S_RI PASS-02 — bounded correction patch to saved PASS-01
Actual research/access date: October 24, 2026, Pacific
Actual model/mode: Regular Chat, GPT-5.6 Sol Pro, continuing the original authorized session
Patch effect: This response replaces only the identified PASS-01 language concerning cancellation waiver, pre-agreement fee timing, national-model-comment provenance, and abbreviated Rhode Island locators. All other PASS-01 findings, conditions, and open gaps remain unchanged. No CPI calculation, broad Rhode Island rerun, named-provider determination, or whole-state/A066 acceptance is made.
1. Exact replacement patches
1.1 Replace the cancellation portion of P1 A3.4
Replace the PASS-01 paragraph beginning “An individual may cancel before midnight…” with:
Ordinary cancellation, emergency waiver, and refund boundary. An individual ordinarily may cancel an agreement before midnight of the third business day after assent. The agreement’s required cancellation notice states that cancellation during that period results in a refund of all money already paid. If the agreement does not comply with §19-14.8-20(b), §19-14.8-19, or §19-14.8-28, the statutory cancellation period extends to 30 days after assent.
Section 19-14.8-20(c) contains a narrow emergency-waiver route. It applies when a personal financial emergency requires disbursement of the individual’s money to one or more creditors before three days have expired after the agreement was signed. The individual must send or deliver a signed and dated statement that:
- is written in the individual’s own words;
- describes the circumstances necessitating the waiver; and
- expressly waives the right to cancel.
A waiver made through a standard-form record is void. Accordingly, the ordinary three-business-day/full-refund discussion and Worked Example 8 assume that no valid §19-14.8-20(c) waiver was executed. The waiver provision addresses the state cancellation right; it does not itself authorize a provider fee, establish that provider compensation is payable, satisfy another state fee condition, or permit collection before the independently applicable federal TSR trigger. Rhode Island Legislature
Replacement for P1 claim C027
| Original claim ID |
Exact replacement assertion |
Corrected sources and limits |
| S_RI-P1-C027 — replaced |
The ordinary cancellation period is three business days after assent, with the required notice promising a refund of all money already paid during that period. A noncompliant agreement can produce a 30-day cancellation period. A consumer may waive the cancellation right only through the personal-financial-emergency procedure in §19-14.8-20(c): creditor disbursement is needed before three days after signing expire; the consumer supplies a signed, dated, own-words statement describing the circumstances and expressly waiving cancellation; a standard-form waiver is void. |
S_RI-P2-C001 and C002; S_RI-P2-S001, §20(a)–(c). The waiver is not treated as advance-fee authorization, automatic provider-compensation authorization, or a TSR exception. Rhode Island Legislature |
1.2 Replace Worked Example 8
Example 8 — Ordinary three-business-day cancellation, with no valid emergency waiver
Assumed inputs
- Hypothetical setup amount already paid: $300
- Hypothetical monthly amount already paid: $50
- The consumer properly cancels during the ordinary three-business-day period.
- No valid §19-14.8-20(c) emergency waiver exists.
- The assumed payments are used solely to illustrate the refund arithmetic; they do not establish that either payment amount or its collection timing was otherwise lawful.
Calculation
Refund = $300 + $50 = $350
Conditional result
Under the required cancellation notice, all money already paid is refunded, producing $350 on these assumed inputs.
This result does not govern when the individual executed a valid emergency waiver satisfying every element of §19-14.8-20(c). The waiver does not by itself validate either assumed fee, create a provider-compensation right, or override independently applicable federal TSR timing. Later termination, trust-money return, and fee-credit questions remain governed by their own provisions. Rhode Island Legislature
1.3 Replace the cancellation/refund row in the P1 coverage table
| Pass component |
Corrected status |
Corrected claim support |
Remaining boundary |
| Cancellation and fee refunds |
Answered within this fee-access pass, subject to emergency-waiver and later-termination boundaries |
P1 C023 and C028, as retained; P1 C027 replaced by P2 C001–C002 |
Ordinary three-business-day cancellation/full refund assumes no valid §20(c) waiver. A valid waiver requires the consumer’s signed, dated, own-words emergency statement and cannot use a standard form. The waiver’s interaction with disputed formation, electronic-signature proof, private remedies, or other non-fee issues remains for later passes. It is not TSR advance-fee permission. |
2. Correction to P1 A4.1 and C018
2.1 Replace the “No pre-agreement collection” shorthand
Replace P1 A4.1 item 1 with:
Agreement prerequisite for debt-management-service charges, with a separate conditional no-agreement counseling route. Section 19-14.8-23(b) prohibits a provider from imposing charges or receiving payment for debt-management services until the provider and individual have signed an agreement complying with §§19-14.8-19 and 19-14.8-28. It should not be restated as an unqualified prohibition on every receipt before an agreement.
Section 19-14.8-23(d)(4), subject to §19-14.8-28(d), separately permits a provider to receive a fee for educational or counseling services when the individual does not assent to an agreement. That fee is limited to the current §19-14.8-32(f)-adjusted ordinary ceiling unless the director has actually approved a larger amount based on the nature and extent of the services. The exact current adjusted ordinary ceiling and any provider- or program-specific director approval remain unresolved.
If the individual enters an agreement before 90 days have expired after the counseling or education ends, §19-14.8-23(e) requires the provider to refund the fee collected under subsection (d)(4). Conversely, when an individual does enter an agreement, subsection (c) generally bars an added educational or counseling charge unless the director authorizes one based on the nature and extent of the services or §19-14.8-28(d) applies.
This conditional counseling route does not mean that all counseling is outside the Act, does not transform counseling into debt-management services, does not eliminate registration or other applicable conditions, and does not authorize collection of debt-settlement compensation before the TSR’s independently applicable performance trigger. Rhode Island Legislature+1
Corrected state-law timing sequence
- Debt-management-service charges: signed compliant agreement required by §23(b).
- No-agreement education/counseling fee: possible only through §23(d)(4), within the unresolved adjusted ceiling or an actual director-approved larger amount, and subject to §28(d).
- Agreement follows within 90 days: full refund of the §23(d)(4) counseling fee.
- Agreement-based settlement/DMP fees: remain subject to their separate state fee bases and credits.
- TSR-covered transaction: a signed agreement alone does not permit collection before the federal performance and consumer-payment conditions.
2.2 Replacement for P1 claim C018
| Original claim ID |
Exact replacement assertion |
Corrected sources and limits |
| S_RI-P1-C018 — replaced |
Rhode Island prohibits imposing charges or receiving payment for debt-management services before the provider and individual sign an agreement satisfying §§19-14.8-19 and 19-14.8-28. That prerequisite does not eliminate §23(d)(4)’s distinct, conditional fee pathway for education or counseling when no agreement is entered. Such a counseling fee remains subject to the current adjusted ceiling or actual director approval and must be refunded if an agreement follows within 90 days. |
S_RI-P2-C003–C004; S_RI-P2-S001, §23(a)–(e). Exact adjusted amount held. No conclusion that every counseling service is exempt, that every provider may charge it, or that a signed agreement satisfies federal TSR timing. Rhode Island Legislature+1 |
2.3 Replace the boundary language in Worked Example 9
Example 9 — Counseling without an agreement, followed by an agreement within 90 days
Assumed facts
- The provider supplies educational or counseling services.
- At completion of those services, the individual has not assented to an agreement.
- A fee F was lawfully collected under §19-14.8-23(d)(4).
- F was within the then-current adjusted ceiling or was supported by an actual director approval.
- The individual enters an agreement 45 days after the counseling ends.
Condition
45 days < 90 days
Result
Required refund = 100% × F
This is a refund rule for the conditional no-agreement counseling fee. It is not a settlement-fee trigger, does not establish the current dollar ceiling, and does not permit TSR-covered debt-relief compensation before federal performance. If the provider could not satisfy §23(d)(4), §28(d), the current adjusted ceiling, or an actual director approval, the example does not independently validate the original collection. Rhode Island Legislature
The earlier 45 < 90 arithmetic remains unchanged.
3. Correction to S004 and comment-dependent PASS-01 claims
3.1 Governing provenance correction
Rhode Island’s enactment was enacted on June 30, 2006 and took effect March 31, 2007. The enacted §19-14.8-43 says that the “official comments to this chapter” express legislative intent and are an interpretive guide. Rhode Island Legislature+1
The FTC-hosted Uniform Debt-Management Services Act PDF accessed in PASS-01 is not identified as a 2006 Rhode Island legislative attachment. Its cover says it was last revised or amended in 2008 and is dated March 6, 2008. The Uniform Law Commission archive separately lists a 2005 approved text, January 2008 amendments, and the final 2008 act, confirming that distinct versions exist. Federal Trade Commission+1
Section 19-14.8-43 therefore supports interpretive force for the official comments accompanying Rhode Island’s chapter, but it does not, by its own language, automatically authenticate every passage in the later 2008 national-model PDF as the exact comment text adopted by Rhode Island in 2006. The 2008 national text remains useful as later model commentary where wording is aligned, but it must be attributed that way unless the applicable 2005/2006 comment version is authenticated.
This distinction is consequential, not merely bibliographic:
- Rhode Island’s enacted and current §23(d)(2) applies when an individual assents to a plan contemplating principal-reduction settlements.
- Rhode Island’s enacted and current §23(f) likewise begins when a plan contemplates settlement.
- The 2008 national-model text instead uses agreement in those locations. Rhode Island Legislature+2
The later national wording cannot be imported to eliminate Rhode Island’s “plan” limitation. The PASS-01 hold concerning fees for covered one-time/no-plan negotiation therefore remains in place.
3.2 Exact replacement for P1 source S004
| Source ID |
Exact replacement source description |
| S_RI-P1-S004 — replaced by S_RI-P2-S004 |
Uniform Debt-Management Services Act, national model text with prefatory note and comments, National Conference of Commissioners on Uniform State Laws, FTC-hosted PDF. Direct URL: https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf. The cover identifies the document as “Last Revised or Amended in 2008” and dates it March 6, 2008. Relevant passages used in PASS-01 appear at PDF-render pages P15, P19, P22, P58, and P65–P70. The file was freshly opened, parsed, and visually inspected in PASS-02. Legal-status limitation: this is later national-model commentary, not independently authenticated as the exact comment version accompanying Rhode Island’s 2006 enactment. Rhode Island statutory text controls where wording differs. Section 19-14.8-43 supports the official comments to Rhode Island’s chapter as an interpretive guide, but no Rhode Island-hosted 2006 comment set or successfully retrieved 2005 approved-comment file was available in this bounded pass. Federal Trade Commission+3 |
3.3 Exact replacement qualifications for P1 C003–C008
| P1 claim |
Replacement/qualification |
| C003 — qualified, core conclusion retained |
Rhode Island’s direct text defines “concessions” as more favorable repayment terms, and §23(d)(1)–(2) directly addresses reductions in finance charges, late/default/delinquency fees, and principal-reduction settlement plans. Those direct provisions support the core classification without depending solely on the 2008 commentary. The fuller example list appearing on model PDF P15 is now attributed as later national-model commentary consistent with the Rhode Island text, not authenticated Rhode Island-2006 comment text. Confidence remains high for the enumerated statutory categories. Rhode Island Legislature+1 |
| C004 — qualified |
Rhode Island’s broad intermediary definition and its separate definition of “plan” support the distinction between covered services and plan-based services. The specific statements that money need not flow through the provider and that one-time, no-plan assistance is covered come from the 2008 national-model comment at P15. They remain persuasive where the definitions align, but are not described as authenticated Rhode Island-2006 commentary. The no-plan classification conclusion remains supported; the no-plan consumer-fee pathway remains held. Federal Trade Commission |
| C005 — qualified, core conclusion retained |
The conclusion that pure education without creditor intermediation is outside the definition and that a creditor acting solely for itself ordinarily is not an intermediary follows principally from Rhode Island’s functional statutory language. The corresponding examples at model PDF P15/P17 are later national commentary and corroboration, not separately authenticated Rhode Island comments. Other laws remain open. Federal Trade Commission+1 |
| C006 — qualified |
The attorney exclusion’s elements come directly from Rhode Island §2(9): qualifying legal services, a Rhode Island-authorized attorney, and an attorney-client relationship. The statement that attorney ownership alone is insufficient is consistent with those direct conditions and appears in later national commentary, but should not be presented as a quotation from an authenticated Rhode Island-2006 comment set. The substantive conclusion remains strong; fact-specific professional-services and unauthorized-practice issues remain open. |
| C007 — confidence reduced for the business/farming example |
Rhode Island uses “individual,” distinguishes individuals from entities, and contains no express consumer-purpose limitation in the cited definition. The specific explanation that personally incurred business or farming debt is included appears in model PDF P22, a later 2008 comment. That application is therefore retained only as a qualified interpretation, not a directly authenticated Rhode Island legislative comment. Entity-only debt remains unresolved. Federal Trade Commission |
| C008 — split between direct law and later examples |
The absence of a physical-presence requirement and the Rhode Island-resident registration nexus are supported directly by Rhode Island §§3–4 and chapter 19-14. The more detailed examples involving temporary residents, later relocation, agent knowledge, and passive website accessibility derive from later national-model commentary and are now expressly qualified on that basis. The direct remote-provider rule remains high confidence; those edge examples are persuasive but not established here as controlling Rhode Island holdings. |
3.4 Exact replacement qualifications for P1 C022, C028–C030, C037, and C039
| P1 claim |
Replacement/qualification |
| C022 — partially retained, partially qualified |
Rhode Island §23(d)(3) directly prohibits imposing or receiving both the DMP and principal-reduction setup/monthly fee sets. That part remains high confidence. The “predominant approach” method for selecting the setup-fee branch in a mixed plan and the instruction to aggregate creditors across components appear in the 2008 model comment at P69. They are now treated as later national-model interpretive guidance, not authenticated Rhode Island-2006 comment text. Exact Rhode Island application remains held absent an authenticated applicable comment, DBR interpretation, or controlling decision. Rhode Island Legislature+1 |
| C028 — direct refund rule retained; sequencing qualified |
Rhode Island §§19(d) and 26(b) directly establish the 65% refund of the uncredited settlement setup fee and the applicable return-of-funds duties. The instruction to credit monthly fees before the setup fee when computing the refund appears at model PDF P58. It is now an illustrative later-model sequencing assumption, not an established Rhode Island rule in this pass. Rhode Island Legislature+2 |
| C029 — qualified provenance, direct custody boundary retained |
Rhode Island §22 directly governs money received by the provider or its designee for creditor distribution. The detailed discussion of consumer-controlled accounts and noncustodial arrangements comes from later national-model commentary. The classification conclusion remains supported by the broad Rhode Island definition, but commentary-derived examples are qualified. Full funds/account treatment remains open. |
| C030 — hold reaffirmed and strengthened |
One-time/no-plan assistance may fall within the broad definition of debt-management services, based on aligned definitions and later model commentary. No affirmative Rhode Island consumer-fee pathway has been established for a truly no-plan arrangement. Rhode Island §23(d)(2) and (f) use plan, while the later 2008 model uses agreement. The later model wording cannot cure the Rhode Island statutory gap. No negotiation fee may be invented from the model text. Rhode Island Legislature+2 |
| C037 — direct credit requirement retained; characterization qualified |
Rhode Island §23(f) directly requires credits for qualifying setup and aggregate monthly charges not already credited against an earlier settlement fee. The characterization of those charges as cash-flow “advances” and the settlement fee as the provider’s real compensation comes from the 2008 model comment at P70. That characterization is now attributed only to later national-model commentary. Rhode Island Legislature+1 |
| C039 — direct result retained |
Rhode Island §23(d)(1)(B) and (d)(2)(B) directly use the number of creditors remaining in the plan when the monthly fee is assessed. The core claim therefore does not depend on the 2008 comment. The two-creditor worked illustration in that comment remains an illustration only, and no printed dollar figure is represented as the verified 2026 adjusted amount. Rhode Island Legislature+1 |
3.5 Required patch to Worked Example 7
Retain the arithmetic, but replace its introductory assumption and final legal conclusion with:
Sequencing assumption: This illustration assumes that monthly fees are credited before the setup fee when determining the uncredited setup amount. That ordering appears in the 2008 national-model comment at PDF P58. The Rhode Island statutory text requires credits and a 65% refund of the uncredited setup portion but does not expressly state the ordering between monthly and setup credits. Because the exact Rhode Island-adopted 2006 comment version has not been authenticated, the monthly-first sequence and the resulting $143 figure are illustrative and conditional rather than an established Rhode Island application. Exact sequencing remains held pending the applicable Rhode Island comment text, a DBR interpretation, or controlling authority. Federal Trade Commission+2
The original arithmetic does not need to be rerun.
3.6 Funds-context preservation note
No automatic netting or deadline correction is made to PASS-01 beyond preserving the separate statutory contexts:
- Section 22(h): if the individual terminates or a plan has failed, the provider must promptly refund money not paid to creditors, less fees that are actually payable under §23.
- Section 26(b): if either party terminates the agreement, the provider must immediately return money of the individual held in trust and return 65% of the uncredited settlement setup fee.
- Section 19(d): the agreement must state the individual’s termination and refund rights.
Those provisions overlap but are not collapsed here into a single netting rule. This patch does not decide whether a disputed fee is “payable,” whether a particular amount is trust money, or how inconsistent timing duties would be remedied. Rhode Island Legislature+2
4. PASS-02 source table
| Source ID |
Title / issuer / legal status |
Full direct literal URL and exact pinpoints |
Actual PASS-02 access and limitations |
| S_RI-P2-S001 |
Rhode Island General Laws, chapter 19-14.8, Uniform Debt-Management Services Act; Rhode Island General Assembly current online codification |
Complete section URLs appear in the expanded locator table below. Correction pinpoints: §20(a)–(c); §23(a)–(g), especially (b)–(f); §43; §§19(d), 22(h), 26(b); definitions and access sections as listed. |
Accessed October 24, 2026. Fresh substantive read of §§2, 3, 4, 19, 20, 22, 23, 24, 26, 32, and 43. Remaining listed sections received fresh locator/title/pinpoint verification only; their substantive P1 treatment was not broadly re-adjudicated. The online General Laws remain subject to the official site’s provisional-publication caveat carried forward from P1. |
| S_RI-P2-S002 |
R.I. Gen. Laws §19-14-4, general licensed-activities fee section |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-4.htm — subsection (a)(7) |
Accessed and freshly read October 24, 2026. Used only to preserve the provider-to-state $200 registration-fee claim; no NMLS charge conclusion. |
| S_RI-P2-S003 |
Rhode Island Public Laws 2006, chapter 243; enacted chapter text |
https://webserver.rilegislature.gov/PublicLaws/law06/law06243.htm — enactment date at page beginning; enacted §23 at lines corresponding to subsections (a)–(f); enacted §43 and effective-date clause near the end |
Accessed and freshly read October 24, 2026. Enacted June 30, 2006; effective March 31, 2007. Used to compare Rhode Island’s enacted wording with the later national model. The current section histories also cite P.L. 2006 ch. 291; that companion act was not substantively re-reviewed in this correction. Rhode Island Legislature+4 |
| S_RI-P2-S004 |
Uniform Debt-Management Services Act, national model with comments; NCCUSL/ULC, FTC-hosted PDF |
https://www.ftc.gov/sites/default/files/documents/public_events/consumer-protection-and-debt-settlement-industry/udmsafinal.pdf — cover P0; definitions comments P15; residence material P19; “individual”/remote-provider comment P22; refund sequencing P58; fee text/comments P65–P70 |
Accessed, parsed, and visually inspected October 24, 2026. Cover says last revised/amended in 2008 and dated March 6, 2008. Later national-model material, not authenticated here as the exact comment edition accompanying Rhode Island’s 2006 enactment. Federal Trade Commission+3 |
| S_RI-P2-S005 |
Uniform Law Commission UDMSA archive/version index |
https://www.uniformlaws.org/viewdocument/committee-archive-53?CommunityKey=e327d09d-edb7-4f3c-95c9-f32a5679e7c1&tab=librarydocuments — entries for Final Act 2008, January 2008 Amendments, and 2005 Annual Meeting Approved Text |
Accessed October 24, 2026. The index establishes that distinct 2005 and 2008 files exist. The 2005 approved-text download did not produce a readable source through the public route in this pass, so its text/comments were not treated as read. Uniform Law Commission |
Failed exact-version retrieval route
The ULC archive’s 2005 approved-text download was attempted through the public Higher Logic document route:
https://www.uniformlaws.org/HigherLogic/System/DownloadDocumentFile.ashx?DocumentFileKey=cba65649-fd9a-7fc9-f67f-06e59e2684f9&forceDialog=0
The route redirected to an inaccessible/expiring storage target and did not yield a readable document in this public-web session. Consequently, this pass does not authenticate the 2005 approved comments or compare them line by line with Rhode Island’s enacted chapter.
5. Expanded direct-literal Rhode Island locator replacing P1 S002’s abbreviated URLs
All entries below use S_RI-P2-S001 unless otherwise stated. “Fresh substantive read” means the relevant statutory passages were read for this correction. “Locator verified only” means the full URL, section identity, and relevant P1 pinpoint were confirmed, but the underlying P1 analysis was not broadly reopened.
| Section and P1 use |
Complete direct literal URL |
Exact pinpoint |
PASS-02 treatment |
| §19-14.8-2 — definitions |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-2.htm |
(7), (9), (10), (12)–(17), (20) |
Fresh substantive read; used in the comment-provenance correction. |
| §19-14.8-3 — exempt agreements/persons |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-3.htm |
(a)–(c) |
Fresh substantive read; no broad exemption rerun. |
| §19-14.8-4 — registration |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-4.htm |
(a)–(c) |
Fresh substantive read; registration conclusion unchanged. |
| §19-14.8-5 — application form, fee, accompanying documents |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-5.htm |
Entire section, especially (a) and (b) |
Locator verified only; P1 substantive read remains attributed to P1. |
| §19-14.8-6 — application information |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-6.htm |
Entire section, including organizational, regulatory, financial, agreement-form, fee-schedule, accreditation, and records-check items |
Locator verified only; no application-checklist rerun. |
| §19-14.8-9 — issuance of certificate |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-9.htm |
(a)–(d) |
Locator verified only. |
| §19-14.8-10 — timing of decision |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-10.htm |
Entire section |
Locator verified only. |
| §19-14.8-11 — renewal |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-11.htm |
Entire section |
Locator verified only. |
| §19-14.8-13 — bond |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-13.htm |
Entire section |
Locator verified only; adjusted bond amount remains open. |
| §19-14.8-14 — substitute for bond |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-14.htm |
Entire section |
Locator verified only. |
| §19-14.8-17 — prerequisites to services |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-17.htm |
(a)–(d), including (d)(5) |
Locator verified only; P1 disclosure/creditor-compensation treatment unchanged. |
| §19-14.8-19 — agreement requirements and termination terms |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-19.htm |
(a), (b), and especially (d)(1)(A)–(C) |
Fresh substantive read, including refund boundary. Rhode Island Legislature |
| §19-14.8-20 — cancellation and waiver |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-20.htm |
(a) ordinary/extended cancellation; (b) required notice/full refund; (c) emergency waiver |
Fresh substantive read; principal PASS-02 correction. Rhode Island Legislature |
| §19-14.8-22 — trust account |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-22.htm |
(a)–(i), especially (h) |
Fresh substantive read, limited to preserving the refund context. Rhode Island Legislature |
| §19-14.8-23 — fees and other charges |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-23.htm |
(a)–(g), especially (b), (c), (d)(2)–(4), (e), and (f) |
Fresh substantive read; principal PASS-02 correction. Rhode Island Legislature+1 |
| §19-14.8-24 — voluntary contributions |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-24.htm |
Entire section |
Fresh substantive read; no change to P1 conclusion. |
| §19-14.8-25 — voidable agreements |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-25.htm |
Entire section |
Locator verified only; remedies remain open. |
| §19-14.8-26 — termination of agreements |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-26.htm |
(a)–(b), especially (b)(1)–(2) |
Fresh substantive read, limited to refund-context preservation. Rhode Island Legislature |
| §19-14.8-27 — periodic reports |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-27.htm |
Entire section |
Locator verified only. |
| §19-14.8-28 — prohibited practices |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-28.htm |
Entire section, especially (d) |
Locator verified only; no prohibited-practices rerun. |
| §19-14.8-32 — director’s powers and dollar adjustments |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-32.htm |
Especially (f)–(g) |
Fresh substantive read; current adjusted amounts remain held. |
| §19-14.8-43 — official comments |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14.8/19-14.8-43.htm |
Entire section |
Fresh substantive read; central provenance provision. Rhode Island Legislature |
| §19-14-4 — annual state fee |
https://webserver.rilegislature.gov/Statutes/TITLE19/19-14/19-14-4.htm |
(a)(7) |
S_RI-P2-S002; fresh substantive read. No NMLS charge conclusion. |
The completed URLs above replace P1 S002’s abbreviated .../ locators. Expanding a URL is not represented as a new substantive investigation for the rows marked “locator verified only.”
6. PASS-02 claim table
| Claim ID |
Precise corrected assertion |
Sources and pinpoints |
Conditions and confidence limits |
| S_RI-P2-C001 |
Rhode Island permits an emergency waiver of the cancellation right only when a personal financial emergency requires disbursement of the individual’s money to one or more creditors before three days after signing expire, and the consumer supplies a signed, dated, own-words statement describing the circumstances and expressly waiving cancellation. A standard-form waiver is void. |
S001, §20(c). |
High confidence from direct current Rhode Island text. Rhode Island Legislature |
| S_RI-P2-C002 |
A valid §20(c) waiver changes the ordinary cancellation-right analysis but does not, by itself, authorize provider compensation, validate a fee, satisfy §23, or displace TSR timing. |
S001, §§20(c), 23(a)–(f); federal TSR context retained from P1. |
First part direct; fee/TSR limitation is a bounded synthesis preventing overreading. No broader remedies conclusion. Rhode Island Legislature+1 |
| S_RI-P2-C003 |
Section 23(b)’s signed-agreement prerequisite is textually limited to imposing charges or receiving payment for debt-management services. |
S001, §23(a)–(b). |
High confidence. It should not be paraphrased as a categorical prohibition on every pre-agreement receipt. Rhode Island Legislature |
| S_RI-P2-C004 |
When no agreement is entered, §23(d)(4) conditionally permits a fee for education/counseling within the unresolved adjusted amount or an actual director-approved larger amount; §23(e) requires refund if an agreement follows within 90 days. |
S001, §23(c), (d)(4), and (e). |
Exact adjusted amount, actual approvals, and §28(d) applications remain held. It is not a settlement-fee pathway. Rhode Island Legislature |
| S_RI-P2-C005 |
Rhode Island enacted the chapter in 2006, effective March 31, 2007, while the accessed national-model PDF identifies itself as revised or amended in 2008 and dated March 6, 2008. |
S003, enactment heading and effective-date clause; S004 cover P0. |
High confidence on chronology. Rhode Island Legislature+2 |
| S_RI-P2-C006 |
Section 43 gives interpretive status to the official comments “to this chapter,” but the accessed 2008 national-model file was not authenticated in this pass as the exact comment version accompanying Rhode Island’s 2006 enactment. |
S001, §43; S004 cover; S005 version archive. |
Direct Rhode Island text controls. Later comments may be persuasive where aligned, but are not automatically incorporated. Exact 2005/2006 comment set unresolved. Rhode Island Legislature+2 |
| S_RI-P2-C007 |
Rhode Island §23(d)(2) and (f) use “plan”; the accessed 2008 model uses “agreement” in the parallel locations. |
S001/S003, enacted and current §23(d)(2), (f); S004 P65–P66. |
Material divergence. The later model cannot create a Rhode Island no-plan fee pathway. Rhode Island Legislature+2 |
| S_RI-P2-C008 |
The monthly-fees-first refund sequence appears in the 2008 national-model comment but is not stated expressly in the Rhode Island statutory text reviewed. |
S004 P58; S001 §§19(d), 23(f), and 26(b). |
Worked Example 7 remains mathematically correct only under that assumed sequence. Exact Rhode Island ordering is held. Federal Trade Commission+2 |
| S_RI-P2-C009 |
Direct Rhode Island statutory propositions retain their direct-law confidence; factual elaborations sourced only to the 2008 national comments must be attributed as later model commentary unless the applicable Rhode Island comment version is authenticated. |
S001, S003–S005. |
Applies specifically to corrected P1 C003–C008, C022, C028–C030, C037, and C039. |
| S_RI-P2-C010 |
Section 22(h)’s prompt refund, less fees actually payable under §23, and §26(b)’s immediate return of trust money plus the 65% uncredited-setup refund are distinct commands and are not collapsed into a single netting/deadline rule in this pass. |
S001, §22(h) and §26(b). |
Full funds, fee-payability, remedies, and reconciliation analysis remains open. Rhode Island Legislature+1 |
| S_RI-P2-C011 |
The prohibition on collecting both fee schedules is direct Rhode Island law; the predominant-plan and mixed-creditor methodology comes from later national commentary. |
S001, §23(d)(3); S004 P69. |
Direct prohibition high confidence; commentary-derived mixed-plan method qualified. Rhode Island Legislature+1 |
| S_RI-P2-C012 |
The number of creditors remaining when the fee is assessed is a direct Rhode Island statutory input, independent of the later comment’s worked illustration. |
S001, §23(d)(1)(B), (d)(2)(B). |
High confidence on the operator; current dollar inputs remain held. Rhode Island Legislature |
| S_RI-P2-C013 |
PASS-01’s exact percentage and formula arithmetic remains conditional and does not establish current dollar permission, lawful collection timing, or provider authorization. |
S001, §§23 and 32(f)–(g); corrected claims above. |
No calculation of a current adjusted amount was made. |
7. Correction coverage and remaining exact gaps
| Correction item |
Status after PASS-02 |
Supporting claims |
Exact remaining authority or next action |
| Emergency cancellation waiver |
Resolved at statutory-text level |
P2 C001 |
Later agreement/remedies/e-signature treatment remains outside scope. |
| Effect on ordinary full-refund example |
Resolved conditionally |
P2 C001–C002 |
Example applies only without a valid §20(c) waiver. Consequences after a valid waiver require separate termination/funds analysis. |
| Whether waiver authorizes compensation or TSR advance collection |
Resolved negatively as an overreading boundary |
P2 C002 |
Actual fee must satisfy its own state and federal conditions. |
| “No pre-agreement collection” shorthand |
Corrected |
P2 C003–C004 |
Exact adjusted counseling ceiling and any director-approved larger fee remain unresolved. |
| No-agreement counseling route |
Answered structurally |
P2 C004 |
Obtain current §32(f) amount and actual approval order before assigning a current dollar figure. |
| 90-day counseling refund |
Answered |
P2 C004 |
Contract/remedy enforcement remains later work. |
| National-model PDF version |
Resolved |
P2 C005 |
It is the 2008 national version, not automatically the 2006 Rhode Island comment edition. |
| Exact Rhode Island-adopted comment version |
Unresolved |
P2 C006 |
Retrieve a readable 2005 approved text/comments file, Rhode Island legislative file, authenticated bill attachment, DBR adoption record, or controlling decision identifying the applicable comments. |
| RI/model §23 “plan” versus “agreement” divergence |
Resolved |
P2 C007 |
No-plan consumer fee pathway remains held. |
| One-time/no-plan service classification |
Partial |
P1 C004/C030 as corrected; P2 C006–C007 |
Direct Rhode Island or controlling authority specifically applying the broad definition to no-plan negotiation remains desirable. |
| One-time/no-plan consumer fee |
Unresolved |
P2 C007 |
Need Rhode Island statute, rule, DBR interpretation, order, or controlling case creating an affirmative fee pathway. Do not import 2008 “agreement” wording. |
| Monthly-first credit sequence |
Unresolved for exact Rhode Island application |
P2 C008 |
Authenticate the applicable Rhode Island comment version or locate DBR/court guidance. |
| Mixed-plan predominant approach |
Qualified/partial |
P2 C011 |
Same authenticated-comment/agency/case authority needed. |
| Remaining-creditor fee operator |
Resolved directly |
P2 C012 |
Current adjusted per-creditor and aggregate dollar amounts remain held. |
| §22(h) versus §26(b) funds wording |
Contexts preserved; no error declared |
P2 C010 |
Full funds, payability, netting, deadline, insolvency, and remedies analysis remains open. |
| Complete direct Rhode Island URLs |
Resolved for all P1 S002 sections |
S001 locator annex; S002 |
Rows marked locator-only were not substantively rerun. |
| Current adjusted dollar amounts |
Still unresolved |
P2 C004, C013; P1 C019–C025/C035 |
Find adjustment rule, orders, notices, archives, and complete history; no CPI invention. |
| Current NMLS checklist and charges |
Still unresolved |
P1 C012/C033 |
Retrieve current public checklist and system charges without authenticated access or account changes. |
| Named provider/DBA status |
Still unresolved |
P1 C033 |
Perform exact NMLS/DBR lookup when a legal name or identifier is within scope. |
| Accreditation/form-version implications |
Still unresolved |
P1 C041 |
Current approved accreditors, settlement-only treatment, and operative form authority. |
| Enactment/case-law completeness |
Still open beyond this version comparison |
P2 C005–C007 |
Companion enactment, legislative file, comprehensive case/docket/citator work. |
| Agreements, funds, bonds, remedies, sectors, local, tribal, secured debt, and full state coverage |
Expressly open |
— |
Dedicated later passes required. |
| Full Rhode Island/A066 acceptance |
Not performed |
— |
Requires completion and coordinator evaluation of every remaining state component. |
8. Researcher self-check
Freshly read for this correction
- Current Rhode Island §§19-14.8-2, 3, 4, 19, 20, 22, 23, 24, 26, 32, and 43.
- Current §19-14-4(a)(7).
- Rhode Island Public Laws 2006 chapter 243, including its enactment date, enacted fee wording, §43, and March 31, 2007 effective-date clause.
- The FTC-hosted 2008 national-model PDF cover and the selected definition, nexus, individual, refund-sequencing, fee-text, and fee-comment passages.
- The ULC archive entries distinguishing the 2005 approved text, January 2008 amendments, and final 2008 act.
Locator verification without broad substantive rerun
Current §§19-14.8-5, 6, 9, 10, 11, 13, 14, 17, 25, 27, and 28 were opened to verify full direct URLs, section identity, and applicable P1 pinpoints. Their wider PASS-01 analysis was not reopened.
Not read or not established
- A readable copy of the ULC 2005 Annual Meeting Approved Text/comments.
- A Rhode Island-hosted 2006 official-comment document or legislative attachment authenticating the exact comment edition.
- The complete companion P.L. 2006 chapter 291 text.
- A current adjusted-dollar rule, notice, order, or complete adjustment history.
- Current NMLS checklist/system charges.
- Any named provider’s registration status.
- DBR orders or controlling decisions resolving the no-plan fee pathway, mixed-plan methodology, or monthly-first credit order.
- Full agreements, funds, bonds, remedies, sector, local, tribal, secured-debt, or case-law coverage.
The coordinator-supplied fresh checks were used as scoped corroboration; the key correction sources were also opened directly in this session. No file artifact was created, and no whole-state or publication conclusion is expressed.
PASS-02 correction result: The emergency-waiver omission and the overbroad pre-agreement shorthand are corrected. The 2008 national comments are now properly version-qualified, the material plan/agreement divergence is preserved, the no-plan fee pathway remains held, Worked Example 7 is explicitly conditional, and every Rhode Island section previously abbreviated in S002 now has a complete literal URL and read-status label.
END S_RI PASS-02.