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

S_OK PASS-01 — Oklahoma provider market access and consumer fees

Fresh source-access date: October 25, 2026, Pacific Daylight Time, America/Los_Angeles. Historical baseline: October 22, 2026 only; it is not the verification date. Mode used: regular Chat with GPT-5.6 Sol Pro, the available owner-authorized quality-first fallback; no Deep Research. Component boundary: provider classification, public market access, consumer-fee amount/timing, operative exceptions, and the minimum related enforcement material necessary to answer those questions. This is not a complete Oklahoma debt-law dossier, not an A066 acceptance, and not legal advice.

Bottom-line disposition

Oklahoma’s official Title 24 compilation still states that it was last updated November 18, 2025. Live OSCN text for §§24-131–133 matched that compilation, and DOCC’s March 2026 licensing page plus October 2026 roster show that the CSO licensing program remains operational. A complete 2026 session-law section concordance was not recovered, so post-November-2025 statutory currentness is high-confidence but qualified, not absolute. Oklahoma Legislature+4

A. Substantive answers

1. Current classification of debt adjustment, settlement, DMP, credit counseling, and related fee-taking conduct

1.1 Oklahoma debt pooling is a conduct-based prohibition

Title 24, §24-15 prohibits operating a debt-pooling business. Section 24-16 supplies the operative elements:

1. a contract with a particular debtor;
2. the debtor agrees to make periodic payments to the provider;
3. the provider will distribute those payments among specified creditors under an agreed plan; and
4. the debtor agrees to pay the provider valuable consideration for those services or related services.

The statute therefore turns principally on the contractual fund flow and compensation arrangement, not the marketing label “debt settlement,” “debt management,” “credit counseling,” or “financial wellness.” A provider does not escape §24-16 merely because it also negotiates interest concessions, fee waivers, principal reductions, or revised payment terms. Conversely, a provider that never receives or distributes debtor payments does not satisfy the clearest literal fund-flow elements, although agency, constructive receipt, and account-control theories remain untested here. [C001–C002, C004, C006; S002 §§24-15–16.] Oklahoma Legislature+1

Section 24-17 makes violation a misdemeanor, punishable by a $100–$500 fine, up to thirty days in county jail, or both. No ordinary debt-pooling license or registration pathway appears in §§24-15–18. [C001, C027; S002 §24-17.] Oklahoma Legislature

1.2 The debt-pooling exclusions are narrow and model-specific

Section 24-18 excludes only:

• a retail merchants’ trade association;
• a nonprofit association formed for the purpose of collecting accounts and exchanging credit information;
• bankruptcy actions under federal bankruptcy law; and
• acts of duly licensed attorneys distributing client funds.

A generic nonprofit label is not enough. In particular, the broader 501(c)(3) exclusion in the separate CSO Act does not rewrite §24-18. Likewise, attaching an attorney’s name to a commercial provider is not equivalent to the excluded acts of a duly licensed attorney distributing client funds. [C003, C014; S002 §24-18.] Oklahoma Legislature+1

The exclusions should also not be enlarged by analogy. The CSO Act places the burden of proving a claimed exception or definitional exclusion on the claimant, reinforcing the need to test actual entity and activity facts rather than accept a label. [C012; S002 §24-138(B).] Oklahoma Legislature

1.3 Consumer versus business purpose under the pooling statute

Sections 24-15–18 do not state a personal, family, household, or consumer-purpose limitation. Section 24-1 broadly defines a debtor as one liable or potentially liable to pay money because of an existing obligation. That supports a textual inference that the debt-pooling prohibition is not limited to consumer debts. No controlling Oklahoma appellate decision resolving application to a commercial-debt pooling arrangement was found in this pass, so that conclusion remains an inference rather than a case-tested holding. [C005, C036; S002 §§24-1, 15–18.] Oklahoma Legislature

1.4 The separate Credit Services Organization Act

A “buyer” is an individual. A CSO is a person that, with respect to an extension of credit by others and in return for money or other valuable consideration from any source, more than twelve times in a calendar year provides or represents that it will provide:

• credit-record, history, or rating improvement;
• assistance obtaining an extension of credit; or
• advice or assistance concerning either service.

An “extension of credit” includes the right to defer payment of an existing debt or to incur debt and defer payment, offered primarily for personal, family, or household purposes, and also credit offered to a person whose principal occupation is agricultural. [C008–C009, C034; S002 §24-132; S003 live OSCN §24-132.] Oklahoma Legislature+2

This yields the following classification rules:

The Attorney General’s 1987 loan-broker opinion is not a debt-settlement decision, but it confirms that the statutory phrase “extension of credit” was applied according to its broad payment-deferral language rather than confined to classic credit repair. [C010; S005 ¶¶1–6.] Oklahoma State Courts Network

1.5 Custodial and noncustodial boundaries

Direct custody. When the debtor periodically pays the provider and the provider pays specified creditors under a plan for consideration, the clearest statutory result is prohibited debt pooling. [C001–C004.]

No custody. A negotiator that never receives or distributes debtor funds avoids the clearest §24-16 fund-flow elements. It may nevertheless be a CSO if it obtains payment deferral or markets credit improvement. [C006, C008–C011.]

Dedicated account. A consumer-owned account administered by a separate institution does not automatically establish that the debt-relief provider receives or distributes the funds. The unresolved Oklahoma questions include contractual agency, withdrawal authority, payment instructions, beneficial control, affiliate relationships, processor attribution, and whether the debtor’s payment obligation is legally to the provider or only to the independent account institution. No Oklahoma appellate authority resolving those contemporary facts was found. [C006, C029, C036.]

1.6 Resident and remote-provider nexus

The CSO Act requires a license before engaging in CSO business and penalizes unlicensed activity “in this state.” It requires a resident agent for process and contemplates foreign applicants. DOCC’s current roster includes out-of-state locations, proving that non-Oklahoma businesses can and do obtain CSO licenses. The reviewed statute and rule mirror did not state a precise test based on consumer residence, solicitation location, contract formation, service performance, or fund location. [C007, C023; S002 §§24-141–145; S007; S009.] Oklahoma Legislature+4

The debt-pooling provisions likewise contain no express remote-provider nexus rule. Application of §§24-15–18 to an out-of-state provider serving an Oklahoma debtor remains a choice-of-law and territorial-reach question for the later contracts/case-law pass.

2. Prohibited, licensed, authorized, or exempt status by business model

2.1 Prohibited model

A model satisfying §24-16 is prohibited under §24-15 unless it falls within §24-18. The statutory structure does not authorize DOCC to convert that prohibition into a licensable debt-pooling business. [C001–C004, C014.]

A CSO license evidences authority under the CSO Act. It does not purport to repeal §24-15, enlarge §24-18, or authorize a separate prohibited fund-handling model. A business that fits both statutes must satisfy the CSO Act and avoid prohibited debt pooling or establish a real §24-18 exclusion. [C014; S002 §§24-15–18, 141–143.] Oklahoma Legislature+2

2.2 Licensed model

Section 24-141 requires a person to obtain a license from the Administrator before engaging in business as a CSO. The Department of Consumer Credit administers the Act. Application and bond, government fees, fitness review, and a decision within sixty days are part of the statutory process. [C013, C023; S002 §§24-140–143.] Oklahoma Legislature+2

DOCC’s current public page describes the license as covering work with individuals to improve credit, obtain an extension of credit, or receive related advice and assistance. As of October 15, 2026, DOCC’s public all-locations roster stated that 72 businesses held active CSO licenses. [C023–C024; S006, S008–S009.] Welcome to Oklahoma's Official Web Site+2

2.3 CSO definitional exclusions

The CSO definition excludes:

1. a person authorized and supervised as a lender or extender of credit under state or federal law, and a qualifying HUD-approved lender;
2. an insured bank, savings-and-loan institution, or credit union, and a subsidiary;
3. a 501(c)(3) nonprofit;
4. an Oklahoma-licensed real-estate broker acting within that license;
5. an Oklahoma-licensed attorney acting within the course and scope of legal practice;
6. a qualifying SEC- or CFTC-registered broker-dealer acting within that regulatory scope;
7. a consumer reporting agency under the FCRA;
8. a person authorized to file electronic income-tax returns who receives no consideration for refund-anticipation loans;
9. a residential mortgage broker as statutorily defined; and
10. an insurer authorized in Oklahoma, its affiliates and subsidiaries, and licensed insurance agents.

These are exclusions from the CSO definition, not universal exemptions from debt-pooling law, the TSR, CROA, Oklahoma consumer-protection law, professional-responsibility rules, or other licensing regimes. [C012, C014; S002 §24-132(2)(b).] Oklahoma Legislature+2

2.4 Attorney and nonprofit failure cases

• An attorney-affiliated corporation is not automatically excluded. For the CSO exclusion, the person must be licensed to practice in Oklahoma and render the services within the course and scope of legal practice.
• For debt pooling, the text protects acts of duly licensed attorneys distributing client funds—not every business with attorney ownership, review, referral, or branding.
• A 501(c)(3) is excluded from the CSO definition, but §24-18’s nonprofit language is materially narrower.
• Under §24-138(B), the claimant bears the burden of proving an exception or definitional exclusion. [C003, C012.] Oklahoma Legislature+1

2.5 No affirmative pure-settlement safe harbor established

No reviewed primary source created a distinct Oklahoma “debt settlement company” license for a provider that only negotiates noncustodial, immediate principal reductions and avoids both payment deferral and credit-improvement representations. That result is a classification hold, not a finding that the model is freely permissible. Other potentially applicable regimes—including deceptive-practices law, unauthorized practice, money transmission, contracts, agency, collection law, and federal law—remain outside or only partly within this pass. [C011, C033.]

3. Applicable consumer fee structures, limits, indexing, and refunds

3.1 Debt pooling

For nonexempt conduct satisfying §24-16, the governing result is prohibition. No setup, monthly, distribution, settlement, savings-based, per-debt, or aggregate fee pathway was established. The correct characterization is “prohibited covered model,” not “lawful with a zero-dollar fee cap.” [C001–C004, C019.]

3.2 Oklahoma CSO consumer fees

The reviewed operative CSO provisions require disclosure of the payment terms and the total of all payments the buyer will make to the CSO or another person. They regulate when consideration may be charged or received, but they do not state a numerical setup, monthly, per-debt, settlement, percentage-of-savings, percentage-of-enrolled-debt, or aggregate consumer-service fee ceiling. [C018–C019; S002 §§24-133, 135–137.] Oklahoma Legislature+3

The full set of non-revoked Chapter 30 provisions visible in the quarterly Cornell OAC mirror was inspected. No consumer-service fee ceiling or CPI adjustment provision was found there. Because the official Oklahoma Rules portal could not be read in this tool route, the negative rule finding is qualified by that official-current-text gap. [C019, C025; S010–S013.] Legal Information Institute

Section 24-147’s heading includes the word “fees,” but the provision concerns consumer reporting agencies and access to credit histories. It is not a CSO or debt-settlement service-fee schedule. [C032; S002 §24-147.] Oklahoma Legislature

3.3 State payment timing

Section 24-133(1) prohibits a CSO and its salespersons, agents, representatives, and selling contractors from charging or receiving money or other valuable consideration before full and complete performance of the agreed services unless the organization has both:

• a $10,000 surety bond from an admitted surety; and
• a trust account at a federally insured bank or savings-and-loan association located in Oklahoma.

The exception removes this particular state timing prohibition; it is not a general declaration that every advance fee is lawful. It does not create a §24-18 debt-pooling exclusion and does not override the TSR, CROA, or another applicable law. [C015, C033; S002 §24-133(1); S003 live OSCN §24-133.] Oklahoma Legislature+1

The application instructions operationalize this distinction by requiring evidence of an Oklahoma trust account when upfront consumer funds are collected, while directing applicants that collect no upfront consumer funds to submit a letter saying so. The current application also requires a $10,000 bond for each location. [C015, C017, C023; S007 pp. 5–6.] Welcome to Oklahoma's Official Web Site+2

3.4 Trust-account amount and duration

The statute does not specify a dollar amount to be maintained in the trust account, how deposits are computed, or how long the account must be maintained. In 1987 OK AG 104, the Attorney General concluded that the Administrator lacked delegated authority to invent a specific trust amount or require maintenance until agency release. Therefore:

• the $10,000 figure is the bond amount;
• it must not be copied over as a trust-account balance;
• no CPI or administrator-created trust amount should be inferred; and
• the trust account’s purpose, deposit formula, and duration remain statutory gaps unless later valid authority supplies them. [C016; S004 ¶¶7–10.] Oklahoma State Courts Network

3.5 Cancellation and refunds

Every CSO contract must give the buyer a five-day cancellation right. The prescribed notice states that a payment made under the contract must be returned within ten days after the seller receives the cancellation notice. The quarterly OAC mirror states that the cancellation period does not begin until all disclosures have been properly furnished and defines “days” as calendar days, subject to its computation rule. [C020; S002 §24-137; S011 §§160:30-1-2, 160:30-5-1.] Oklahoma Legislature+4

The contract must also describe all promises of full or partial refunds. The Administrator may order refunds of unlawful charges, and a private claimant may obtain actual damages of at least the amount paid, plus reasonable attorney’s fees and costs, with punitive damages potentially available. No general post–five-day, no-fault pro rata refund formula was located in the reviewed provisions. [C021, C027; S002 §§24-137, 139, 145.] Oklahoma Legislature+2

3.6 Government charges are not consumer fee ceilings

DOCC currently lists:

• $300 investigation fee;
• $200 annual license fee;
• $400 examination fee;
• $900 total initial government charges;
• $600 renewal, consisting of the annual and examination fees;
• $10 per day late charge for up to thirty days after the December 1 renewal deadline;
• $25 amended or duplicate license fee; and
• $25 returned-check fee in the rule mirror.

These are provider-to-government licensing charges. They do not establish what a consumer may be charged. No indexing mechanism was found for either these charges or CSO consumer-service fees. [C022; S006–S007, S012.] Welcome to Oklahoma's Official Web Site+3

4. When fees may actually be requested or received

4.1 Oklahoma-only state timing matrix

Section 24-134 is therefore an employee/agent allocation rule, not a general provider exemption. [C017; S002 §24-134.] Oklahoma Legislature

“Full and complete performance” is not defined for a multidebt settlement contract in the reviewed Oklahoma material. Without the bond/trust exception, the provider should not assume that settling one debt necessarily completes the services promised under an entire multidebt contract. That contract-specific question remains open.

4.2 Federal TSR debt-relief timing, when applicable

The TSR defines a debt-relief service as a represented program or service to renegotiate, settle, or otherwise alter terms of unsecured debt, including balance, interest, or fee reductions. “Telemarketing” requires a plan, program, or campaign using telephones to induce a purchase and involving more than one interstate telephone call. Thus, the federal rules below are common context, not a finding of universal coverage. [C028; S014, 16 C.F.R. §310.2(o), (hh), (ii).] eCFR+1

For a covered debt-relief service, a seller or telemarketer may not request or receive a fee until:

1. at least one debt has been renegotiated, settled, reduced, or otherwise altered under a valid settlement agreement, DMP, or comparable contractual agreement executed by the customer;
2. the customer has made at least one payment under that customer-creditor or customer-debt-collector agreement; and
3. any fee for an individually altered debt is allocated by one of the two prescribed methods:the debt’s enrolled-balance proportion of the total contracted fee; ora constant percentage of actual savings, using the same percentage for each debt.

Actual savings equal the enrolled balance minus the amount actually paid to satisfy that debt. The TSR supplies timing and allocation rules, not a maximum percentage. [C028; S014 §310.4(a)(5)(i).] eCFR+1

The triggering payment must be made under the valid customer-creditor or customer-debt-collector agreement. A deposit into a savings or dedicated account, standing alone, is not the required payment to the creditor or collector. Similarly, an unaccepted creditor offer, an unsigned agreement, or a signed agreement followed by no customer payment does not satisfy both triggers.

4.3 Federal dedicated-account conditions

The TSR does not categorically prohibit requiring a consumer to place funds in a dedicated account, but its safe structure requires:

• an insured financial institution;
• consumer ownership of the funds and accrued interest;
• an administrator not owned, controlled by, or affiliated with the debt-relief service;
• no referral compensation between the administrator and service;
• withdrawal from the service at any time without penalty; and
• return within seven business days of all account funds except fees already earned in compliance with the debt-relief earning rule.

That federal account structure does not answer Oklahoma’s separate debt-pooling question. [C029; S014 §310.4(a)(5)(ii).] eCFR

4.4 Federal credit-improvement timing

When a covered seller or telemarketer represents that services will remove derogatory information or improve a person’s credit history, record, or rating, §310.4(a)(2) bars both requesting and receiving payment until:

1. the represented time for providing all promised goods or services has expired; and
2. the seller has provided the person a consumer report demonstrating that the promised results were achieved, issued more than six months after those results were achieved.

The regulation preserves the FCRA permissible-purpose requirement for obtaining a consumer report. [C030; S014 §310.4(a)(2).] eCFR

4.5 Conditional CROA overlap

CROA can apply where a person uses interstate commerce or the mails, receives consideration, and has an express or implied purpose of improving a consumer’s credit record, history, or rating or provides related advice. Its statutory exclusions include a qualifying 501(c)(3), a creditor restructuring its own debt, and qualifying depository institutions or credit unions and their affiliates or subsidiaries. The text does not contain a general attorney exclusion. [C031, C038; S015, 15 U.S.C. §1679a.] U.S. Code+1

For a covered credit-repair organization, CROA prohibits charging or receiving consideration before the agreed service is fully performed. It also requires a written, dated contract, bars service before the end of the three-business-day period beginning on the signing date, and supplies a three-business-day cancellation right. State law remains applicable except to the extent of an actual inconsistency. [C031; S015 §§1679b, 1679d, 1679e, 1679j.] U.S. Code+3

Accordingly, Oklahoma’s bond-and-trust exception cannot be read as permission to collect an advance fee where the TSR, CROA, or another applicable law still bars it. [C033.]

5. Actual regulator permission, public procedure, and lookup evidence

5.1 Issuing regulator

The Oklahoma Department of Consumer Credit administers the CSO Act, and the Administrator issues CSO licenses. The current agency page links the Act, rules, application, fee information, bond prerequisite, and a stated processing period of up to sixty days. [C013, C023; S002 §§24-140–143; S006.] Oklahoma Legislature+1

5.2 Current application pathway

The March 4, 2024 application currently linked by DOCC requires, among other things:

• completed entity and ownership information;
• a $10,000 bond for each location;
• financial information;
• evidence of an Oklahoma trust account when upfront consumer funds are collected, or a letter stating that no upfront funds are collected;
• entity-formation and foreign-corporation materials where applicable;
• $900 in initial government charges;
• separate branch materials and a $600 branch charge; and
• annual renewal materials and $600 renewal charge by December 1.

The form is operational guidance and evidence of current procedure. It does not enlarge the underlying statute or prove that any particular proposed product is legally covered by the license. [C017, C022–C024; S007.] Welcome to Oklahoma's Official Web Site+6

5.3 Public lookup

DOCC’s regulated-industries page, updated October 19, 2026, links in-state, out-of-state, and all-location CSO rosters. The all-location roster states that each listed business held an active CSO license as of October 15, 2026 and reports 72 active licenses. [C023; S008–S009.] Welcome to Oklahoma's Official Web Site+1

The roster proves only the public license status shown for the listed legal entity and location on that date. It does not establish:

• that every product marketed by the licensee is a CSO service;
• that a debt-settlement product avoids §24-15;
• that the licensee qualifies for an attorney, nonprofit, lender, or other exclusion;
• that a dedicated-account arrangement is lawful;
• that a named provider complies with the TSR or CROA; or
• that a marketing statement accurately describes authorization.

No named-provider status determination was performed. [C024.]

5.4 Official-rule limitation

DOCC links to the Oklahoma Administrative Code portal at https://rules.ok.gov/code, but that official portal could not be opened through the available public-web route. The quarterly Cornell mirror was used to inspect Chapter 30’s non-revoked provisions and the government-fee rule, but it is not a substitute for a freshly read official rule export or adoption order. [C025; S010–S013.] Welcome to Oklahoma's Official Web Site+1

6. Worked fee and boundary examples

The detailed calculations are in Part D. The controlling distinctions are:

• A prohibited pooling model does not become lawful because its fee is small.
• A state CSO fee can be numerically disclosed yet still be premature.
• Oklahoma’s bond/trust exception and the federal TSR earning trigger are different tests.
• A dedicated-account deposit is not an earned settlement fee.
• Under the TSR, prior earnings and the current debt must use the same contractual allocation method and the same original enrolled balances.
• An accepted settlement without the required customer payment still yields a $0 TSR-earned fee.
• A timely Oklahoma cancellation requires return of the payment, while no general post–five-day pro rata formula was established. [C015, C019–C021, C028–C029, C033.]

7. Component result and required next investigations

This pass establishes:

• the prohibited custodial debt-pooling category;
• the separate CSO licensing category;
• operative statutory exclusions;
• the absence of a located numerical Oklahoma CSO consumer-service fee ceiling;
• the state bond/trust payment-timing condition;
• cancellation and identified refund rules;
• the public DOCC application and lookup pathway; and
• conditional federal TSR/CROA timing overlays.

It does not establish a universal answer for every noncustodial principal-reduction provider, every remote transaction, or every dedicated-account structure. Official-current OAC text, complete 2026 session-law reconciliation, contemporary Oklahoma case authority, and several transaction-law dimensions remain open. See the coverage table in Part D.

B. Source table

S_OK-P1-S011 direct-section URL inventory

These were treated as sections of one rule compilation, not as separate invented documents:

Plain text

https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-1-1
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-1-2
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-1.1
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3.1
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3.2
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3.3
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-3-3.4
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-5-1
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-1
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-2
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-3
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-7-5
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-9-1
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-9-2
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-1
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-2
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-3
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-4
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-5
https://www.law.cornell.edu/regulations/oklahoma/OAC-160-30-11-6

C. Claim table

D. Worked examples and scope-coverage table

Example 1 — Direct custodial DMP/debt pooling

Inputs

• Debtor pays provider: $500 each month.
• Provider retains service charge: $25.
• Provider distributes remaining $475 among three named creditors under a prearranged plan.
• No §24-18 exclusion is assumed.

Base

Periodic debtor payment to provider: $500/month.

Operator

Provider receives the periodic sum, distributes it among specified creditors, and receives valuable consideration.

Intermediate

$500 − $25 = $475 distributed.

Result

The facts satisfy the literal §24-16 elements. Section 24-15 prohibits the covered business absent a real §24-18 exclusion.

Units and rounding

Dollars per month; no rounding issue.

Legal consequence

The $25 is not validated merely because it is modest. There is no lawful nonexempt fee calculation to perform. The correct result is prohibited model, not “maximum fee = $0.” [C001–C004.]

Example 2 — Oklahoma CSO timing without and with trust-account qualification

Assumptions

• The provider is otherwise a covered, licensed, noncustodial CSO.
• The agreement promises four integrated services for a total contracted fee of $600.
• Forty percent of internal work is complete.
• No federal rule is considered in the first branch.
• The model does not constitute debt pooling.

Branch A: bond but no qualifying trust account

Inputs

Contracted fee: $600. Performance completed: 40%.

Operator

Section 24-133 bars charging or receiving consideration before full and complete performance unless both the bond and trust conditions are met.

Arithmetic

$600 × 40% = $240 represents an internal progress value, but Oklahoma supplies no progress-payment formula.

Result

Amount chargeable/receivable at this point under the stated Oklahoma branch: $0.

This is a timing result, not a finding that the service’s lawful total fee is $0.

Branch B: accepted $10,000 bond plus qualifying Oklahoma trust account

The particular §24-133 advance-payment barrier is excepted. The total $600 remains subject to:

• contract and total-payment disclosure;
• five-day cancellation;
• any promised refund terms;
• prohibition against fraud or deception;
• federal TSR or CROA timing if applicable; and
• the requirement that the underlying activity not be prohibited debt pooling.

Oklahoma’s exception does not itself say that all $600 is immediately earned. [C015–C016, C018–C019, C033.]

Example 3 — Timely Oklahoma cancellation

Assumptions

• Otherwise lawful CSO contract.
• Provider collected $100 on signing under the state bond/trust branch.
• All required disclosures were properly furnished.
• Buyer delivers written cancellation on calendar day three.
• Seller receives the notice that day.

Base

Payment received: $100.

Operator

Timely five-day cancellation; payment must be returned within ten days following seller’s receipt of notice.

Result

Refund due: $100. Deadline: within ten days after receipt of cancellation notice.

Rounding

None.

Failure branch

If the required disclosures were not properly furnished, the quarterly OAC mirror states that the cancellation period has not begun. Because the official rule portal was unavailable, that branch carries the S010–S011 currentness qualification.

Later-cancellation branch

If cancellation occurs after the statutory five-day period, this example supplies no automatic pro rata formula. Contract refund promises, unlawful-charge relief, other law, and actual performance must be analyzed. [C020–C021.]

Example 4 — TSR proportional-to-enrolled-debt allocation

Assumptions

• TSR applies.
• The Oklahoma service itself is lawful and is not prohibited pooling.
• Two debts were enrolled under one contract.
• Total contracted fee: $2,000.
• The provider consistently uses the proportional-enrolled-balance method.
• Debt A has a customer-executed valid settlement agreement, and the customer has made one payment under it.
• Debt B has not triggered.

Inputs

Debt A enrolled balance: $6,000. Debt B enrolled balance: $4,000. Total enrolled balance: $10,000. Total contracted fee: $2,000.

Operator

Fee for Debt A = total contracted fee × Debt A enrolled balance ÷ total enrolled balance.

Intermediate

$6,000 ÷ $10,000 = 0.60. $2,000 × 0.60 = $1,200.

Result

TSR-earned fee for Debt A: $1,200. Fee for Debt B at this time: $0.

Remaining potential allocation

$2,000 − $1,200 = $800, but that $800 does not become earned until Debt B separately satisfies the required agreement and payment triggers.

Units and rounding

Dollars; exact result, no rounding.

State interaction

If the Oklahoma CSO lacks the bond/trust qualification and has not fully completed the entire agreed service, Oklahoma §24-133 may still be more restrictive than the debt-by-debt TSR trigger. [C015, C028, C033.]

Example 5 — TSR percentage-of-savings method

Assumptions

• TSR applies.
• Provider uses a constant 25% savings fee for every debt.
• Debt A satisfies both federal earning triggers.

Inputs

Debt A enrolled balance: $6,000. Amount actually paid to satisfy Debt A: $3,000. Contractual savings percentage: 25%.

Operator 1: calculate savings

$6,000 − $3,000 = $3,000 savings.

Operator 2: apply constant percentage

$3,000 × 25% = $750.

Result

TSR-earned fee for Debt A: $750.

Failure cases

• The provider cannot use 25% on Debt A and 30% on Debt B.
• It cannot switch Debt B to the proportional-enrolled-balance method merely because that produces a larger fee under the same contracted program.
• An unaccepted offer or a signed agreement without the customer’s first payment produces an earned fee of $0.
• Oklahoma state timing remains independently applicable. [C028.]

Example 6 — Lower debt, prior fee, and later cancellation

Assumptions

• TSR applies.
• Total contracted fee is $400.
• The same proportional method and original enrolled balances apply to both debts.
• Debt B triggers first.
• Debt A never triggers before cancellation.

Inputs

Debt A: $1,200 enrolled. Debt B: $800 enrolled. Total enrolled: $2,000. Total contracted fee: $400.

Debt B operator

$400 × ($800 ÷ $2,000) = $400 × 0.40 = $160.

Result after Debt B trigger

Earned fee for Debt B: $160.

Debt A result at cancellation

Debt A has no executed-and-paid qualifying agreement. Its TSR-earned fee is $0.

Consistency check

The previously earned $160 arose from the same enrolled balances, same total contracted fee, and same proportional allocation method. No second subtraction or method switch is made.

Refund limitation

Whether the already earned $160 must nevertheless be returned under Oklahoma contract law, a timely state cancellation, a specific refund promise, or another remedy depends on facts not supplied here. The TSR arithmetic alone does not answer that separate question. [C020–C021, C028.]

Example 7 — Settlement signed but no creditor payment

Inputs

• Enrolled debt: $5,000.
• Creditor and customer execute a valid settlement for $2,500.
• Customer has not made any payment under the settlement.
• Contracted savings fee: 20%.

Potential arithmetic only

Savings would be $5,000 − $2,500 = $2,500. Potential fee would be $2,500 × 20% = $500.

Trigger analysis

The customer has made no payment under the customer-creditor agreement.

Actual result

TSR-earned fee now: $0.

The $500 is merely a potential future amount if all earning conditions are later satisfied. [C028.]

Example 8 — Dedicated account withdrawal

Assumptions

• TSR applies.
• Consumer deposits $500 in a qualifying independent dedicated account.
• No debt has yet satisfied the agreement-and-payment triggers.
• No lawfully earned fee exists.
• Consumer asks to leave the program.

Base

Consumer-owned account balance: $500.

Lawfully earned fees

$0.

Operator

Return all funds other than fees lawfully earned under §310.4(a)(5)(i).

Result

Amount to return: $500, within seven business days of the request.

Oklahoma hold

This federal result does not decide whether the underlying Oklahoma arrangement constitutes debt pooling. The provider’s legal control, payment instructions, agency relationship, account administrator, and creditor-distribution process still require Oklahoma analysis. [C006, C029.]

Pass coverage and gap table

E. Researcher self-check

Actually read or inspected

• The official Oklahoma Title 24 PDF, including §§24-1, 15–18, and 131–148, with visual inspection of the relevant PDF pages.
• Live OSCN text for §§24-131–133 and the §131 citationizer.
• 1987 OK AG 104 and 1987 OK AG 126 in full relevant part.
• DOCC’s current CSO page, application, regulated-industries roster page, and October 15, 2026 all-locations roster, including visual inspection of the application and roster PDFs.
• Every non-revoked Chapter 30 provision material to licensing, cancellation, bond, records, examination, and enforcement that was visible in the quarterly Cornell mirror, plus the Title 160 government-fee rule.
• Current eCFR text for 16 C.F.R. §§310.2 and 310.4.
• Current U.S. Code text for the cited CROA provisions.
• Targeted official Oklahoma legislative and public OSCN searches for recent amendments and judicial authority.

Not actually read or not established

• An official-current export of Oklahoma Administrative Code Title 160, because rules.ok.gov failed in the available public-web route.
• The underlying Oklahoma Register adoption text at 16 Ok Reg 2145, because the archive returned unsupported JP2/image content.
• A complete section-by-section 2026 Oklahoma session-law concordance.
• A commercial citator’s complete case history for §§24-15–18 and 131–148.
• Any nonpublic agency interpretation, examination manual, advisory letter, enforcement file, application file, or provider correspondence.
• Any named provider’s current product-level authorization, contract, fund flow, federal coverage, or compliance.
• Full Oklahoma funds, bond, remedies, collections, limitations, litigation, property-exemption, secured-debt, sector, local, tribal, contract, choice-of-law, or case-law dimensions.

Method and assertion controls

• Discovery snippets were not treated as operative law.
• The DOCC application and roster were used as procedural evidence, not as substitutes for statutory permission.
• The Cornell rule mirror was expressly identified as secondary and was not represented as the official current OAC.
• The 2025 statutory-compilation date was not silently converted into an October 2026 current-through date.
• No CPI calculation, adjusted consumer fee, trust-account amount, fee ceiling, exemption, or refund formula was invented.
• No CSO license was treated as authority to conduct prohibited debt pooling.
• State fee ceilings and state timing were kept separate from federal TSR and CROA timing.
• Worked examples distinguish arithmetic validity, contractual consistency, actual earning triggers, state model legality, and unresolved refund interpretation.
• No application was filed, no person or agency was contacted, no account or permission was changed, no other Chat was created, and no private borrower information was used.
• No local file was written, and this response is not represented as independently reviewed or publication-ready.
• All remaining Oklahoma parent-state dimensions remain open; no state-level or A066 acceptance is implied.

END S_OK PASS-01.