.

Which modern payment structure satisfies that condition remains tied to the unresolved custody and account-control questions.

B6. Regulator filing of the blank form

At licensing, the applicant supplies a blank copy of the contract intended for use. The licensee must notify the Secretary of State of all changes and amendments to that form within 30 days after the changes or amendments. The current public application repeats this instruction. Nebraska Legislature+1

That requirement does not establish:

• advance approval;
• substantive review;
• a safe harbor;
• that the form complies with federal law;
• that a filed arbitration clause is enforceable;
• that individual debtor modifications need not be documented; or
• that the Secretary approved any particular provider’s actual signed contract.

A material distinction must be preserved:

• Template/form change: triggers the 30-day Secretary notice requirement.
• Individual-account change, such as adding or removing a debt without changing the form template: must leave the operative agreement and records accurate, but the exact state amendment, signature, and copy procedure was not specified.

B7. Assignment and provider changes

A Chapter 69 license is nontransferable and nonassignable. That is not textually the same as a categorical prohibition on assigning a consumer contract. Nebraska Legislature

No reviewed provision resolves whether a consumer contract may be assigned when:

• the assignee is another licensed debt manager;
• servicing changes but the contracting entity remains;
• an affiliate takes over;
• the original provider closes;
• the consumer objects; or
• debts, fees, payment instructions, or account authority change.

An assignment cannot itself transfer the assignor’s license. Any substituted provider must independently satisfy applicable licensing and agreement requirements. Contract assignment, novation, consumer consent, continuing liability, and records transfer remain held.

C. Nebraska CSO disclosure and contract architecture

C1. Precontract disclosure timing

Before either:

1. executing a contract or agreement with the buyer; or
2. receiving money or other valuable consideration,

a covered CSO must give the buyer the written disclosure statement. Thus, delivering it inside a completed contract only after the buyer signs would be too late. Nebraska Legislature

Nebraska does not expressly say the state disclosure must be a document separate from every other writing. Federal CROA, when applicable, does require its disclosure to be separate from the contract and all other written material. A combined state/federal packet therefore must preserve the federal separation requirement rather than assuming one merged contract paragraph is enough. U.S. Code

C2. State disclosure contents

The CSO retains an exact copy signed by the buyer acknowledging receipt for two years after the statement was provided. Because the CSO requires that acknowledgment to be signed, §45-808(4) also supports giving the buyer a copy at signing as one of the other documents the organization required the buyer to sign. Nebraska Legislature+1

C3. The stale 30-day FCRA wording

Nebraska §45-807 was enacted in 1991 and still says the buyer’s file is available without charge if requested within 30 days after denial notice and for a minimal charge at other times. Federal amendment history shows that the pre-1996 FCRA used a 30-day formulation. Current FCRA instead provides:

• one free annual disclosure through the statutory centralized process;
• a free disclosure if requested within 60 days after an adverse-action notification; and
• other free-report categories. Nebraska Legislature+1

This creates an operational drafting problem:

• Repeating only the old state sentence omits current federal rights.
• Silently substituting a wholly different statement risks failing the state-specific item.
• Section 45-807 separately requires a “complete and accurate” statement of FCRA review rights.

No current Nebraska model disclosure, interpretation, rule, or order reconciling the wording was located. The defensible research conclusion is to hold exact final language for a current legal drafting review, while recognizing that a 1991-only disclosure should not be treated as complete current FCRA compliance.

C4. Mandatory CSO contract terms

These requirements appear in §45-808. Nebraska Legislature+1

C5. State cancellation sequence

Nebraska’s state-only sequence is:

Plain text

Contract signed on event date S
        ↓
Buyer may cancel before midnight of the third day after S
        ↓
Buyer mails or delivers:
    • signed, dated statutory form; or
    • other written notice
        ↓
CSO receives cancellation notice on event date R
        ↓
Any payment made under the contract returned within 10 days after R

The statute says days, not business days. It does not provide, in the reviewed text:

• a weekend/holiday extension rule;
• a statutory email address;
• portal cancellation;
• a received-versus-sent rule beyond “mail or deliver” by the displayed deadline;
• certified-mail requirement;
• a service pause during the state three-day period; or
• permission to deduct an enrollment, cancellation, administrative, or earned fee from the state-required return. Nebraska Legislature+1

No concrete calendar date is supplied here because no Nebraska counting, weekend, or holiday rule was established for this provision in this pass.

C6. Waiver and releases

A CSO may not attempt to cause a buyer to waive a right under the Act, and a purported waiver is void. This covers contract language, releases, acknowledgments, and amendment clauses to the extent they purport to surrender an Act right. Nebraska Legislature

The antiwaiver provision does not automatically answer every question about:

• settlement of an accrued dispute;
• arbitration;
• forum selection;
• class procedures;
• releases executed after litigation;
• severability; or
• choice of law.

Those issues depend on the actual clause, timing, federal law, and whether a substantive Act right is eliminated.

C7. Amendments, debt changes, and assignment

The CSO Act does not establish an express amendment procedure. Any amendment must nevertheless leave the contract compliant with the mandatory terms. A change to:

• total payments;
• services;
• guarantees;
• refund promises;
• duration;
• provider identity or address;
• service agent; or
• cancellation mechanics

cannot safely be handled through an undisclosed unilateral dashboard update.

No express CSO contract-assignment rule was located. An assignment that changes the service provider may implicate:

• registration and exemption status;
• the required provider address;
• service-agent information;
• disclosure of services and payments;
• consumer assent;
• security information; and
• whether the original party remains liable.

The operational result is held pending the actual assignment clause and entity facts.

D. State CSO versus conditional federal CROA requirements

CROA is included only as a conditional agreement overlay; its coverage, exemptions, representations, and sales facts remain the prior unresolved questions.

Federal CROA’s operative provisions appear in 15 U.S.C. §§1679c–1679f and 1679j. U.S. Code+4

E. Electronic signature, assent, delivery, and retention

E1. Nebraska UETA conditions

E2. Federal E-SIGN consumer consent

Where the transaction is in or affects interstate commerce, the recipient is a statutory consumer, and law requires written information to be provided or made available, E-SIGN requires more than ordinary contract assent. Before electronic consent, the consumer must receive clear and conspicuous information concerning:

• the paper option;
• withdrawal of electronic consent and consequences or fees;
• whether consent covers one transaction or categories of records;
• withdrawal and contact-update procedures;
• paper-copy procedures and charges;
• hardware/software needed for access and retention.

The consumer must then consent electronically in a manner reasonably demonstrating the ability to access the format actually used. Material access-requirement changes can trigger revised disclosures and renewed consent. E-SIGN preserves the substantive content, timing, proximity, and other protections of the underlying law. U.S. Code+3

No relevant E-SIGN exclusion for an ordinary DMP or CSO services contract was identified in §7003. That does not by itself establish that every Nebraska transaction is interstate or that every debtor is a statutory E-SIGN consumer. U.S. Code

E3. What an electronic workflow must preserve

A compliant electronic system would need evidence of at least:

1. Correct model classification and applicable agreement package.
2. Precontract disclosure delivered before contract or payment.
3. E-SIGN consumer consent when applicable.
4. Ability to download, print, and retain the exact record.
5. Complete obligations, creditors, services, payment terms, dates, and notices.
6. Required boldness, proximity, and attachment/duplication.
7. Intent to sign and attribution to the buyer/debtor.
8. A final immutable version tied to the signature.
9. Delivery of the completed copy and every signed document at the required time.
10. Retention for the required period.
11. A method to prove which version, disclosures, and cancellation date appeared.

A generic checkbox saying “I agree to terms” does not establish all eleven.

E4. Electronic CSO cancellation forms

Nebraska requires two easily detachable cancellation copies attached to the contract. UETA preserves statutory formatting and presentation requirements. No Nebraska authority was located deciding whether any of these are equivalent:

• two pages in a downloadable PDF;
• two separately downloadable files;
• duplicate HTML panels;
• one reusable electronic form;
• a portal cancellation button; or
• a single form that can be copied electronically.

The precise electronic equivalent remains held. A provider should not claim that one link or one portal button is conclusively equivalent to two detachable copies without authoritative support.

E5. Email or portal cancellation

Section 45-808 authorizes mailing or delivering the statutory form or “other written notice.” UETA can recognize an electronic record as writing, but it also preserves a statute’s specified method. No controlling authority was located establishing that:

• an email is “delivered” within §45-808;
• clicking a portal button is written notice;
• sending before midnight is enough if the provider receives it later;
• a provider may require cancellation only through a portal; or
• an automated acknowledgment proves the content received.

Accordingly:

• A provider may voluntarily accept electronic cancellation.
• It may not use that voluntary practice to deny the statutory paper route.
• Mandatory legal sufficiency of a particular email or portal workflow remains held.
• The ten-day state refund period begins when the organization receives the cancellation notice. Nebraska Legislature+2

F. Changes, termination, waiver, assignment, arbitration, and choice of law

F1. Nebraska arbitration notice

A written future-dispute arbitration provision is generally valid under Nebraska’s Uniform Arbitration Act if entered into voluntarily and willingly, subject to ordinary contract defenses and listed statutory exclusions. A standardized agreement making binding arbitration the sole dispute remedy must contain the capitalized and underlined statutory warning adjoining the signature block. Nebraska Legislature+1

F2. FAA preemption

In Aramark Uniform & Career Apparel, Inc. v. Hunan, Inc., the Nebraska Supreme Court held that:

• Nebraska’s special arbitration notice would make a noncomplying clause unenforceable under Nebraska law;
• the service contract involved interstate commerce;
• the FAA governed; and
• the FAA preempted Nebraska’s arbitration-only notice requirement for that contract.

The court reversed and directed confirmation of the arbitration award. This is not a DMP or CSO case, and its application turns on the actual commerce and contract facts. Nebraska.gov+1

F3. CROA arbitration

In CompuCredit Corp. v. Greenwood, the U.S. Supreme Court held that CROA’s disclosure and nonwaiver provisions do not contain a congressional command overriding the FAA; because CROA is silent on arbitrability, the agreement was enforceable according to its terms. The case does not approve every arbitration clause or eliminate ordinary formation, fraud, duress, unconscionability, or remedy-preservation challenges. Supreme Court+1

F4. Nebraska CSO nonwaiver boundary

An arbitration clause is not necessarily a waiver of substantive rights merely because it selects a forum. But a clause cannot safely:

• disclaim the state cancellation right;
• eliminate statutory damages or other nonwaivable rights;
• shorten a mandatory notice or refund obligation;
• permit prohibited conduct;
• require the buyer to waive the Act;
• prevent the required security claim disclosure; or
• make a noncompliant contract compliant.

No controlling Nebraska CSO-specific arbitration decision was located.

G. Event matrix

H. Bounded agreement and notice examples

Example 1 — Paper Chapter 69 enrollment workflow

Hypothetical assumptions

• Provider is already a properly licensed Chapter 69 entity.
• Consumer and debts satisfy the statutory classification.
• No electronic records are used.
• Fee, funds, and creditor-payment legality are assumed but not recalculated.

Sequence

Plain text

T0  Provider completes a written, thorough budget analysis.
    Analysis indicates the debtor can reasonably make required payments.

T1  Provider prepares a fully completed written agreement.
    It includes:
      • every obligation to be adjusted;
      • every creditor holding those obligations;
      • total agreed charges;
      • beginning and expiration dates;
      • clear cancellation/prepayment settlement.

T1  Debtor approves the arranged program.
    Provider immediately gives debtor a true copy.

T2  Debtor makes a payment to the licensee for creditor distribution.

T2  Contract becomes effective under §69-1212.

Limits

• A signature is strongly contemplated, but no specific state signature format is supplied.
• The example does not decide whether a modern third-party account payment qualifies as payment to the licensee.
• No fee becomes earned merely because T2 occurred.
• No creditor acceptance, funds-return, or bond result is implied.

Example 2 — Blank creditor fields at signature

Facts

• Debtor signs a DMP form.
• Two creditor names and the expiration date are left blank.
• Provider fills them in the next morning.

Result

The agreement fails the express prohibition against executing a debtor-signed contract unless fully and completely filled in and finished. Later backfilling is not authorized by the reviewed statute. Whether the defect makes the agreement void, voidable, unenforceable, or a disciplinary violation in a particular proceeding remains a remedies question outside this pass. Nebraska Legislature

Example 3 — Adding a debt after enrollment

Facts

• Original agreement accurately lists Creditors A, B, and C.
• Debtor later asks to add Creditor D.
• The provider’s standard form is unchanged.

Required distinction

Plain text

Individual account change:
    Operative contract/records must accurately reflect Creditor D.

Template change:
    If provider changes the blank contract form itself,
    SOS must be notified within 30 days after that form change.

Held issues

• Whether the individual addition requires a new contract, signed amendment, initials, electronic assent, or only an updated schedule was not specified.
• The provider cannot rely on the original “complete list” once it is no longer complete.
• No new fee or payment treatment is approved.

Example 4 — Nebraska CSO state cancellation without calendar assumptions

Define:

Plain text

S = date contract is signed
D = third day after S
R = date CSO receives the cancellation notice

Sequence

Plain text

Before midnight on D:
    Buyer mails or delivers:
       • signed, dated cancellation form; or
       • another written notice.

By R + 10 days:
    CSO returns any payment made under the contract.

Limits

• “Day” is not replaced by “business day.”
• No exact calendar date is calculated because weekend/holiday counting was not resolved.
• The ten-day clock runs from receipt, not necessarily mailing.
• No fee deduction is assumed.
• State law does not expressly create a service pause during the three days.

Example 5 — Nebraska CSO plus federal CROA

Assumptions

• Actual services and representations make both laws applicable.
• No exemption applies.
• Paper documents are used.

Sequence

1. Before contract execution, provider gives:Nebraska §45-807 disclosure; andfederal CROA disclosure as a separate document.
2. Consumer signs acknowledgment; provider retains the required copy.
3. Contract is written, dated, and signed.
4. Contract contains both applicable cancellation disclosures and forms.
5. Provider gives the completed contract, disclosures, and every signed document at signing.
6. Provider does not begin CROA services before the federal three-business-day service-pause period ends.
7. Consumer retains:Nebraska’s three-day cancellation right; andfederal CROA’s three-business-day right.

No attempt is made to collapse the two periods or use the shorter state period to terminate the federal protection. U.S. Code+2

Example 6 — Electronic CSO execution with retainable records

Assumptions

• Interstate consumer transaction.
• E-SIGN and Nebraska UETA apply.
• Electronic cancellation-form equivalence is not assumed resolved.

Sequence

Plain text

1. Consumer receives E-SIGN paper-option, withdrawal,
   scope, copy, fee, contact-update, and hardware/software disclosures.

2. Consumer electronically demonstrates access to the PDF format.

3. Provider displays the Nebraska precontract statement before contract signing.

4. Consumer signs the acknowledgment electronically.

5. Provider presents a final contract PDF with:
      • complete state terms;
      • conspicuous cancellation statement next to signature;
      • stable attached notices;
      • no blank fields.

6. Consumer intentionally signs through an attributed process.

7. Consumer immediately receives downloadable, printable copies
   of every signed document.

Result

The workflow addresses many UETA/E-SIGN predicates, but this pass does not certify that the electronic presentation constitutes the two “easily detachable” state cancellation copies. That remains a specific hold.

Example 7 — Portal display that blocks saving

Facts

• Provider shows the contract in a scroll box.
• Consumer clicks “I agree.”
• The portal prevents printing, downloading, or saving.
• The provider later emails only a one-page receipt.

Result

The electronic record is not capable of retention as required by Nebraska UETA, and the full contract was not shown to have been furnished as a true or completed copy. The click does not cure the delivery defect. Nebraska Legislature+1

Example 8 — Cancellation email sent before midnight

Facts

• State CSO contract identifies a postal address but no cancellation email.
• Buyer emails an unequivocal cancellation at 11:50 p.m. on the stated deadline.
• Provider’s system records receipt at 11:51 p.m.

Result

The message may be an electronic record and UETA supplies general sent/received rules. But no controlling authority was located establishing that email satisfies §45-808’s “mail or deliver” procedure in these circumstances. The mandatory legal result remains held.

The provider may honor the email voluntarily. This example does not authorize a provider to reject a timely statutory paper notice or force exclusive portal cancellation.

Example 9 — Stale Nebraska/FCRA disclosure template

Facts

The provider’s disclosure says only:

• free file review if requested within 30 days after denial; and
• a charge at all other times.

Result

The form repeats the old Nebraska language but omits current federal rights to a free annual disclosure and a free post-adverse-notice disclosure requested within 60 days. It therefore should not be treated as the complete and accurate current FCRA-rights statement required separately by §45-807(d). Exact compliant drafting remains held because Nebraska has not publicly reconciled its old item (e) language. Nebraska Legislature+1

Example 10 — Standardized sole-remedy arbitration clause

Facts

• Agreement is standardized.
• Binding arbitration is stated to be the sole dispute remedy.
• Nebraska’s special warning is omitted.
• Interstate-commerce facts are unknown.
• Clause preserves statutory remedies on paper.

Conditional outcomes

Plain text

If Nebraska UAA governs:
    Omission of the special adjoining-signature warning creates
    enforceability risk under §25-2602.02.

If FAA governs:
    Aramark holds the arbitration-specific Nebraska warning preempted.

If CROA applies:
    CompuCredit holds CROA does not categorically prohibit arbitration.

This does not approve the clause. Formation, voluntariness, scope, delegation, costs, remedy limitations, waiver, unconscionability, and actual interstate-commerce facts remain necessary.

I. Source register

J. Claim register

K. Component coverage and gap table

L. Researcher self-check

Freshly read in PASS-06

• The materially relevant current Chapter 69 agreement provisions:§§69-1201;69-1202;69-1204;69-1207;69-1209;69-1212;69-1213; and69-1214.
• The materially relevant current Nebraska CSO provisions:§§45-802;45-803;45-804;45-807;45-808; and45-809.
• Nebraska UETA provisions addressing definitions, scope, electronic agreement, signature, retainability, attribution, error, retention, automated transactions, and sent/received rules.
• Federal E-SIGN §§7001–7003 and 7006 as relevant to consumer records.
• Federal CROA §§1679c–1679f and 1679j as a conditional agreement overlay.
• Current FCRA §1681j and its amendment history, solely to reconcile the state disclosure’s 30-day language.
• Nebraska arbitration §§25-2602.01 and 25-2602.02.
• Relevant portions of:Aramark Uniform & Career Apparel, Inc. v. Hunan, Inc.; andCompuCredit Corp. v. Greenwood.
• Current Nebraska Secretary of State DMP and CSO pages.
• The one-page DMP license application and CSO registration PDFs, including visual page inspection.
• Targeted official-source searches for model agreements, electronic cancellation authority, assignment, and DMP/CSO agreement cases.

Reused only as attributed prior history

• PASS-01 provider, fee, and narrow agreement starting findings.
• PASS-02 Title 433 access history and federal precision.
• PASS-03 correction that federal withdrawal is from the debt-relief service rather than an unconditional bank-account withdrawal or closure.
• The fact that PASS-04 funds and PASS-05 security exist as saved components.

PASS-04 and PASS-05 were not treated as reviewed or accepted for their new substantive findings.

Failed, limited, or unresolved routes

• No complete authenticated current Title 433 agreement/disclosure chapter or adoption-order universe.
• No public SOS model DMP consumer agreement.
• No public SOS model CSO disclosure statement or full contract package.
• No public Nebraska interpretation reconciling §45-807’s 1991 FCRA wording with current federal law.
• No controlling Nebraska DMP/CSO decision located on:electronic cancellation;debtor-signature mechanics;assignment;unilateral amendment;detachable electronic cancellation notices;choice of law;forum selection; orarbitration under the specific state acts.

The searches were bounded public-source searches, not a commercial citator, paid docket, trial-court universe, administrative-file review, or records request.

Not read or not performed

• Any actual provider’s consumer agreement, amendment, disclosure, budget worksheet, e-signature certificate, audit log, portal presentation, cancellation notice, arbitration clause, assignment, or regulator filing.
• Any nonpublic Secretary of State approval, examiner manual, deficiency letter, interpretive correspondence, or enforcement file.
• A complete general Nebraska contract-law, unconscionability, novation, assignment, severability, forum-selection, or choice-of-law survey.
• Full funds-return, bond, insurance, bankruptcy, remedies, collections, litigation, limitations, garnishment, secured-debt, sector, local, tribal, or international analysis.
• Named-provider registration, contract approval, or operational compliance.
• Any Deep Research, Work, Codex research generation, API, purchase, filing, account action, regulator/company contact, records request, private borrower-data access, website action, publication, Chrome control, other chat, CAPTCHA bypass, or security workaround.

Focused disposition: Nebraska’s licensed DMP contract is mandatory but comparatively sparse: budget suitability, complete written debt/creditor terms, immediate copy, clear cancellation/prepayment wording, debtor approval, and delayed effectiveness. The CSO agreement package is detailed and formal, with a precontract statement, buyer acknowledgment, signed contract, prescribed cancellation language and forms, copies at signing, and nonwaivable state rights. Electronic execution is possible only through UETA/E-SIGN predicates and does not solve missing content or uncertain cancellation-form equivalence. Assignment, unilateral amendment, electronic cancellation, exact FCRA reconciliation, and the complete current Title 433 layer remain expressly held.

END S_NE PASS-06.