FIND THE EXPLANATION
Use the notice, agreement, and places connected to the debt to find the right court, regulator, or legal-help service.
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State: Virginia Component: consumer agreements, termination/cancellation, and client-money custody/control Baseline: October 22, 2026 Pacific Actual primary-source access: October 24, 2026 Pacific
This is a focused Virginia component only. It does not reopen PASS-01’s licensing/fee conclusions, does not treat PASS-02’s unresolved interpretations as settled, and does not establish authorization for SettleADebt.com or any named provider.
The central distinction for this pass is important:
For both chapters, the operative consumer concept is a Virginia-resident individual with personal, family, or household debt. The statutes reach covered providers even without a Virginia office, facility, agent, or physical presence. Banks, savings institutions, credit unions, and persons licensed to practice law in Virginia are excluded from these chapters. Chapter 20.1 also exempts a Chapter 20 licensee from a separate settlement license only where the settlement activity is solely in connection with DMPs. A Chapter 20.1 settlement license alone does not authorize creditor-payment transmission. S_VA-P3-C001–C004. Virginia Law+2
A nonprofit label is not itself an exemption from the current Chapter 20 agreement/custody duties. The present statute expressly requires the DMP applicant’s pre-contract disclosure form to state whether the applicant is for-profit or nonprofit, demonstrating that both can be regulated licensees. S_VA-P3-C005. Virginia Law
Every covered debt-settlement-services agreement must be evidenced by a written agreement. It may be kept as:
It must be signed by both the consumer and a person authorized by the licensee, and both signatures/date formalities must correspond to the day the consumer executes the agreement. Original or electronic signatures are expressly permitted. S_VA-P3-C006. Virginia Law
The agreement must contain, at minimum:
The statute additionally requires a duplicate original to be given to the consumer when both sides have fully executed the agreement. “Duplicate original” expressly includes, for an electronic transaction, an electronic version with electronic signatures. S_VA-P3-C008. Virginia Law+1
Before the agreement is executed, the provider must separately disclose in writing and retain a copy of:
Those disclosures are pre-execution conditions, not merely items that can be buried somewhere in the signed agreement after execution.
Chapter 20.1 expressly requires the cost explanation to be bold, but I did not find a Chapter 20.1 statutory minimum font point size or a general reading-grade/readability formula for the settlement agreement. The SCC’s operative Chapter 230 rule does not add one. S_VA-P3-C010. Virginia Law+1
The provider may not require:
Those are substantive contract limitations even if a drafted agreement purports to make either mandatory. S_VA-P3-C011. Virginia Law
The SCC regulation also makes the licensee responsible for ensuring that an agreement set up by another person complies with Chapter 20.1 and Chapter 230. Selling or assigning the agreement is restricted to a purchaser/assignee that is itself licensed or exempt from Chapter 20.1. S_VA-P3-C012. Virginia Law
I did not locate in Chapter 20.1 an analogue to Chapter 20’s express prohibition on contractual waivers of all statutory rights, out-of-state forum clauses, or confession-of-judgment authority. That absence should not be turned into a conclusion that any such term is valid under Virginia contract, VCPA, arbitration, forum-selection, or other law; those broader contract/case-law questions are expressly outside this pass. S_VA-P3-C013 — bounded hold.
Each DMP likewise must be evidenced by an agreement maintained in hard copy, faxed copy, or electronic form; signed by the consumer and an authorized licensee representative; and dated the same day the consumer executes it. Original and electronic signatures are authorized. S_VA-P3-C014. Virginia Law
The DMP agreement must include:
The licensee must give the consumer a duplicate original upon full execution. S_VA-P3-C016. Virginia Law
Chapter 20 has a second mandatory disclosure layer beyond the agreement itself.
Before execution, the provider must give the consumer the filed disclosure form stating:
The final SCC regulation makes that disclosure form unusually specific:
Separately, on or before entering the DMP, the licensee must give the consumer the Bureau complaint/contact notice in at least 10-point boldface type, either separately or inside the DMP agreement. S_VA-P3-C018. Virginia Law+1
These are current operative requirements adopted in the SCC’s 2015 final regulation, not merely proposal language. The Commission adopted that regulation effective December 1, 2015. Virginia Register
At execution, a DMP licensee must have a good-faith belief that the creditors listed in the DMP will participate. If a creditor later changes its acceptance of payments under the DMP, the provider must promptly advise the consumer. S_VA-P3-C019. Virginia Law
The provider may not structure the DMP so that, at completion, it knowingly results in negative amortization of the consumer’s creditor obligations. S_VA-P3-C020. Virginia Law
Chapter 20 also expressly forbids obtaining any consumer agreement that:
Those are not merely missing disclosure terms; they are prohibited agreement provisions. S_VA-P3-C021. Virginia Law
The debt-service statutes expressly allow electronic agreements/signatures, but Virginia’s Uniform Electronic Transactions Act still governs the conditions under which electronic transaction mechanics have legal effect.
Virginia UETA provides that:
Where law requires information to be provided, sent, or delivered in writing, electronic delivery can satisfy that requirement if the parties agreed to electronic transactions and the recipient can retain the record when received. If the sender’s system prevents printing or storage, the electronic record is not enforceable against the recipient. Formatting rules imposed by the underlying statute still have to be honored electronically. S_VA-P3-C023. Virginia Law+1
Thus, “we emailed a link” is not enough if the consumer never agreed to electronic transactions or the record cannot be retained.
The Chapter 20.1 agreement itself must tell the consumer that it can be terminated for any reason and that the consumer has no duty to continue unless satisfied. S_VA-P3-C024. Virginia Law
For an account requested in connection with settlement services, Virginia separately requires that the consumer be allowed to withdraw from the settlement services at any time without penalty and receive the money in the account except a fee lawfully earned by the settlement provider for completed services, subject to § 6.2-2041. S_VA-P3-C025. Virginia Law
Virginia Chapter 20.1 does not specify in those provisions:
Accordingly, this pass does not invent those requirements or import the federal TSR’s separate account-return timing. S_VA-P3-C026.
The unresolved PASS-02 questions concerning what amounts may qualify as a lawfully earned fee or a permissible independent administrator charge remain held and are not resolved here.
A DMP can be terminated for any reason by the consumer. The agreement must state that on termination the consumer is entitled to:
The undisbursed-creditor-money right is distinct from the fee refund. The statute does not condition return of undisbursed creditor funds on cancellation occurring within 30 days. S_VA-P3-C028. Virginia Law
After the specified early fee-refund window, the agreement still must permit termination, but § 6.2-2014(1) itself does not provide a blanket refund formula for previously earned fees after that period. S_VA-P3-C029. Virginia Law
PASS-02’s separate uncertainty over whether actually incurred § 6.2-2016 “reimbursements” are included within “all fees paid” remains expressly unresolved. This pass does not adopt either refund treatment.
Virginia’s general construction statute says that when an act must be performed within a prescribed period after an event, the day of the triggering event is not counted. S_VA-P3-C030. Virginia Law
That supplies an important counting rule for a DMP executed on Day 0: the execution date is excluded when counting a period measured after that event.
But § 6.2-2014 uses “days,” not “business days,” for its five-day and less-than-31-day fee-refund wording. I found no Chapter 20 regulation redefining those cancellation “days” as business days. S_VA-P3-C031. Virginia Law+1
Section 1-210’s weekend/holiday extension provisions are written for particular governmental or judicial acts and should not automatically be imported into a private consumer’s notice to a private DMP provider without an applicable factual/legal basis. Therefore I do not calculate an exact weekend/holiday endpoint here. S_VA-P3-C032 — held at endpoint level. Virginia Law
Also, § 6.2-2014 states what refund the consumer is entitled to, but the language reviewed does not specify a separate number of days in which the licensee must physically deliver that refund after termination. An exact state refund-delivery deadline therefore remains unestablished in this component. S_VA-P3-C033.
A Chapter 20.1 settlement licensee is expressly prohibited from receiving consumer money for transmission to creditors unless it is also licensed under Chapter 20. S_VA-P3-C034. Virginia Law
This sharply limits what a “settlement-only” money flow can look like.
If the settlement provider requests use of an account:
Those requirements establish consumer ownership and provider independence, not a provider trust account.
A model in which the settlement provider or its agent actually controls consumer funds for onward creditor distribution may instead satisfy Chapter 20’s “money or control of funds” DMP definition. The marketing label “dedicated account,” “escrow,” “settlement wallet,” or “noncustodial” is not dispositive. S_VA-P3-C036. Virginia Law+1
Chapter 20 requires an applicant/licensee to maintain a separate trust account with an FDIC-insured depository institution for customer funds. S_VA-P3-C037. Virginia Law
Section 6.2-2014 further requires:
The 2015 SCC final regulation then adds explicit ownership and commingling rules:
This is a stronger rule than merely keeping a separate bookkeeping ledger.
The final SCC regulation expressly states that the trust-account provisions apply whether consumer funds are handled:
A licensee may not allow a third party to perform debt-pooling/distribution services or obtain control over consumer creditor-payment money unless:
The licensee remains liable under Chapter 20 for the agent’s acts and omissions that would violate Chapter 20 or Chapter 110 if committed directly by the licensee. S_VA-P3-C041. Virginia Register
Thus, outsourcing payment processing is not a custody escape hatch.
No alternative Virginia rule was located in this pass authorizing a third-party-controlled DMP trust structure that disregards the statutory requirement that consumer funds be held in a trust account in the licensee’s name.
A DMP licensee must maintain an established practice of sending consumer funds to creditors within eight business days of receipt and must give consumers its disbursement practices in writing, including any circumstances that create an exception to that eight-day practice. S_VA-P3-C042. Virginia Law
The SCC defines “business day,” for Chapter 20, as a day on which the licensee’s office is open for business. S_VA-P3-C043. Virginia Law+1
The wording is not an unconditional command that every dollar invariably leave by the eighth day: the statute calls for an “established practice” and expressly contemplates disclosed exceptions. A provider therefore cannot represent the rule accurately simply as “Virginia gives us eight days to hold the money.” S_VA-P3-C044.
A DMP consumer must receive a periodic statement at least quarterly accounting for:
Upon request, the licensee must either:
The bond statute separately conditions the DMP licensee’s bond on, among other things, correctly and accurately accounting for all funds received in the licensed business. That provision supports the statutory accounting obligation but is not itself a specified bank-reconciliation schedule. S_VA-P3-C047. Virginia Law
I found no express Chapter 20/10VAC5-110 clause saying “perform a trust-bank reconciliation every X days/months.” Therefore a specific reconciliation cadence should not be invented from the quarterly consumer-statement rule. Accounting and examination obligations remain broader, but a particular reconciliation interval is unresolved on the primary material read here. S_VA-P3-C048.
For DMPs, books/accounts/records required for regulatory compliance must be kept separate from records of other businesses, and DMP records must be retained for at least three years after the DMP is terminated. Personal financial records must later be securely destroyed. S_VA-P3-C049. Virginia Law
Settlement providers have the parallel record rule: debt-settlement-agreement records must be kept for at least three years after the agreement terminates, separate from other-business records, with secure disposal of personal financial information. The provider also has an express duty under § 2040(4) to retain its copy of the mandatory pre-contract disclosures. S_VA-P3-C050. Virginia Law+1
These are demonstrations of verified clauses, not findings that any provider is licensed or that an unresolved fee is lawful.
Facts
Classification operator
Chapter 20.1 § 2027(D): settlement licensee may not receive money for transmission to creditors unless also licensed under Chapter 20.
Result
$700 received for creditor transmission → Chapter 20 authority dependency
The amount is irrelevant: $1 or $700 produces the same legal classification issue. No settlement contract term can expand the Chapter 20.1 license into creditor-payment custody. C034, C036. Virginia Law
Assumptions
Arithmetic
Account funds: 1,200.00 Less proven earned provider fee: 250.00 Consumer return: 950.00
Result
$1,200.00 − $250.00 = $950.00
Units: dollars/cents. Rounding: none.
If the $250 had already been removed from the account, it cannot be deducted again. If the provider cannot establish that the fee was earned for completed services, this example becomes a hold, not a $250 deduction.
Virginia’s statute establishes the withdrawal/right-to-funds rule but this pass does not establish a separate Virginia deadline measured in days for completing the account return. C025, C035. Virginia Law
Facts
Licensee receives:
Required classification
Consumer creditor-payment funds:
$400 + $600 = $1,000 trust money
Provider operating funds:
$5,000 operating money
Result
The $1,000 cannot be commingled with the $5,000 operating balance or with funds belonging to other persons. It must be held in the qualifying separate trust structure for consumers.
The fact that multiple consumers use a trust-account system does not erase the regulatory prohibition on commingling with “funds of any other persons”; the exact permissible banking/account architecture for pooled subledger arrangements beyond the operative language would require institution-specific analysis and is not invented here. C038–C040. Virginia Law
Assumptions
Money-flow calculation
Undisbursed creditor money:
$700.00 − $450.00 = $250.00
Fee refund:
$60.00
Total provider-to-consumer return in this bounded example:
$250.00 + $60.00 = $310.00
The $450.00 already delivered to creditors is not part of the provider-held fund return.
Units: dollars/cents. Rounding: none.
No refund-delivery deadline in days is supplied because the statute reviewed establishes entitlement but does not state a separate delivery period. C027–C033. Virginia Law
Facts
A DMP is executed on an unspecified “Day 0.”
Virginia § 1-210(A) says the triggering event day is excluded when a statutory period runs after that event.
Therefore:
That is the verified counting operator.
What cannot be stated without further facts:
Those endpoints remain held rather than being guessed. C030–C032. Virginia Law
Assumptions
Consumer creditor-payment funds are received on a Monday.
The provider’s office is open Monday through Friday and closed Saturdays/Sundays. No holidays or disclosed exceptional circumstances occur.
The regulation defines business day as a day the licensee’s office is open. The statute requires an established practice of disbursing within eight such business days.
I do not assign an exact calendar date because receipt-time conventions, whether the receipt day counts, and any provider-specific office closure facts were not established by the retrieved text. The legally safe output is:
8 business days = 8 days on which this licensee’s office is actually open
not “8 calendar days” and not necessarily “8 Monday-through-Friday days” for every licensee. C042–C044. Virginia Register+1
Chapter 20.1 was enacted through 2020 Acts, Chapter 785, approved April 7, 2020. The enactment expressly provided that its substantive first enactment would become effective July 1, 2021. The agreement, account, and termination provisions read in current Code are traceable to that enacted text. S_VA-P3-C051. Legislative Information System+1
The operative debt-settlement regulation, 10VAC5-230, was adopted by SCC final order and is shown in the current Administrative Code with an effective date of December 15, 2021. The current regulation requires agreements created by outsiders to comply with Chapter 20.1, limits assignment, and continues prior-agreement duties after license surrender/cessation. S_VA-P3-C052. Virginia Law+1
The modern predecessor structure was enacted in 2004 Acts, Chapter 790, approved April 14, 2004. That enactment already included DMP concepts involving money/control, duplicate originals/electronic signatures, written agreements, fund accounting, and consumer-funds protection. The current Code sections are current codification, with subsequent amendments and the 2010 Title 6.2 recodification reflected in their histories. S_VA-P3-C053. Legislative Information System+1
The consequential current DMP regulatory custody and disclosure provisions in 10VAC5-110-40 were added/adopted in the SCC’s final Case BFI-2015-00039 order. The Commission adopted the modified regulation effective December 1, 2015. The final order’s own summary specifically identifies:
This is final regulatory history, not proposed text. S_VA-P3-C054. Virginia Register
The Administrative Code page accessed October 24, 2026 continues to show those operative provisions and the December 1, 2015 amendment history. S_VA-P3-C055. Virginia Law
Targeted ordinary public searches for Virginia appellate decisions or SCC adjudicatory decisions specifically construing the agreement/custody clauses above did not surface a controlling merits decision during this pass.
That is a research-result limitation, not a statement that no such decision exists.
The 2015 SCC final adoption order is strong primary administrative authority for what the Commission adopted and why, but it is not a judicial holding construing every fact pattern under the rules.
No prior PASS-02 interpretive hold is treated as resolved by this PASS-03 work.
Because the interface requires source links to be rendered through its citation/link mechanism, the “Direct source” column links to the literal destination rather than printing bare URLs.
| Source ID | Issuer / title | Direct source | Exact material actually read | Status / access date / limitations |
|---|---|---|---|---|
| S_VA-P3-S001 | Virginia General Assembly — Code Title 6.2, Ch. 20.1 | Chapter 20.1 — Debt Settlement Services Providers | §§ 2026–2028, 2034, 2039–2041; especially § 2040(1)–(7). | Current codified law displayed 10/24/2026; read 10/24/2026. |
| S_VA-P3-S002 | Virginia General Assembly — Code Title 6.2, Ch. 20 | Chapter 20 — Agencies Providing Debt Management Plans | §§ 2000–2005, 2008, 2013–2016; especially § 2014(1)–(16). | Current codified law displayed 10/24/2026 in current retrieval. |
| S_VA-P3-S003 | Virginia General Assembly — § 6.2-2027 | Settlement license requirement and exceptions | A–D, particularly remote nexus, exclusions and prohibition on receiving creditor-transmission money without Ch. 20 license. | Current codified law; read 10/24/2026. |
| S_VA-P3-S004 | Virginia General Assembly — § 6.2-2001 | DMP license requirement and exceptions | A–C; consumer-funds/control protective purpose. | Current codified law; page displayed 10/23/2026; read 10/24/2026. |
| S_VA-P3-S005 | Virginia General Assembly — § 6.2-2005 | DMP qualifications | A(3), A(9), C: trust account and mandatory pre-contract disclosure form. | Current codified law; read 10/24/2026. |
| S_VA-P3-S006 | Virginia Administrative Code / SCC — 10VAC5-230 | Chapter 230 — Debt Settlement Services Providers | -50(B)–(I), -60; agreement responsibility, assignment, anti-evasion, continuing obligations. | Current regulation; origin effective 12/15/2021. Read 10/24/2026. |
| S_VA-P3-S007 | Virginia Administrative Code / SCC — 10VAC5-110 | Chapter 110 — Credit Counseling | -10 business-day definition; -40(B)–(M); -50 record item. | Current regulation; consequential -40 provisions effective 12/1/2015. Read 10/24/2026. |
| S_VA-P3-S008 | SCC / Virginia Register — Case BFI-2015-00039 | Final Regulation 10VAC5-110, Nov. 2, 2015 publication | Final order lines 45–82; adopted -40 provisions lines 163–199. | Final order, not proposal. Adopted effective 12/1/2015. Read 10/24/2026. |
| S_VA-P3-S009 | Virginia General Assembly — UETA Ch. 42.1 | Uniform Electronic Transactions Act | §§ 59.1-483, -485, -486: agreement to e-transact, separate consent, retention capability, formatting/method preservation. | Current law; read 10/24/2026. |
| S_VA-P3-S010 | Virginia General Assembly — § 1-210 | Computation of time | A–F, especially A and limits of B/C/E. | Current law displayed 10/24/2026; read 10/24/2026. |
| S_VA-P3-S011 | Virginia General Assembly — 2020 Acts Ch. 785 | 2020 Chapter 785 enacted debt-settlement law | Original §§ 2026–2050; enactment clause 2 establishing 7/1/2021 effective date. | Enacted historical primary source; current law checked separately. Read 10/24/2026. |
| S_VA-P3-S012 | Virginia General Assembly — 2004 Acts Ch. 790 | 2004 Chapter 790 enacted credit-counseling law | Original definitions, remote coverage, DMP agreement/funds architecture, bond/accounting. | Historical enacted primary source, approved 4/14/2004; not substituted for current codification. Read 10/24/2026. |
| S_VA-P3-S013 | Virginia General Assembly — § 6.2-2008 | DMP retention of books, accounts and records | A–B, especially three years after DMP termination and separate records. | Current law; read 10/24/2026. |
| S_VA-P3-S014 | Virginia General Assembly — § 6.2-2014 | DMP required and prohibited business methods | Full subdivisions 1–16. | Current law; independently surfaced again in targeted search 10/24/2026. |
| S_VA-P3-S015 | Virginia General Assembly — § 6.2-2040 | Settlement required and prohibited business methods | Full subdivisions 1–7. | Current law; read 10/24/2026. |
| Route / issue | Actual result | Consequence |
|---|---|---|
| Virginia appellate searches for direct construction of §§ 6.2-2014 / 6.2-2040 agreement or trust provisions | No responsive controlling merits passage surfaced | No judicial gloss asserted. |
| SCC public searches for adjudicatory orders construing trust/cancellation language in a disputed consumer case | No responsive merits order surfaced | Final regulatory adoption order used only for adoption/history and its stated rationale. |
| Specific trust-account bank-reconciliation cadence | No express cadence located in current Ch. 20 or 10VAC5-110 text | Cadence remains unresolved; quarterly consumer statements are not silently converted into monthly reconciliation law. |
| State-law deadline for physically delivering settlement-account or DMP cancellation refunds | No express number of days located in assigned provisions | No deadline invented; federal timing not substituted. |
| Claim ID | Consequential assertion | Primary source/pinpoint | Conditions / exceptions / currentness / confidence |
|---|---|---|---|
| S_VA-P3-C001 | Both regimes are keyed to Virginia-resident consumer debt and reach remote providers. | S001 §2026–27; S002 §§2000–01 | High. Business-purpose/nonresident scenarios need separate analysis. |
| C002 | Banks, savings institutions, credit unions, and Virginia-licensed lawyers are outside these chapters. | S003(A); S004(A) | High statutory text. Entity qualification is factual; attorney affiliation is not presumed enough. |
| C003 | Ch. 20 licensee need not hold Ch. 20.1 license for settlement solely connected to DMPs. | S003(C) | High. Limited exception. |
| C004 | Ch. 20.1 settlement license alone does not authorize receipt of creditor-transmission money. | S003(D) | High. |
| C005 | Nonprofit status itself does not remove current DMP agreement duties. | S005(A)(9); S008 -40(K) | High. |
| C006 | Settlement agreement must be written, same-day dated and signed by consumer and authorized licensee person; hard/fax/electronic forms allowed. | S001 §2040(1) | High. |
| C007 | Settlement agreement has seven minimum content categories including bold costs, at-will termination, dispute method and privacy. | S001 §2040(1) | High. |
| C008 | Consumer must receive duplicate original on full execution; electronic duplicate original is recognized. | S001 §§2026, 2040(2) | High. UETA consent still applies. |
| C009 | Settlement timing, accumulation and adverse missed-payment consequences must be disclosed in writing before execution and copy retained. | S001 §2040(4) | High. |
| C010 | Settlement chapter specifies bold costs but no additional minimum point-size/readability formula located. | S001 §2040; S006 | High as retrieved-law result, not proof no other generally applicable law exists. |
| C011 | Settlement provider cannot condition service on POA or opening an account. | S001 §2040(5)–(6) | High. |
| C012 | Agreements established by others remain licensee’s compliance responsibility; assignment limited to licensed/exempt transferee. | S006 -50(B)–(C) | High. |
| C013 | No Ch.20.1 analogue to Ch.20’s explicit statutory-right waiver/out-of-state-suit prohibition was located. | S001 full chapter; compare S002 §2014(16) | Bounded absence finding. Broader contract enforceability open. |
| C014 | DMP agreement has same basic written/electronic, signature and same-day execution formalities. | S002 §2014(1) | High. |
| C015 | DMP agreement must include statutory termination/refund and credit-report warning in addition to core terms. | S002 §2014(1)(i)–(ix) | High. |
| C016 | DMP consumer receives duplicate original on full execution. | S002 §2014(2) | High. |
| C017 | DMP fee/status/creditor-support disclosure must be separate 12-point form with signed/date acknowledgment in 14-point bold. | S005(A)(9); S007 -40(K); S008 | High. Final rule effective 12/1/2015. |
| C018 | Bureau complaint notice must be supplied no later than DMP entry, in at least 10-point bold, separately or in agreement. | S007 -40(F); S008 | High. |
| C019 | DMP provider must believe listed creditors will participate and promptly advise consumer of creditor acceptance changes. | S002 §2014(3) | High. |
| C020 | Provider may not knowingly structure DMP to end in negative amortization. | S002 §2014(9) | High. |
| C021 | DMP cannot contain POA/confession, out-of-state suit authority, or statutory-right waiver. | S002 §2014(16) | High. |
| C022 | Virginia electronic transaction requires agreement by both parties; standard-form consent must be conspicuous and separately consented. | S009 §59.1-483 | High. |
| C023 | Required written electronic disclosures must be retainable; underlying formatting/method requirements survive electronic delivery. | S009 §§59.1-485–486 | High. |
| C024 | Settlement contract must permit termination for any reason. | S001 §2040(1)(iv) | High. |
| C025 | Consumer using qualifying settlement account may withdraw at any time without penalty and receive balance less lawfully earned completed-service fee. | S001 §2040(6)(e) | High text; fee characterization remains dependent on unresolved prior-pass issues. |
| C026 | No Chapter 20.1 state cooling-off period, cancellation method, or numeric refund-delivery deadline was located in assigned provisions. | S001 §2040 | High retrieved-law result; broader law open. |
| C027 | DMP termination always entails return of undisbursed creditor funds, with early fee-refund rules at <5 and >5/<31 day windows. | S002 §2014(1)(v) | High text. PASS-02 reimbursement classification remains held. |
| C028 | Undisbursed-money return is distinct from early fee refund and not textually limited to first 30 days. | S002 §2014(1)(v) | High grammatical/textual reading. |
| C029 | After early refund windows, Chapter 20 still permits termination but §2014(1) provides no general later fee-refund formula. | S002 §2014(1) | High as to this subsection. Other claims/remedies open. |
| C030 | Virginia general time rule excludes triggering-event day for a period running after an event. | S010(A) | High. |
| C031 | DMP cancellation provision says “days,” not “business days”; Chapter 110’s business-day definition specifically applies where “business day” is used. | S002 §2014(1)(v); S007 -10 | High. |
| C032 | Weekend/holiday endpoint for a private cancellation cannot be safely extended using §1-210 without applicable facts/legal basis. | S010(B)–(E) | Held at precise endpoint. |
| C033 | Assigned DMP provision does not state an independent numeric refund-delivery deadline after termination. | S002 §2014 | High retrieved-text result. |
| C034 | Settlement-only licensee cannot receive creditor-transmission money unless also Ch.20 licensed. | S003(D) | High. |
| C035 | Voluntary settlement account must be FDIC-insured, consumer-owned, interest credited to consumer, independently administered, referral-compensation free. | S001 §2040(6)(a)–(e) | High. Independent administrator fee treatment remains PASS-02 hold. |
| C036 | Actual control of money for creditor distribution can trigger DMP classification even if provider lacks physical possession. | S002 §2000; S004(B) | High definition-level conclusion. |
| C037 | DMP qualification requires separate FDIC-insured trust account. | S005(A)(3) | High. |
| C038 | Consumer creditor-payment funds must be separate from operating funds and held in trust in licensee name at insured institution. | S002 §2014(14) | High. |
| C039 | SCC rule declares DMP trust money consumer-benefit property, not licensee property; bars commingling with operating or other-person funds. | S007 -40(C); S008 | High. |
| C040 | Trust duties apply when third party handles funds for licensee. | S007 -40(C)(3) | High. |
| C041 | Third-party control requires agency agreement plus Bureau notice/conditions; licensee remains liable for agent violations. | S007 -40(L); S008 | High. |
| C042 | DMP must maintain practice of creditor disbursement within eight business days and disclose practices/exceptions in writing. | S002 §2014(11) | High. |
| C043 | “Business day” means day the licensee’s office is open. | S007 -10 | High. |
| C044 | Eight-day language is an established-practice standard with disclosed exceptions, not simple authority to warehouse funds for eight days. | S002 §2014(11) | High textual reading. |
| C045 | DMP statements must be at least quarterly and account for receipts and creditor-specific disbursements since prior statement. | S002 §2014(4) | High. |
| C046 | On request consumer gets signed/date receipt or electronic account-status access. | S002 §2014(15) | High. |
| C047 | DMP bond obligation includes correctly/accurately accounting for all licensed-business funds. | S002 §2003 | High. Bond remedies beyond this point excluded. |
| C048 | No express trust-bank reconciliation cadence was located in Chapter 20 / Chapter 110. | S002; S007 | Held as absence finding. |
| C049 | DMP records retained minimum three years after termination, separate from other-business records, with secure disposal of financial information. | S002 §2008 | High. |
| C050 | Settlement-agreement records likewise retained three years after termination; precontract disclosures copied and retained. | S001 §§2034, 2040(4) | High. |
| C051 | Ch.20.1 substantive settlement act became effective 7/1/2021. | S011 enactment 2 | High. |
| C052 | Current Ch.230 settlement rules derive from final SCC rule effective 12/15/2021. | S006 history / prior final order | High. |
| C053 | Modern DMP architecture traces to 2004 Ch.790 but current Code controls. | S012; S002 | High historical/current distinction. |
| C054 | Consequential trust/delegation/disclosure provisions were adopted in final SCC order effective 12/1/2015. | S008 | High. |
| C055 | Current Administrative Code still carries those operative provisions as of access. | S007 | High as of 10/24/2026 access. |
| Example | Result | Claims |
|---|---|---|
| Settlement-only provider collects consumer money to transmit to creditors | Classification hold / additional Chapter 20 authorization dependency, regardless of amount | C034, C036 |
| Settlement account $1,200 balance, independently proven $250 earned fee not previously deducted | $1,200 − $250 = $950 consumer return; no administrator fee assumed | C025, C035 |
| DMP receives $400 + $600 creditor money plus provider has $5,000 operating cash | $1,000 trust money must remain legally distinct from $5,000 operating money | C037–C040 |
| DMP cancellation: $700 creditor funds received, $450 already sent, $60 indisputably refundable fee | Undisbursed = $250; total return in stated early-window assumptions = $250 + $60 = $310 | C027–C029 |
| DMP cancellation period | Execution date excluded under §1-210(A); exact weekend/holiday endpoint held | C030–C032 |
| Eight-business-day DMP practice | Count days provider office is open; exact calendar endpoint requires receipt and office facts | C042–C044 |
| PASS-03 issue | Status | Claims | Exact missing authority / next action |
|---|---|---|---|
| Settlement written agreement form | Answered | C006–C013 | Broader arbitration/forum/unconscionability law remains later contract/case-law pass. |
| DMP written agreement form | Answered | C014–C021 | No remaining core statutory form question identified. |
| Electronic agreement/signature mechanics | Answered for Virginia UETA | C022–C023 | Federal E-SIGN interaction not needed to establish the state-law duties here and remains outside this state-focused analysis unless later required. |
| Settlement pre-execution disclosures | Answered | C009 | Actual provider document would need clause-level compliance review. |
| DMP pre-execution disclosures and formatting | Answered | C017–C018 | Actual form still requires factual inspection. |
| Creditor participation expectations | Answered | C019–C020 | Case-specific creditor representations remain factual. |
| Settlement prohibited agreement conditions | Answered in Chapter 20.1 scope | C011–C013 | Broader void/unenforceable clauses require separate Virginia contract and VCPA research. |
| DMP prohibited agreement clauses | Answered | C021 | General contract doctrines remain later pass. |
| Settlement termination | Answered in core | C024–C026 | Exact fund-return deadline and PASS-02 fee/account-charge questions remain open. |
| DMP termination and fee refund windows | Answered textually | C027–C033 | §2016 reimbursement treatment remains PASS-02 unresolved; exact private cancellation endpoint may depend on facts and authority not established here. |
| Legal day-count starting rule | Answered | C030 | Private weekend/holiday extension not established. |
| Settlement voluntary account ownership/control | Answered | C034–C036 | Independent account-administrator charge treatment remains PASS-02 hold. |
| DMP trust-account structure | Answered | C037–C040 | Institution-specific deposit mechanics and any additional banking rules remain open. |
| DMP third-party handler | Answered | C040–C041 | Actual Bureau conditions for a particular appointed agent would require provider-specific evidence. |
| DMP creditor disbursement practice | Answered | C042–C044 | Exact timestamp counting for a particular receipt would require provider facts and any applicable interpretation. |
| Consumer statements / receipts / access | Answered | C045–C046 | No separate settlement quarterly statement requirement established. |
| Trust/account reconciliation cadence | Unresolved | C047–C048 | Search SCC examination manuals, formal guidance, and controlling adjudications for any specific reconciliation cycle before asserting one. |
| DMP record retention | Answered | C049 | Other records may have separate retention rules outside this chapter. |
| Settlement record retention | Answered | C050 | Same limitation. |
| Settlement enactment/currentness | Answered for consequential duties | C051–C052 | Future amendments must be rechecked at future publication date. |
| DMP regulatory adoption/currentness | Answered for consequential duties | C053–C055 | No claim that all historical amendments in unrelated subsections were reviewed. |
| Controlling appellate construction of these clauses | Not located | — | Expand later case-law pass using Virginia appellate/SCC case dockets and subsequent-history checks. |
| PASS-02 later-debt timing interpretation | Excluded / remains held | — | PASS-02 coordinator review and/or later targeted authority required. |
| PASS-02 independent account-charge interpretation | Excluded / remains held | — | No affirmative permission inferred here. |
| PASS-02 §2016 reimbursement-refund construction | Excluded / remains held | — | No refund classification adopted here. |
| Licensing/fee reassessment | Excluded | — | PASS-01/PASS-02 remain separate. |
| Bonds/insurance/remedies architecture | Excluded except accounting clause needed here | C047 | Dedicated later pass required. |
| Full collection/litigation/limitations/debtor exemptions/secured/sector/local/tribal/general contract/case-law | Open | — | Required parent-state work remains. |
| Full Virginia dossier / state acceptance / A066 | Open | — | No acceptance or publication-readiness implication. |
I freshly read the current Chapter 20 and Chapter 20.1 operative provisions governing agreements, disclosures, money/control, trust accounts, creditor-payment practices, termination, records and applicable exemptions. I also read the current Chapter 110 and Chapter 230 operative regulations needed for third-party delegation, consumer notices, trust status, formatting and agreement responsibility. Virginia Law+3
I read the SCC’s final 2015 adoption order for the DMP regulatory amendments and distinguished it from proposed text. That final order expressly states the December 1, 2015 effective date and identifies trust-account, consumer-notice and third-party-agent changes. Virginia Register
I read Virginia UETA’s electronic-consent, enforceability and retainability rules rather than assuming that statutory permission for an e-signature automatically authorizes every electronic delivery process. Virginia Law
I read Virginia’s general computation-of-time statute before addressing the DMP five-/31-day language. I did not manufacture a weekend extension or exact calendar deadline not established by the facts and applicable provision. Virginia Law
I read the 2020 enacted settlement chapter and its actual July 1, 2021 effective clause, and the 2004 DMP enactment as historical primary material while treating the current codified statutes as controlling current text. Legislative Information System+1
Targeted searches did not surface a controlling Virginia appellate holding or SCC merits order interpreting the exact contract/trust-account edge questions discussed above. I therefore did not fabricate a judicial construction or characterize an enforcement allegation as a final holding.
I did not rerun PASS-01’s fee overview, did not declare PASS-02’s interpretation holds resolved, did not verify any provider’s authorization, and did not use a federal TSR rule as a substitute for Virginia contract/custody law.
No Deep Research, Work, Codex, API, additional chat, Chrome permission, account change, contact, purchase, private borrower data, filing, website change, publication, or local-save claim was used. This self-check is not independent review.
All other Virginia parent-dossier categories and A066 requirements remain open.
END S_VA PASS-03.
Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
Source ID · Issuer / title · Direct source · 15 data rows
| Source ID | Issuer / title | Direct source | Exact material actually read | Status / access date / limitations |
|---|---|---|---|---|
| S_VA-P3-S001 | Virginia General Assembly — Code Title 6.2, Ch. 20.1 | Chapter 20.1 — Debt Settlement Services Providers | §§ 2026–2028, 2034, 2039–2041; especially § 2040(1)–(7). | Current codified law displayed 10/24/2026; read 10/24/2026. |
| S_VA-P3-S002 | Virginia General Assembly — Code Title 6.2, Ch. 20 | Chapter 20 — Agencies Providing Debt Management Plans | §§ 2000–2005, 2008, 2013–2016; especially § 2014(1)–(16). | Current codified law displayed 10/24/2026 in current retrieval. |
| S_VA-P3-S003 | Virginia General Assembly — § 6.2-2027 | Settlement license requirement and exceptions | A–D, particularly remote nexus, exclusions and prohibition on receiving creditor-transmission money without Ch. 20 license. | Current codified law; read 10/24/2026. |
| S_VA-P3-S004 | Virginia General Assembly — § 6.2-2001 | DMP license requirement and exceptions | A–C; consumer-funds/control protective purpose. | Current codified law; page displayed 10/23/2026; read 10/24/2026. |
| S_VA-P3-S005 | Virginia General Assembly — § 6.2-2005 | DMP qualifications | A(3), A(9), C: trust account and mandatory pre-contract disclosure form. | Current codified law; read 10/24/2026. |
| S_VA-P3-S006 | Virginia Administrative Code / SCC — 10VAC5-230 | Chapter 230 — Debt Settlement Services Providers | -50(B)–(I), -60; agreement responsibility, assignment, anti-evasion, continuing obligations. | Current regulation; origin effective 12/15/2021. Read 10/24/2026. |
| S_VA-P3-S007 | Virginia Administrative Code / SCC — 10VAC5-110 | Chapter 110 — Credit Counseling | -10 business-day definition; -40(B)–(M); -50 record item. | Current regulation; consequential -40 provisions effective 12/1/2015. Read 10/24/2026. |
| S_VA-P3-S008 | SCC / Virginia Register — Case BFI-2015-00039 | Final Regulation 10VAC5-110, Nov. 2, 2015 publication | Final order lines 45–82; adopted -40 provisions lines 163–199. | Final order, not proposal. Adopted effective 12/1/2015. Read 10/24/2026. |
| S_VA-P3-S009 | Virginia General Assembly — UETA Ch. 42.1 | Uniform Electronic Transactions Act | §§ 59.1-483, -485, -486: agreement to e-transact, separate consent, retention capability, formatting/method preservation. | Current law; read 10/24/2026. |
| S_VA-P3-S010 | Virginia General Assembly — § 1-210 | Computation of time | A–F, especially A and limits of B/C/E. | Current law displayed 10/24/2026; read 10/24/2026. |
| S_VA-P3-S011 | Virginia General Assembly — 2020 Acts Ch. 785 | 2020 Chapter 785 enacted debt-settlement law | Original §§ 2026–2050; enactment clause 2 establishing 7/1/2021 effective date. | Enacted historical primary source; current law checked separately. Read 10/24/2026. |
| S_VA-P3-S012 | Virginia General Assembly — 2004 Acts Ch. 790 | 2004 Chapter 790 enacted credit-counseling law | Original definitions, remote coverage, DMP agreement/funds architecture, bond/accounting. | Historical enacted primary source, approved 4/14/2004; not substituted for current codification. Read 10/24/2026. |
| S_VA-P3-S013 | Virginia General Assembly — § 6.2-2008 | DMP retention of books, accounts and records | A–B, especially three years after DMP termination and separate records. | Current law; read 10/24/2026. |
| S_VA-P3-S014 | Virginia General Assembly — § 6.2-2014 | DMP required and prohibited business methods | Full subdivisions 1–16. | Current law; independently surfaced again in targeted search 10/24/2026. |
| S_VA-P3-S015 | Virginia General Assembly — § 6.2-2040 | Settlement required and prohibited business methods | Full subdivisions 1–7. | Current law; read 10/24/2026. |
Route / issue · Actual result · Consequence · 4 data rows
| Route / issue | Actual result | Consequence |
|---|---|---|
| Virginia appellate searches for direct construction of §§ 6.2-2014 / 6.2-2040 agreement or trust provisions | No responsive controlling merits passage surfaced | No judicial gloss asserted. |
| SCC public searches for adjudicatory orders construing trust/cancellation language in a disputed consumer case | No responsive merits order surfaced | Final regulatory adoption order used only for adoption/history and its stated rationale. |
| Specific trust-account bank-reconciliation cadence | No express cadence located in current Ch. 20 or 10VAC5-110 text | Cadence remains unresolved; quarterly consumer statements are not silently converted into monthly reconciliation law. |
| State-law deadline for physically delivering settlement-account or DMP cancellation refunds | No express number of days located in assigned provisions | No deadline invented; federal timing not substituted. |
Claim ID · Consequential assertion · Primary source/pinpoint · 55 data rows
| Claim ID | Consequential assertion | Primary source/pinpoint | Conditions / exceptions / currentness / confidence |
|---|---|---|---|
| S_VA-P3-C001 | Both regimes are keyed to Virginia-resident consumer debt and reach remote providers. | S001 §2026–27; S002 §§2000–01 | High. Business-purpose/nonresident scenarios need separate analysis. |
| C002 | Banks, savings institutions, credit unions, and Virginia-licensed lawyers are outside these chapters. | S003(A); S004(A) | High statutory text. Entity qualification is factual; attorney affiliation is not presumed enough. |
| C003 | Ch. 20 licensee need not hold Ch. 20.1 license for settlement solely connected to DMPs. | S003(C) | High. Limited exception. |
| C004 | Ch. 20.1 settlement license alone does not authorize receipt of creditor-transmission money. | S003(D) | High. |
| C005 | Nonprofit status itself does not remove current DMP agreement duties. | S005(A)(9); S008 -40(K) | High. |
| C006 | Settlement agreement must be written, same-day dated and signed by consumer and authorized licensee person; hard/fax/electronic forms allowed. | S001 §2040(1) | High. |
| C007 | Settlement agreement has seven minimum content categories including bold costs, at-will termination, dispute method and privacy. | S001 §2040(1) | High. |
| C008 | Consumer must receive duplicate original on full execution; electronic duplicate original is recognized. | S001 §§2026, 2040(2) | High. UETA consent still applies. |
| C009 | Settlement timing, accumulation and adverse missed-payment consequences must be disclosed in writing before execution and copy retained. | S001 §2040(4) | High. |
| C010 | Settlement chapter specifies bold costs but no additional minimum point-size/readability formula located. | S001 §2040; S006 | High as retrieved-law result, not proof no other generally applicable law exists. |
| C011 | Settlement provider cannot condition service on POA or opening an account. | S001 §2040(5)–(6) | High. |
| C012 | Agreements established by others remain licensee’s compliance responsibility; assignment limited to licensed/exempt transferee. | S006 -50(B)–(C) | High. |
| C013 | No Ch.20.1 analogue to Ch.20’s explicit statutory-right waiver/out-of-state-suit prohibition was located. | S001 full chapter; compare S002 §2014(16) | Bounded absence finding. Broader contract enforceability open. |
| C014 | DMP agreement has same basic written/electronic, signature and same-day execution formalities. | S002 §2014(1) | High. |
| C015 | DMP agreement must include statutory termination/refund and credit-report warning in addition to core terms. | S002 §2014(1)(i)–(ix) | High. |
| C016 | DMP consumer receives duplicate original on full execution. | S002 §2014(2) | High. |
| C017 | DMP fee/status/creditor-support disclosure must be separate 12-point form with signed/date acknowledgment in 14-point bold. | S005(A)(9); S007 -40(K); S008 | High. Final rule effective 12/1/2015. |
| C018 | Bureau complaint notice must be supplied no later than DMP entry, in at least 10-point bold, separately or in agreement. | S007 -40(F); S008 | High. |
| C019 | DMP provider must believe listed creditors will participate and promptly advise consumer of creditor acceptance changes. | S002 §2014(3) | High. |
| C020 | Provider may not knowingly structure DMP to end in negative amortization. | S002 §2014(9) | High. |
| C021 | DMP cannot contain POA/confession, out-of-state suit authority, or statutory-right waiver. | S002 §2014(16) | High. |
| C022 | Virginia electronic transaction requires agreement by both parties; standard-form consent must be conspicuous and separately consented. | S009 §59.1-483 | High. |
| C023 | Required written electronic disclosures must be retainable; underlying formatting/method requirements survive electronic delivery. | S009 §§59.1-485–486 | High. |
| C024 | Settlement contract must permit termination for any reason. | S001 §2040(1)(iv) | High. |
| C025 | Consumer using qualifying settlement account may withdraw at any time without penalty and receive balance less lawfully earned completed-service fee. | S001 §2040(6)(e) | High text; fee characterization remains dependent on unresolved prior-pass issues. |
| C026 | No Chapter 20.1 state cooling-off period, cancellation method, or numeric refund-delivery deadline was located in assigned provisions. | S001 §2040 | High retrieved-law result; broader law open. |
| C027 | DMP termination always entails return of undisbursed creditor funds, with early fee-refund rules at <5 and >5/<31 day windows. | S002 §2014(1)(v) | High text. PASS-02 reimbursement classification remains held. |
| C028 | Undisbursed-money return is distinct from early fee refund and not textually limited to first 30 days. | S002 §2014(1)(v) | High grammatical/textual reading. |
| C029 | After early refund windows, Chapter 20 still permits termination but §2014(1) provides no general later fee-refund formula. | S002 §2014(1) | High as to this subsection. Other claims/remedies open. |
| C030 | Virginia general time rule excludes triggering-event day for a period running after an event. | S010(A) | High. |
| C031 | DMP cancellation provision says “days,” not “business days”; Chapter 110’s business-day definition specifically applies where “business day” is used. | S002 §2014(1)(v); S007 -10 | High. |
| C032 | Weekend/holiday endpoint for a private cancellation cannot be safely extended using §1-210 without applicable facts/legal basis. | S010(B)–(E) | Held at precise endpoint. |
| C033 | Assigned DMP provision does not state an independent numeric refund-delivery deadline after termination. | S002 §2014 | High retrieved-text result. |
| C034 | Settlement-only licensee cannot receive creditor-transmission money unless also Ch.20 licensed. | S003(D) | High. |
| C035 | Voluntary settlement account must be FDIC-insured, consumer-owned, interest credited to consumer, independently administered, referral-compensation free. | S001 §2040(6)(a)–(e) | High. Independent administrator fee treatment remains PASS-02 hold. |
| C036 | Actual control of money for creditor distribution can trigger DMP classification even if provider lacks physical possession. | S002 §2000; S004(B) | High definition-level conclusion. |
| C037 | DMP qualification requires separate FDIC-insured trust account. | S005(A)(3) | High. |
| C038 | Consumer creditor-payment funds must be separate from operating funds and held in trust in licensee name at insured institution. | S002 §2014(14) | High. |
| C039 | SCC rule declares DMP trust money consumer-benefit property, not licensee property; bars commingling with operating or other-person funds. | S007 -40(C); S008 | High. |
| C040 | Trust duties apply when third party handles funds for licensee. | S007 -40(C)(3) | High. |
| C041 | Third-party control requires agency agreement plus Bureau notice/conditions; licensee remains liable for agent violations. | S007 -40(L); S008 | High. |
| C042 | DMP must maintain practice of creditor disbursement within eight business days and disclose practices/exceptions in writing. | S002 §2014(11) | High. |
| C043 | “Business day” means day the licensee’s office is open. | S007 -10 | High. |
| C044 | Eight-day language is an established-practice standard with disclosed exceptions, not simple authority to warehouse funds for eight days. | S002 §2014(11) | High textual reading. |
| C045 | DMP statements must be at least quarterly and account for receipts and creditor-specific disbursements since prior statement. | S002 §2014(4) | High. |
| C046 | On request consumer gets signed/date receipt or electronic account-status access. | S002 §2014(15) | High. |
| C047 | DMP bond obligation includes correctly/accurately accounting for all licensed-business funds. | S002 §2003 | High. Bond remedies beyond this point excluded. |
| C048 | No express trust-bank reconciliation cadence was located in Chapter 20 / Chapter 110. | S002; S007 | Held as absence finding. |
| C049 | DMP records retained minimum three years after termination, separate from other-business records, with secure disposal of financial information. | S002 §2008 | High. |
| C050 | Settlement-agreement records likewise retained three years after termination; precontract disclosures copied and retained. | S001 §§2034, 2040(4) | High. |
| C051 | Ch.20.1 substantive settlement act became effective 7/1/2021. | S011 enactment 2 | High. |
| C052 | Current Ch.230 settlement rules derive from final SCC rule effective 12/15/2021. | S006 history / prior final order | High. |
| C053 | Modern DMP architecture traces to 2004 Ch.790 but current Code controls. | S012; S002 | High historical/current distinction. |
| C054 | Consequential trust/delegation/disclosure provisions were adopted in final SCC order effective 12/1/2015. | S008 | High. |
| C055 | Current Administrative Code still carries those operative provisions as of access. | S007 | High as of 10/24/2026 access. |
Example · Result · Claims · 6 data rows
| Example | Result | Claims |
|---|---|---|
| Settlement-only provider collects consumer money to transmit to creditors | Classification hold / additional Chapter 20 authorization dependency, regardless of amount | C034, C036 |
| Settlement account $1,200 balance, independently proven $250 earned fee not previously deducted | $1,200 − $250 = $950 consumer return; no administrator fee assumed | C025, C035 |
| DMP receives $400 + $600 creditor money plus provider has $5,000 operating cash | $1,000 trust money must remain legally distinct from $5,000 operating money | C037–C040 |
| DMP cancellation: $700 creditor funds received, $450 already sent, $60 indisputably refundable fee | Undisbursed = $250; total return in stated early-window assumptions = $250 + $60 = $310 | C027–C029 |
| DMP cancellation period | Execution date excluded under §1-210(A); exact weekend/holiday endpoint held | C030–C032 |
| Eight-business-day DMP practice | Count days provider office is open; exact calendar endpoint requires receipt and office facts | C042–C044 |
PASS-03 issue · Status · Claims · 29 data rows
| PASS-03 issue | Status | Claims | Exact missing authority / next action |
|---|---|---|---|
| Settlement written agreement form | Answered | C006–C013 | Broader arbitration/forum/unconscionability law remains later contract/case-law pass. |
| DMP written agreement form | Answered | C014–C021 | No remaining core statutory form question identified. |
| Electronic agreement/signature mechanics | Answered for Virginia UETA | C022–C023 | Federal E-SIGN interaction not needed to establish the state-law duties here and remains outside this state-focused analysis unless later required. |
| Settlement pre-execution disclosures | Answered | C009 | Actual provider document would need clause-level compliance review. |
| DMP pre-execution disclosures and formatting | Answered | C017–C018 | Actual form still requires factual inspection. |
| Creditor participation expectations | Answered | C019–C020 | Case-specific creditor representations remain factual. |
| Settlement prohibited agreement conditions | Answered in Chapter 20.1 scope | C011–C013 | Broader void/unenforceable clauses require separate Virginia contract and VCPA research. |
| DMP prohibited agreement clauses | Answered | C021 | General contract doctrines remain later pass. |
| Settlement termination | Answered in core | C024–C026 | Exact fund-return deadline and PASS-02 fee/account-charge questions remain open. |
| DMP termination and fee refund windows | Answered textually | C027–C033 | §2016 reimbursement treatment remains PASS-02 unresolved; exact private cancellation endpoint may depend on facts and authority not established here. |
| Legal day-count starting rule | Answered | C030 | Private weekend/holiday extension not established. |
| Settlement voluntary account ownership/control | Answered | C034–C036 | Independent account-administrator charge treatment remains PASS-02 hold. |
| DMP trust-account structure | Answered | C037–C040 | Institution-specific deposit mechanics and any additional banking rules remain open. |
| DMP third-party handler | Answered | C040–C041 | Actual Bureau conditions for a particular appointed agent would require provider-specific evidence. |
| DMP creditor disbursement practice | Answered | C042–C044 | Exact timestamp counting for a particular receipt would require provider facts and any applicable interpretation. |
| Consumer statements / receipts / access | Answered | C045–C046 | No separate settlement quarterly statement requirement established. |
| Trust/account reconciliation cadence | Unresolved | C047–C048 | Search SCC examination manuals, formal guidance, and controlling adjudications for any specific reconciliation cycle before asserting one. |
| DMP record retention | Answered | C049 | Other records may have separate retention rules outside this chapter. |
| Settlement record retention | Answered | C050 | Same limitation. |
| Settlement enactment/currentness | Answered for consequential duties | C051–C052 | Future amendments must be rechecked at future publication date. |
| DMP regulatory adoption/currentness | Answered for consequential duties | C053–C055 | No claim that all historical amendments in unrelated subsections were reviewed. |
| Controlling appellate construction of these clauses | Not located | — | Expand later case-law pass using Virginia appellate/SCC case dockets and subsequent-history checks. |
| PASS-02 later-debt timing interpretation | Excluded / remains held | — | PASS-02 coordinator review and/or later targeted authority required. |
| PASS-02 independent account-charge interpretation | Excluded / remains held | — | No affirmative permission inferred here. |
| PASS-02 §2016 reimbursement-refund construction | Excluded / remains held | — | No refund classification adopted here. |
| Licensing/fee reassessment | Excluded | — | PASS-01/PASS-02 remain separate. |
| Bonds/insurance/remedies architecture | Excluded except accounting clause needed here | C047 | Dedicated later pass required. |
| Full collection/litigation/limitations/debtor exemptions/secured/sector/local/tribal/general contract/case-law | Open | — | Required parent-state work remains. |
| Full Virginia dossier / state acceptance / A066 | Open | — | No acceptance or publication-readiness implication. |
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
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Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.
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The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.
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Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.
revise
Inside: A. Substantive findings · 1. Classification follows the conduct, funds arrangement, and customer—not the marketing label · 3. Consumer fee bases, ceilings, additional charges, and currentness
Inside: Bottom line · 1. Later debt settled without its own creditor payment · What Virginia actually says
Inside: A. Exact narrative-to-canonical-claim map · Exact identity corrections · B1. Replacement for PASS-02 narrative § 2, “Current conclusion”
Inside: A. Exact old-to-replacement claim map · B1. Replacement for PASS-03 claim C027 · Dependent PASS-03 language
Original saved Markdown SHA-256: 01a2b1a43a31b0b9cd3aad7c1dc21c878bd7869fc2ff69c5738fefa13045f056. Public formatting, private-reference removal and correction annotations are separate from that immutable original.