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

S_NV PASS-02 — Focused current-law correction and 2026 fee-adjustment evidence

SettleADebt.com — Nevada provider-access/fees component

• Fresh public-source access: October 25, 2026, Pacific time
• Coordinator-supplied review date: October 24, 2026
• Actual model/mode: GPT-5.6 Sol Pro, Regular Chat
• Disposition: The registration-expiration and former-NAC-676A.140 issues are corrected. The settlement-account, prohibited-debt and fee-trigger rules are added or tightened. The exact consumer-fee dollar amounts operative in October 2026 remain held because the Commissioner’s required annual adjusted-amount publication was not retrieved.
• Scope control: PASS-01’s preserved findings, four examples and unaffected source/claim records are not regenerated here. This addendum does not establish Nevada launch approval, a provider’s registration, contract approval or publication readiness.

A. Replacement and supplemental passages

A1. Replace PASS-01 section 7 and S_NV-P1-C016

The ordinary Nevada registration-expiration date is no longer unresolved.

Current NRS 676A.370 expressly provides that a provider registration expires December 31 unless renewed, and that a renewal application must be filed from November 1 through December 31. A timely and complete renewal application keeps the registration effective until the Commissioner issues a recorded denial. If required renewal material is not submitted during the statutory window, the registration is cancelled December 31; the Commissioner may, rather than must, reinstate it when all required information and fees are submitted by February 28 of the following year. The denial-and-appeal provisions contain a distinct, qualified branch for continuing to service existing agreements, subject to NRS 676A.750; they do not establish an unrestricted right to solicit or enter new agreements. Nevada Legislature+1

The filed and approved regulation, LCB File R098-23AP, independently reconciles the formerly inconsistent administrative text. Its header states that it was filed June 20, 2024; section 8 changes NAC 676A.130 from June 30 to December 31 and retains the $1,500 renewal and $1,500 additional reinstatement fees. Section 19 expressly repeals NAC 676A.140, including its old 10-day extension request and 30-day completion procedure. Nevada Legislature+2

The numerical register separately identifies R098-23A as the adopted-stage document posted June 6, 2024 and R098-23AP as approved by the Legislative Commission June 20, 2024. The informational statement and workshop materials are not the final operative regulation. Nevada Legislature

NRS 233B.070(1) provides the default rule that a permanent regulation becomes effective when filed with the Secretary of State unless the regulation specifies a later date. R098-23AP bears a June 20, 2024 filing date, and a text search of the filed PDF found no separate later-effective-date clause. Thus, on the reviewed record, the amendment and repeal became effective on filing, June 20, 2024. That conclusion is a statutory application of the filing rule, not an express effective-date sentence in section 8 or section 19, and this pass did not perform a separate stay, injunction or vacatur audit. Nevada Legislature+2

The online NAC compilation still displays June 30 and the repealed NAC 676A.140 text despite a page refresh timestamp of April 13, 2026 and a chapter revision date of September 2018. That unintegrated display does not create a current-law conflict or revive the repealed provision. The current statute and filed regulation control the correction; the FID page’s December 31 date is corroborative operational guidance rather than the reason the law changed. Nevada Legislature+1

A2. Replace PASS-01 section 3’s reliance on old NAC 676A.140

Delete any treatment of NAC 676A.140’s former 10-day extension request and 30-day reinstatement-completion procedure as current law.

The current framework for the issue examined here is:

1. December 31 expiration and November 1–December 31 renewal under NRS 676A.370(1)–(2).
2. Continued effectiveness only for a timely and complete renewal under subsection 4.
3. The qualified denial/appeal and existing-agreement provisions in subsection 5.
4. Cancellation under subsection 6 when required renewal items are missing.
5. Discretionary reinstatement when all renewal information and fees are submitted by February 28.
6. The $1,500 renewal and additional $1,500 reinstatement government charges preserved in amended NAC 676A.130.

No inference should be made that a particular expired provider qualified for continuation or reinstatement without its filing record, completeness determination, denial history, dates and current public status. Nevada Legislature+3

A3. Add the express settlement-account and prohibited-debt limits

PASS-01 correctly recorded that the statutory debt-settlement definition contemplates periodic deposits in an FDIC-insured account owned by the individual and not controlled by the provider. NRS 676A.700(2)(i) supplies an additional direct prohibition that cannot be reduced to a classification question:

• With respect to debt-settlement services, the provider may not have an ownership interest in or any control over the individual’s settlement account.
• The provider may not furnish debt-settlement services for a secured debt, a debt that was at any time secured, or a loan governed by NRS Chapter 604A.
• The provider may not include any such debt or loan when calculating its fee. Nevada Legislature

This language does not establish that every noncustodial model is permitted, does not convert registration into approval of an account design, and does not establish that every debt-management plan involving secured obligations is prohibited. The statutory wording applies the quoted prohibitions specifically “with respect to debt settlement services.” Actual debt history and service classification therefore remain necessary.

A4. Replace the imprecise fee-prerequisite discussion

NRS 676A.580 contains distinct branches that must not be collapsed:

General agreement prerequisite. A provider may impose or receive charges for debt-management services only as permitted by section 580, and not until the provider and individual sign an agreement complying with NRS 676A.540 and 676A.700. Signing is necessary, but it is not sufficient to authorize every charge. Nevada Legislature

Education and counseling after assent. Once the individual assents to an agreement, subsection 3 generally prohibits an education, counseling or similar fee. The Commissioner may authorize a fee based on the nature and extent of the services, and the provision preserves the separate NRS 676A.700(5) exception. The rule is therefore neither a universal no-fee rule nor permission to add an education charge merely because an agreement was signed. Nevada Legislature

No-agreement counseling branch. When the individual does not assent to an agreement, subsection 4(b) permits a statutory base fee up to $100 for educational or counseling services, or a larger amount with Commissioner approval when warranted by the nature and extent of the services, subject to the NRS 676A.700(5) cross-reference. If the individual assents to an agreement before 90 days expire after the counseling is completed or terminated, subsection 5 requires refund of the fee paid under subsection 4(b). The $100 is subject to the annual adjustment mechanism and is not established here as the October 2026 ceiling. Nevada Legislature+1

Debt-settlement performance fee. Subsection 6 imposes three cumulative conditions before a provider may request or receive any fee or consideration:

1. The provider has settled the terms of at least one debt under a settlement agreement or other valid contractual agreement executed by the individual.
2. The individual has made at least one payment under that settlement agreement or other valid contractual agreement between the individual and creditor or debt collector.
3. The fee is calculated using the complete statutory proportional-allocation method or a uniform percentage of actual savings.

An offer, enrollment, negotiation, deposit into an account or merely scheduled installment is not the statutory performance event. Satisfaction of one debt’s conditions does not automatically earn the allocation associated with another debt. Nevada Legislature

Subsection 6 does not state a universal numerical settlement-fee percentage ceiling. That narrow observation does not validate an arbitrary rate, resolve contract enforceability or unconscionability, establish registration, displace other Nevada law, or satisfy independently applicable federal restrictions.

PASS-01’s four examples and arithmetic remain unchanged. The base-dollar DMP and dishonored-payment examples remain illustrations only, not verified October 2026 ceilings.

A5. Current annual adjustment evidence

NRS 676A.730(6) requires the Commissioner to adopt replacement dollar amounts for specified Chapter 676A provisions using CPI-U or an adopted substitute index. The amounts are adjusted effective July 1 when the index change from the selected base year, measured as of the preceding December 31, is at least 10 percent. Section 580 amounts are rounded to the nearest dollar; the other covered amounts are rounded to the nearest $100. Subsection 7 requires notice to registered providers and public availability. Nevada Legislature

NAC 676A.060 selects 2010 as the base year and states that the Commissioner will post each year’s dollar amounts online and make them available in print. Nevada Legislature

The bounded official-source search did not retrieve the publication stating the amounts applicable on October 25, 2026. Consequently:

• $50 for setup, $10 per remaining account and $50 monthly aggregate under subsection 4(a);
• $100 under subsection 4(b); and
• the lesser-of-$25-or-other-law dishonored-payment amount under subsection 7

remain statutory base figures, not verified current maxima. No CPI calculation, assumed adjustment, inferred unchanged amount or substitute amount is supplied in this pass.

The failure to retrieve the annual table is not a finding that the Commissioner failed to issue it. It is an evidence-access gap.

B. Minimal current-law and pinpoint matrix

C. Focused source register

The complete R050-10 and R054-16 adoption orders corresponding to P1-S006 and P1-S007 were not newly read. Their P1 locator-only classifications remain unchanged.

D. Focused claim register

E. Bounded 2026 consumer-fee publication search

Result

The exact October 2026 amounts remain unresolved. The next evidence needed is the Commissioner’s actual annual dollar-amount publication or archived provider notice showing:

• the covered statutory provisions;
• the operative year and July 1 effective date;
• the index measurement and base-year relationship;
• the adjusted and rounded amounts;
• whether the notice superseded an earlier notice; and
• the official publication or distribution provenance.

No BLS calculation should substitute for that operative agency record in the state dossier.

F. Bounded federal carry-forward

No federal provision was freshly opened or assigned a new P2 source ID.

The same-coordinator supplied record may support only this conditional overlay:

• For a covered telemarketed debt-relief service, the TSR performance conditions concern an executed customer settlement or other valid agreement, a qualifying customer payment, and the prescribed allocation calculation—not merely receipt of money into an account.
• The federal dedicated-account conditions are separate from Nevada’s absolute no-ownership/no-control prohibition and include distinct ownership, independence, affiliation, referral-compensation, withdrawal and return-of-funds requirements.
• Credit-repair telemarketing fee timing depends on the actual represented-results window, performance and qualifying consumer-report evidence.
• CROA’s payment and cancellation provisions depend on actual statutory coverage, entity status and promised services.

The supplied current-code URLs for the CROA contract and cancellation provisions were:

• https://uscode.house.gov/us/usc/119-120/t15/s1679d/
• https://uscode.house.gov/us/usc/119-120/t15/s1679e/

Those materials were not freshly reopened in PASS-02. No automatic TSR or CROA coverage, exemption, Nevada-specific federal conclusion or federal exception to Nevada’s settlement-account prohibition is asserted.

G. Focused coverage and gap table

H. Remaining explicit holds

1. Exact October 2026 consumer-fee ceilings: still unresolved; statutory base figures cannot be published as current ceilings.
2. Named-provider authority: no entity, trade name, registration number, effective date, location or disciplinary status was checked.
3. Current NMLS checklist: the state-specific route did not yield readable checklist content.
4. Individual lapse or reinstatement: December 31 and February 28 rules are established, but no provider is deemed continued or reinstated.
5. Full R050-10/R054-16 history: not newly read; P1 locator classifications remain.
6. Federal coverage: the supplied TSR/CROA material remains conditional and was not freshly reopened.
7. Cases and interpretations: no controlling judicial or formal agency interpretation was added.
8. Complete government-rate currentness: the current FID page links the filename-dated 2024 schedule, but NRS 658.101 and all current NMLS charges were not fully reconciled.
9. Contract and operational legality: no agreement, fee rate, account structure, provider, campaign or launch was approved.
10. Broader Nevada dossier: full contracts, funds, bond, insurance, remedies, collection, litigation, limitations, complete exemptions, other sectors, local and tribal law remain open.

I. Researcher self-check

Freshly and substantively read on October 25, 2026

• NRS 676A.370(1)–(6).
• NRS 676A.580(1)–(7).
• NRS 676A.700(2)(i)(1)–(2).
• NRS 676A.730(6)–(7).
• R098-23AP’s filing header, section 8, section 19 and displayed repealed NAC 676A.140 text; the relevant PDF pages were visually inspected.
• The 2023 NAC numerical-register entries for R098-23.
• NRS 233B.070(1).
• NAC 676A.060 and the stale displayed .130/.140 text.
• The relevant body of the current FID Uniform Debt Management Services page.
• Both pages of the December 8, 2022 NMLS transition memorandum, including visual inspection.
• The current FID Fees and Prime Interest Rate page.
• The one-page FID government-fee PDF, including visual inspection.
• The visible current FID Notice & Information page.
• The NMLS state-specific redirect result.

Search-only, failed or deliberately not upgraded

• No actual annual 2026 consumer-adjustment table was retrieved.
• The live NMLS state-resource route yielded no extracted checklist content.
• FID sitemap and robots routes were inaccessible through the tool.
• The historical checklist remains historical and does not replace current NMLS requirements.
• P1-S005 is not retroactively reclassified.
• Full R050-10 and R054-16 orders were not newly read.
• The adopted-stage R098-23A document was not used instead of the filed AP version.
• No federal TSR or CROA source was freshly opened.
• No named-provider roster or NMLS Consumer Access search was run.
• NRS 658.101 was not successfully retrieved and no complete 2026 governmental-rate conclusion was made.

Scope and process limits

This was a focused correction and evidence addendum, not an independent review. It did not rerun PASS-01, regenerate its examples, create local files, control Chrome, open browser tabs, use Deep Research or Work, use an API, submit an application, purchase anything, contact any person or regulator, access private borrower information, change an account, publish a site or establish operational approval.

The current-law expiration correction is supported by the current statute and filed approved regulation rather than by choosing the newest webpage. The exact adjusted consumer-fee amounts remain expressly held. All broader Nevada categories remain required.

END S_NV PASS-02