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

SettleADebt — S_OH PASS-02

Remaining evidence: §4710.02 fee bases and aggregation

Result: none of the four held fee questions is cleared by the newly read authority. The current statute, enacted amendment, official legislative analysis, agency comment, and judicial materials examined do not establish a controlling answer permitting:

• Separate initial consultation and setup allowances to be stacked;
• A fresh periodic allowance for every weekly or other submonthly charge;
• Inclusion of retained provider fees in the creditor-distribution base; or
• A stand-alone savings-, enrolled-principal-, or per-debt success fee.

There is one useful wording clarification: §4710.02(B)(3) measures an amount paid for creditor distribution. It does not expressly substitute an amount actually disbursed during that same month. That distinction does not resolve the gross-versus-net allocation of a bundled debit.

Baseline: October 22, 2026, Pacific. Actual access: October 23, 2026, UTC, corresponding to October 22, 2026, Pacific for the checks reported here. The final current-statute check occurred at approximately 06:47 UTC / 23:47 PDT. Scope: Only the four specified §4710.02 fee questions and the authority needed to evaluate them. This is not renewed Ohio market-access or CSO clearance.

In the discussion below, short references such as S001 and C001 mean S_OH-P2-S001 and S_OH-P2-C001. PASS-01 identifiers are written separately.

A. Substantive findings

1. Initial setup, initial consultation, and the annual consultation limit

The current official codification retains three distinct provisions relevant here: the $75 initial consultation-or-setup restriction, the $100 calendar-year consultation restriction, and the periodic administration restriction. It identifies March 29, 2007, and H.B. 699, 126th General Assembly, as the effective version. [C001–C003; S001, §4710.02(B)(1)–(3)] Ohio Laws

The annual consultation provision supports retaining the prior treatment of an initial consultation charge as part of that year’s consultation total. Calling a consultation “initial” does not expressly remove it from the consultation category.

The remaining questions are different:

• Does a genuinely separate setup service consume the annual consultation allowance?
• Does the word “or” in the initial-fee provision permit two separately priced initial services, each with its own allowance?
• How should a combined consultation/setup charge be allocated?

No newly read controlling interpretation answers those questions. The record therefore does not clear either a $75-plus-$75 initial arrangement or a $75 setup fee added to a separate $100 consultation allowance. It also does not establish a judicial holding that every pure setup charge must be credited against the annual consultation limit. Those are unresolved classifications and aggregation questions, not arithmetic questions. [C002–C003]

The enacted H.B. 699 amendment is useful because it confirms that the legislature added explicit reasonableness and hardship-policy requirements while retaining the relevant initial, annual, and periodic structure. Its operative amendment supplies no express stacking or setup-credit rule. The Senate-reported LSC analysis likewise discusses the added safeguards without resolving these allocation questions. The analysis is historical legislative material; it is not a current agency ruling. [C008; S002, amendment to §4710.02, printed pp. 200–201; S003, printed p. 26] search-prod.lis.state.oh.us+1

Disposition: Retain PASS-01 C019 and C020, including their aggregation limitations.

2. Multiple weekly or other submonthly administration charges

The numerical comparison remains:

Periodic-fee comparison = greater of 8.5% of the identified monthly creditor-distribution payment base or $30.

The statute expressly uses a monthly base. It does not expressly state, in the language examined, how multiple separately billed periodic fees within that month must be aggregated. [C004; S001, §4710.02(B)(3); S002, printed pp. 200–201] Ohio Laws+1

Two unsupported conclusions must remain outside the findings:

1. That each weekly billing event automatically creates another full $30-or-percentage allowance; and
2. That this pass has located a controlling decision expressly imposing one aggregate calendar-month ceiling across every separately characterized charge.

No such interpretation was established. Splitting collection of an assumed single monthly fee into installments is also not evidence that separate weekly fees are authorized.

The reasonableness and hardship requirements continue to constrain any otherwise applicable fee. In particular, the $30 branch is not proof that a debtor necessarily owes $30 regardless of service, circumstances, other legal conditions, or the required hardship policy. The policy requirement calls for an established and implemented mechanism allowing waiver or discontinuance when the debtor cannot pay; this pass does not recast that language as an automatic zero-fee rule for every asserted hardship. [C001, C004]

Disposition: Repeated or submonthly billing remains held. The earlier examples assuming one identified monthly charge remain conditional.

3. Fee-inclusive debit versus money paid for creditor distribution

The exact statutory phrase matters:

“paid by the debtor each month for distribution to the debtor’s creditors”

That is a payment-purpose formulation. It does not expressly say that only creditor payments completed during that same calendar month count. [C005; S001, §4710.02(B)(3)] Ohio Laws

This clarification does not establish whether a bundled debit consists entirely of the statutory base. Three amounts should remain distinct:

Section 4710.02(A)(1) separately addresses disbursement of received funds, with subtraction of contributions not prohibited by division (B), and a debtor-instruction exception. That provision does not expressly reconcile the denominator in (B)(3) with a fee-inclusive debit. It therefore does not, by itself, establish permission to compute a fee on another retained fee. [C006; S001, §4710.02(A)(1), (B)(3)]

A potentially misleading case lead was examined: FTC v. Leshin discusses gross receipts and disgorgement. That discussion concerns a civil-contempt remedy, including fees associated with Ohio contracts and insurance noncompliance. It is not a construction of Ohio’s periodic-fee denominator. It supplies no basis for converting a gross consumer debit into the §4710.02(B)(3) base. [C011; S007, printed pp. 29–33, especially pp. 32–33] media.ca11.uscourts.gov

Disposition: Preserve the fee-inclusive-debit hold. Append a wording guardrail to the prior denominator description, without replacing it with either an approved gross-base or an actual-disbursement-only rule.

4. Stand-alone savings-, principal-, or per-debt success fees

No current controlling authority was established that specifies an independently available Ohio fee pathway for:

• A percentage of negotiated savings;
• A percentage of enrolled principal; or
• A separate success fee for each resolved debt.

The absence of an express schedule does not establish either unrestricted permission or a universal prohibition. The prior hold remains the correct evidentiary disposition. A fee’s collection after success does not itself resolve its permissible state-law category or amount. [C007; S001, §4710.02(A)(3), (B)]

The strongest newly read material that could support a broader argument is an Ohio Attorney General comment submitted to the FTC in 2009. In discussing foreclosure-rescue services, the Attorney General supported restrictions on upfront fees and contemplated legitimate businesses charging after satisfactory results. That is relevant contrary context to an assertion that all post-result compensation is inherently forbidden. But the comment identifies no savings percentage, principal percentage, per-debt schedule, or method for reconciling such compensation with §4710.02(B). It is historical federal-rulemaking advocacy in a mortgage-assistance context, not a current Ohio fee authorization. [C009; S004, printed pp. 3–4, “Prohibition on Upfront Fees”] ftc.gov

The judicial and receivership materials do not supply the missing approval:

[C010, C012–C013; S005–S006, S008–S009] supremecourt.ohio.gov+3

Disposition: PASS-01 C024 remains held, including the absence of an established general lifetime settlement-fee cap. Neither industry fee descriptions nor the existence of a litigated contract supplies the missing legal permission.

B. Actual-source register — documents retrieved and relevant passages read

Access convention A: October 23, 2026 UTC / October 22, 2026 Pacific. “Read” means the operative passages identified below were retrieved and examined. It does not mean every page of a lengthy bill was read.

Each document has one source ID regardless of how many provisions are cited.

Status reconciliation

The operative current-law anchor is S001, corroborated by the relevant enacted amendment in S002. S003 is explanatory legislative history. S004 is a historical agency submission. S005–S008 are judicial documents with the procedural limitations stated above. S009 is a filed request.

None of the historical comment, proposed findings, or receiver’s requested position is elevated here into current binding fee permission. No newly read adopted regulation or adjudication resolving the four held questions was established.

C. Claim table

D. Actual earlier-claim patch map

No substantive fee-permission replacement is warranted. The only addition is a denominator wording guardrail. These are proposed record dispositions in this visible answer; no original record has been edited.

Example disposition

No new worked fee example is warranted because no held legal premise was cleared. The following records preserve the earlier conditional boundaries rather than re-presenting arithmetic as new verification.

E. Failed routes — excluded from the actual-source register

These are the material failed or unreliable retrieval routes, not authorities supporting a fee conclusion. Alternate aliases and irrelevant search hits are omitted. Attempts occurred during access convention A.

No contact, purchase, CAPTCHA workaround, permission expansion, or private docket access was used to overcome these failures.

F. Dependency crosswalk — carried findings and unverified dependencies

G. Component coverage and exact remaining investigations

H. Researcher self-check

Actually read: Current §4710.02; the pertinent enrolled H.B. 699 amendment; the relevant LSC analysis; the 2009 Ohio AG comment; relevant passages in the 2012 Bumpus opinion and the 2014 procedural follow-up; the pertinent Leshin analysis; French’s document status and conclusions; and the receiver’s Ohio-cap passage in StratFS.

Not claimed as read or resolved: Every page of the 461-page act or 85-page analysis; complete inaccessible AG guides and enforcement PDFs; a comprehensive citator history; a later Bumpus merits case; final adoption of French’s proposed findings; or a judicial adoption of the StratFS receiver’s Ohio characterization.

The research used ordinary public-web retrieval in this conversation. No separate regular Chat conversations or verified chatgpt.com model-selector setting are claimed. Parallel research contributions were synthesized into this answer; that process is not independent review.

No local writes, publication, provider authorization, CSO clearance, or publication readiness are claimed. The continuation boundary remains the four expressly held fee questions and the specific missing evidence identified above. All other Ohio dossier categories remain open.

END S_OH PASS-02.