Neon Law Nautilus — debt-shield design

Nautilus is the firm's $66/month debt-collection correspondence shield. A licensed attorney becomes the consumer's address of record and answers debt collectors under the consumer's federal rights — by letter, with an attorney signing every one. It runs on the inbound-email engine and the @approve attorney-approval gate that already serve the firm in production; the /services/nautilus product page, route, and nav already ship.

This document is the canonical compliance contract for the offering. The Restate workflow PRs (intake, triage, debt validation, cease/FCRA dispute, settlement/referral) each cite it rather than re-deriving the scope boundary. Every statutory claim below is grounded in an official U.S. government source so a future reader can re-verify it as the law moves.

The scope boundary (read this first)

Nautilus v1 is a correspondence shield only. It is what it does — and just as load-bearing, what it deliberately is not:

  1. A flat legal fee, never contingent. The fee is a flat $66/month for legal representation in debt-collection communications. It is never a percentage of the debt, never contingent on reducing or settling a balance, and never sold by outbound telephone solicitation. The number stays $66 whether the balance is $500 or $50,000.
  2. No debt settlement for a cut, no debt management. Nautilus asserts rights and demands validation; it does not renegotiate, settle, or alter the terms of a debt as its business.
  3. No bankruptcy assistance. No template, questionnaire, or marketing surface advertises or sells bankruptcy help. Bankruptcy is a referral, never handled in-workflow.
  4. No litigation. A collection lawsuit, a summons, or a viable damages claim is litigation — referred to litigation counsel, never answered as correspondence.

These four hold the product clear of three regimes that would otherwise reach it. Each carve-out is grounded below.

Why the FTC Telemarketing Sales Rule advance-fee ban does not reach us

The TSR bans collecting any fee for a debt relief service before at least one of the consumer's debts has actually been renegotiated or settled (16 C.F.R. §310.4(a)(5)). It does not reach Nautilus, on two independent grounds:

There is no general attorney exemption for inbound calls about debt relief services in 16 C.F.R. §310.6 — the protection is that Nautilus is neither a debt relief service nor sold by telemarketing, so the ban never attaches.

Why the bankruptcy "debt relief agency" disclosures are not triggered

The "debt relief agency" label, and the §527/§528 disclosures it carries (including the mandated "We are a debt relief agency. We help people file for bankruptcy" advertising statement), attach only to a person who provides "bankruptcy assistance … in return for the payment of money" (11 U.S.C. §101(12A)). Milavetz, Gallop & Milavetz, P.A. v. United States, 559 U.S. 229 (2010), confirms the label reaches attorneys who provide bankruptcy assistance — and is tethered to that assistance. Because Nautilus provides no bankruptcy assistance, it is not a debt relief agency and owes none of the 11 U.S.C. §§526–528 disclosures. A future bankruptcy-prep tier would take on that label deliberately; it is out of v1.

Why no debt-adjuster / prorater license is needed in CA / NV / WA

Each state exempts an attorney rendering services in the practice of law from its debt-adjuster licensing scheme. The exemption is conditional, not categorical: it holds only while the work is genuine practice of law in an attorney-client relationship, with fees flowing to the firm and an attorney owning every matter.

Unauthorized practice of law

A licensed attorney reviews and signs every outbound letter via the @approve gate — the staff-reply approval bridge already live in production. No letter auto-sends. The attorney is load-bearing, per mission.md: the fee buys an actual lawyer in the loop, not software pretending to be one. Every Nautilus Restate workflow PR reuses this @approve gate as its UPL control; none introduces an auto-send path.

The engagement letter governs

A written engagement letter signed before representation begins states the exact scope, the $66 monthly fee, any out-of-scope rate, and how either party may end the representation. The no-contingency rule lives in the engagement letter itself, not only in marketing. Nautilus guarantees no particular result and does not erase debts the client owes — it makes sure the client's rights are used and that collectors deal with the client's lawyer. The letter is compliant across the firm's California, Nevada, and Washington admissions.

The four core letters and their statutory hooks

Each letter carries role-scoped signature anchors so the attorney signs, and each goes out only through the @approve gate.

Official sources for the operative text:

The CFPB's Regulation F (12 C.F.R. part 1006) is the FDCPA implementing rule — §1006.6 restates the attorney-representation and cease-communication limits, and §1006.34 prescribes the modern validation notice. It is the layer most likely to drift first, so workflow copy should track it as the regulation, with the statute as the anchor.

The referral seams

Nautilus refers out the moment a matter leaves correspondence:

Intake & portal UX contract

The Client Council's findings are requirements for the surfaces that workflows 01–02 build:

Build sequence

Nautilus engagements are projects matters opened by onboarding__ and closed by closing__letter. The workflows ride the existing workflows-service Restate worker — one worker, no per-workflow pod — and the existing inbound-email engine and @approve gate. Build order, each as one PR:

  1. 01 — Intake & notice of representation (notice_of_representation, §1692c(a)(2)).
  2. 02 — Inbound triage — classify each inbound collector .eml against active matters; the deadline-tracking spine.
  3. 03 — Debt validation (debt_validation, §1692g; 30-day timer).
  4. 04 — Cease-communication & FCRA dispute (cease_communication, §1692c(c); fcra_dispute, §1681i).
  5. 05 — Settlement & referral (settlement_letter, client-directed, no cut; lawsuit/summons → litigation referral).

See docs/glossary.md for the Person / Entity / role vocabulary these workflows use, and the agent-workflows.md for the feature-first recipe each PR follows.