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S_PA PASS-02 — Pennsylvania DMSA §15(i) annual adjusted fee maxima

Scope: only the current indexed DMSA consultation fee, per-initial-account monthly amount, aggregate monthly maximum, adjustment period/effective trigger, publication trail, and rounding instructions.

Actual public-web access date: October 24, 2026, Pacific.

Bottom line

I cannot authenticate an exact October 24, 2026 dollar maximum for any of the three indexed DMS figures from an operative DoBS annual notice.

What is authenticated is narrower but important:

• The enacted §15 base figures are $50 initial consultation, $10 × accounts initially included, and $50 aggregate monthly maximum. Pennsylvania General Assembly
• Section 15(i) requires annual CPI-linked increases and bars negative adjustments from deflation. Pennsylvania General Assembly
• The Act took effect February 6, 2009. Pennsylvania Government
• DoBS’s January 8, 2009 implementation letter expressly interprets the inflation increases as beginning with the 12-month period following the effective date, and states that DoBS “will publish these fee increases annually in the Pennsylvania Bulletin.” Pennsylvania Government+1
• However, the official January–December 2025 Pennsylvania Bulletin subject index contains no Banking and Securities entry for a DMSA fee adjustment, and the official January–September 2026 subject index likewise contains no such entry. Both indexes list other DoBS notices specifically, including mortgage-rate notices and other adjustments. Pennsylvania Code & Bulletin+3
• The Pennsylvania Bulletin issues immediately around the 2026 anniversary—January 31, February 7, February 14 and February 21—also show no DoBS DMS fee-adjustment notice in their Banking and Securities contents. Pennsylvania Code & Bulletin+3
• The October 24, 2026 current issue likewise contains only “Actions on Applications” under DoBS, not a DMS fee schedule. Pennsylvania Code & Bulletin
• No primary DoBS page or document located in this pass supplied an authoritative current adjusted numerical schedule or a rounding rule.

Accordingly, PASS-01’s hold should remain in force. It would be unsupported to turn §15(i) into a self-calculated 2026 figure, even if the relevant CPI series could be reconstructed.

A. Findings

1. The three statutory starting figures are authenticated, but they are not automatically the October 2026 figures

Section 15(a) says a licensee may charge no more than $50 for the initial consultation. Section 15(b) says the monthly maintenance fee may not exceed $10 times the number of accounts initially included, subject to a $50 total monthly ceiling. Section 15(i), however, immediately subjects “the fee limits provided in this section” to annual inflation adjustment. Pennsylvania General Assembly

Therefore the three relevant starting figures are:

S_PA-P2-C001 through C003.

The fact that unofficial current statute reproductions still print $50 / $10 / $50 does not prove those are the operative indexed dollar figures. Section 15(i) itself says the limits are adjusted annually. The statutory printed figures remain the enacted bases. Pennsylvania General Assembly

2. The adjustment mechanism and relevant anniversary can be bounded

The DMSA was enacted October 9, 2008 and §50 made it effective 120 days later. DoBS’s contemporaneous official letter states the concrete effective date: February 6, 2009. Pennsylvania General Assembly+1

Section 15(i) requires the fee limits to be increased by the percentage change, if any, in the specified CPI-U measure for the “most recent 12-month period” officially reported by BLS immediately before the adjustment is due to take effect, with no negative COLA from deflation. Pennsylvania General Assembly

There is a wording point worth preserving rather than smoothing over:

• The statute says: “For the 12-month period beginning with the effective date of this act, and annually thereafter,” the limits shall be increased. Pennsylvania General Assembly
• DoBS’s January 8, 2009 implementation letter says the initial-consultation and monthly-maintenance fees “are to be increased annually for inflation beginning with the 12-month period following the effective date of the DMSA.” Pennsylvania Government+1

On the agency’s contemporaneous operational reading, the first indexed period followed the initial February 6, 2009–February 5, 2010 year; the recurring adjustment cycle therefore keys to February 6. I am treating that as official agency implementation guidance, not rewriting the statutory text into a judicial holding. S_PA-P2-C004 through C006.

3. DoBS expressly promised annual Pennsylvania Bulletin publication

The January 8, 2009 letter is unusually direct:

“The Department will publish these fee increases annually in the Pennsylvania Bulletin.”

The quoted language is nine words excluding the preceding sentence, within the source quotation limit. The letter specifically identifies the “initial consultation fee” and “monthly maintenance fee” as the two inflation-adjusted fee categories. Pennsylvania Government+1

For the monthly fee, §15(b) itself contains two numerical limits—the per-initial-account amount and the aggregate ceiling. Because the present assignment asks for both numbers, neither is being presumed current without the actual schedule.

S_PA-P2-C007.

4. The current annual notice was not found in the official 2025 or 2026 Bulletin indexes

This is stronger than a generic search failure.

The official January–December 2025 cumulative subject index identifies the Banking and Securities material published in the Bulletin that year. Its DoBS list includes:

• actions on applications,
• the Loan Interest and Protection Law “base figure” adjustment,
• assessments rulemaking,
• the nonregulatory-document catalog,
• IRRC items,
• regulatory agendas,
• a virtual-currency policy rescission,
• and monthly residential-mortgage-rate notices.

There is no indexed Debt Management Services Act fee-adjustment notice. Pennsylvania Code & Bulletin+1

Likewise, the official January–September 2026 cumulative subject index lists the DoBS materials for those nine months—applications, assessments, catalog, agendas, reorganization and monthly mortgage-rate notices—but no DMSA fee-adjustment notice. Pennsylvania Code & Bulletin+1

These are official Bulletin indexes, not search-engine snippets. They substantially weaken the hypothesis that an ordinary indexed annual DMS notice was published in either 2025 or the first nine months of 2026 under a recognizable Banking and Securities entry.

They do not prove that no non-indexed communication, licensing instruction, interpretive letter, examination directive or legacy schedule exists.

S_PA-P2-C008–C009.

5. The 2026 anniversary issues themselves do not contain the notice in their DoBS contents

Because February 6 is the relevant annual timing point under DoBS’s implementation guidance, I separately checked the surrounding Bulletin issues:

• January 31, 2026 — Volume 56 No. 5: DoBS lists only “Actions on Applications.” Pennsylvania Code & Bulletin
• February 7, 2026 — Volume 56 No. 6: DoBS lists only “Actions on Applications.” Pennsylvania Code & Bulletin
• February 14, 2026 — Volume 56 No. 7: DoBS lists “Actions on Applications” plus the March mortgage rate; no DMS fee notice. Pennsylvania Code & Bulletin
• February 21, 2026 — Volume 56 No. 8: DoBS lists only “Actions on Applications.” Pennsylvania Code & Bulletin

As a historical cross-check, February 6, 2010, the first anniversary itself, likewise shows only “Actions on Applications” under the Department of Banking in that issue’s contents. That does not establish what happened in other 2010 issues, but it shows the first anniversary notice was not sitting in the obvious February 6 issue either. Pennsylvania Code & Bulletin

S_PA-P2-C010.

6. Nothing published through October 24, 2026 in the current issue cures the gap

The Pennsylvania Bulletin site identifies Volume 56 No. 43, Saturday, October 24, 2026 as the current issue. Under Department of Banking and Securities it lists only “Actions on Applications.” Pennsylvania Code & Bulletin

The January–September cumulative index says its next cumulative subject index will be published in January, so there is not yet an official January–October cumulative index to rely on. Pennsylvania Code & Bulletin

Thus the strongest current conclusion is:

No operative DoBS annual notice establishing the February 2026 indexed DMSA amounts was authenticated in this pass.

That is not equivalent to saying “no such notice exists.”

S_PA-P2-C011.

7. No rounding instruction was authenticated

Section 15(i) specifies:

• the CPI measure,
• a 12-month comparison period,
• the timing of the official BLS data used,
• and the no-negative-adjustment rule.

It does not, in the text read here, specify whether the adjusted fee limits are rounded to the nearest cent, dime, dollar, whole percentage point or by some other method. Pennsylvania General Assembly

The January 2009 DoBS letter promises annual publication but contains no rounding instruction. Pennsylvania Government+1

Because the requested operative notice was not found, rounding remains HELD. I did not reverse-engineer an amount from CPI data.

S_PA-P2-C012.

B. PASS-02 source register

Supplied evidence not relabeled as new evidence

PASS-01 supplied S002/S009/S010/S016 and claims C020–C022. Those records remain part of the dossier. PASS-02 source IDs above identify documents actually accessed during this pass rather than renaming the supplied records as if newly discovered.

C. PASS-02 material claim register

D. Earlier-claim patch map

No PASS-01 numeric claim is upgraded to a current adjusted dollar amount.

E. Failed-route table

These are failed or nonproductive routes from this pass; they are not substantive evidence of a fee amount.

F. Dependency / missing-evidence table

G. Granular scope coverage / gap table

Researcher self-check

I freshly read the statutory §15 fee and indexing language; the current official 2009 DoBS letter including its fee-publication passage; the official 2025 annual Bulletin index; the official January–September 2026 Bulletin index; the relevant 2026 anniversary issue contents; and the October 24, 2026 current issue. For the PDF sources, the relevant pages were also visually inspected.

I did not obtain or read an operative 2026 DoBS annual fee-adjustment notice because no such primary document was surfaced through the public routes checked. I therefore did not manufacture a fee by CPI arithmetic, did not adopt a secondary state chart, and did not infer a rounding convention.

The supplied coordinator review is reuse context, not independent review, and I do not characterize this self-check as independent review. I did not verify the UI model/mode, make local-save claims, claim Pennsylvania is complete, or claim publication readiness.

Most important patch result: S_PA-P1-C020, C021 and C022 remain numerically held for current indexed values. PASS-02 adds materially stronger primary evidence explaining why that hold remains necessary rather than clearing it.

END S_PA PASS-02