SettleADebt C_BR PASS-12 — Brazil
One bounded provenance-only repair to PASS-11
Affected report: C_BR PASS-11, response 79817197-4ba7-49d1-8617-d119fe293dcf
Scope: Provenance attribution only.
PASS-11’s substantive prior-information correction, H06 source-receipt clarification, source-content partition, legal findings, dates, arithmetic, claims, examples and holds remain preserved. This patch does not redo PASS-07 or PASS-11 legal research and does not modify any substantive conclusion.
Additional web or legal-source access in PASS-12: None.
New source register: None.
Source-specific opening clocks: Still unknown.
Workflow checkpoints: Not source-opening timestamps.
The error corrected here is that PASS-11 treated the later BR7 coordinator’s use of earlier BR6 review material as though it replaced the original PASS-07 researcher’s reported generation-stage access history for S009 and S010.
Replacement R2 source/provenance paragraph
Replace the PASS-11 R2 source-count paragraph with the following:
Corrected source and provenance audit: PASS-07 displayed 11 source rows. By content class, rather than by access actor or access stage, they divide into four operative or amending bodies (S001–S004), four limited crossover or timing sources (S007–S010), one historical revoked source (S011), and two index/unread dynamic bodies (S005–S006), for a total of 4 + 4 + 1 + 2 = 11. At original PASS-07 generation, the researcher reported fresh access to S001–S004, fresh limited or timing access to S007–S010, a historical revoked-body read for S011, and no substantive body read for S005–S006. During the later BR7 coordinator review completed at 2026-10-27T04:35:55.546223Z, the coordinator separately fresh-checked selected provisions from S001–S004 and S007–S008, while the S009–S010 checks were supplied through precisely dated prior BR6 primary-check reuse completed at 2026-10-27T04:25:31.766016Z. That later review-stage reuse neither rewrites nor independently certifies the original PASS-07 researcher’s reported fresh-generation access to S009 and S010. The two completion timestamps are workflow checkpoints, not source-opening clock times. In PASS-11, the researcher freshly reopened only the three narrow PASS-11 sources corresponding to Lei 12.414, LC 166 and Decreto 9.936; PASS-11 did not reopen P07 S004 or S007–S011. Reading S004’s official consolidated Resolução 4.737 PDF and its visible Resolução 4.990 annotations does not establish that standalone S005 was read. S006 remains unread. The original PASS-07 researcher reported reading the historical revoked S011 body; the BR7 coordinator did not reopen Decreto 7.829 but separately confirmed its repeal through Decreto 9.936 art. 22, and PASS-11 likewise did not reopen Decreto 7.829. Source-specific clock times remain unknown throughout.
Actor-and-stage provenance matrix
Content classification and access provenance are separate dimensions.
| Source group |
Original PASS-07 researcher claims |
Later BR7 coordinator checks |
PASS-11 researcher access |
| S001–S003 — Lei 12.414, LC 166, Decreto 9.936 |
Researcher reported fresh operative/amending reads within the stated P07 limits. |
Coordinator separately fresh-checked selected provisions during BR7 review completed 2026-10-27T04:35:55.546223Z. |
PASS-11 freshly reopened these three bodies only for its narrow prior-information, H06 and repeal/currentness patch. |
| S004 — consolidated Resolução CMN 4.737 PDF |
Researcher reported a fresh read of the official consolidated PDF and specified articles/pages. |
Coordinator separately checked selected arts. 1–6 and 12–19 and the visible 4.990 annotations; no PDF-pixel review was claimed. |
PASS-11 did not reopen S004. |
| S005–S006 — standalone 4.990 and BCB 14 dynamic pages |
Researcher classified both as index/failed-body or unread. |
Coordinator did not upgrade either source to a substantive read. Standalone 4.990 and the detailed BCB 14 procedure remained unread. |
PASS-11 did not retry or reopen either source. |
| S007–S008 — LC 105 and LGPD limited crossovers |
Researcher reported fresh limited reads at original P07 generation. |
Coordinator separately fresh-checked the selected LC 105 and LGPD provisions during BR7 review. |
PASS-11 did not reopen either source. |
| S009–S010 — CDC arts. 2–3 and Civil Code art. 132 |
Researcher reported FRESH-READ—LIMITED for S009 and FRESH-READ—TIMING ONLY for S010 at original P07 generation. |
Coordinator used precisely dated prior BR6 primary-check reuse, completed 2026-10-27T04:25:31.766016Z, rather than treating these as fresh BR7 review reads. |
PASS-11 did not reopen either source. |
| S011 — revoked Decreto 7.829 |
Researcher reported reading the historical revoked body to preserve the original opt-in regulatory history. |
Coordinator did not reopen Decreto 7.829; it freshly confirmed repeal through current Decreto 9.936 art. 22. |
PASS-11 did not reopen Decreto 7.829. |
Neither workflow timestamp identifies when any source was opened by the original researcher, the BR6 reviewer or the BR7 reviewer.
Corrected affected source-audit rows
The content classes remain unchanged. The descriptions below replace only the access-stage language in PASS-11.
| P07 source ID |
Content class |
Corrected provenance description |
| S007 |
Limited crossover/timing source 1 of 4 |
Original PASS-07 researcher reported a fresh limited read of LC 105 art. 1 §3(VII). The BR7 coordinator later and separately fresh-checked the selected LC 105 material. PASS-11 did not reopen this source. Full literal URL: https://www.planalto.gov.br/ccivil_03/leis/lcp/lcp105.htm |
| S008 |
Limited crossover/timing source 2 of 4 |
Original PASS-07 researcher reported a fresh limited crossover read of the selected LGPD provisions. The BR7 coordinator later and separately fresh-checked the selected LGPD material. PASS-11 did not reopen this source. Full literal URL: https://www.planalto.gov.br/ccivil_03/_ato2015-2018/2018/lei/l13709compilado.htm |
| S009 |
Limited crossover/timing source 3 of 4 |
Original PASS-07 researcher row remains FRESH-READ—LIMITED, limited to CDC arts. 2–3. During the later BR7 coordinator review, the coordinator used prior BR6 primary-check reuse completed at 2026-10-27T04:25:31.766016Z; that review-stage reuse does not rewrite or independently certify the original researcher access claim. PASS-11 did not reopen this source. Full literal URL: https://www.planalto.gov.br/ccivil_03/leis/l8078compilado.htm |
| S010 |
Limited crossover/timing source 4 of 4 |
Original PASS-07 researcher row remains FRESH-READ—TIMING ONLY, limited to Civil Code art. 132 caput and §§1–4. During the later BR7 coordinator review, the coordinator used prior BR6 primary-check reuse completed at 2026-10-27T04:25:31.766016Z; that review-stage reuse does not rewrite or independently certify the original researcher access claim. PASS-11 did not reopen this source. Full literal URL: https://www.planalto.gov.br/ccivil_03/leis/2002/l10406compilada.htm |
| S011 |
Historical revoked source 1 of 1 |
Original PASS-07 researcher reported reading Decreto 7.829 as a historical revoked body. The BR7 coordinator did not reopen Decreto 7.829 but separately confirmed repeal through Decreto 9.936 art. 22. PASS-11 also did not reopen Decreto 7.829. None of those later steps supplies a new full-body read or source-opening clock. Full literal URL: https://www.planalto.gov.br/ccivil_03/_ato2011-2014/2012/decreto/d7829.htm |
The classifications of S001–S006 remain substantively unchanged:
- S001–S004 remain the four operative/amending content rows.
- S005–S006 remain the two index/unread content rows.
- S004’s consolidated annotations do not upgrade S005.
- S006’s detailed procedure remains unread.
Exact old-to-new affected-cell crosswalk
| Patch ID |
Affected PASS-11 item |
Erroneous or incomplete wording |
Replacement disposition |
| P12-X01 |
R2 replacement source-count paragraph |
Treated S009–S010 as “dated reuse, not fresh P07 or PASS-11 access.” |
Replace with the full R2 paragraph above: S009–S010 were researcher-reported fresh at original P07 generation; only the later BR7 coordinator check used prior BR6 review reuse. |
| X02 |
R2 narrative for S007 |
“fresh limited primary-family read in the P07 review scope” did not identify the actor/stage. |
State separately: original P07 researcher reported fresh limited access; BR7 coordinator later fresh-checked selected material; P11 did not reopen it. |
| X03 |
R2 narrative for S008 |
“fresh limited primary-family read in P07” did not distinguish generation from review. |
State separately: original P07 researcher reported fresh limited crossover access; BR7 coordinator separately fresh-checked it; P11 did not reopen it. |
| X04 |
R2 audited S009 row |
Reclassified original P07 access as prior BR6 reuse. |
Preserve original researcher row as FRESH-READ—LIMITED; identify BR6 reuse only as the later BR7 coordinator-review method. |
| X05 |
R2 audited S010 row |
Reclassified original P07 access as prior BR6 reuse. |
Preserve original researcher row as FRESH-READ—TIMING ONLY; identify BR6 reuse only as the later BR7 coordinator-review method. |
| X06 |
R2 audited S011 row |
Correctly said P11 did not reopen it, but did not fully preserve the original researcher’s reported historical read. |
State all three stages: original P07 researcher historical-body read; BR7 coordinator repeal confirmation through Decreto 9.936 only; no P11 reopening. |
| X07 |
PASS-11 claim C013 |
“S009–S010 remain dated prior reuse, not fresh PASS-07/PASS-11 access.” |
Replace in full with the corrected C013 below. |
| X08 |
PASS-11 coverage G17 |
“Dated reuse preserved.” |
Replace in full with the corrected G17 below. |
| X09 |
PASS-11 crosswalk item X09/source-audit description |
Described a coherent content partition without separating access actor/stage. |
Retain 4 + 4 + 1 + 2 = 11, but expressly state that the partition is a content classification and does not determine original-research, later-review or P11 access status. |
| X10 |
PASS-11 final patch disposition item 2 |
Said the source narrative was corrected without acknowledging the later-stage conflation. |
Replace with: “PASS-07’s 11-source content partition remains correct, while the provenance is now separated among original P07 researcher claims, later BR7 coordinator checks—including BR6 reuse for S009–S010—and P11’s own narrow S001–S003 reopening.” |
Affected-cell crosswalk count: 10.
Full replacement for PASS-11 claim C013
| Claim ID |
Replacement proposition |
Evidence and limit |
| C_BR-P11-C013 |
A098. Original PASS-07 source rows S009 and S010 report fresh generation-stage access: S009 as FRESH-READ—LIMITED for CDC arts. 2–3 and S010 as FRESH-READ—TIMING ONLY for Civil Code art. 132 caput and §§1–4. During the later BR7 coordinator review, those two bodies were checked through precisely dated prior BR6 primary-check reuse completed at 2026-10-27T04:25:31.766016Z. That review-stage reuse does not rewrite or independently certify the original PASS-07 researcher’s access claims. PASS-11 did not reopen either source. |
Original P07 researcher source cells supplied in PASS-12; BR6 and BR7 workflow records supplied by the coordinator. The completion timestamps are workflow checkpoints, not source-opening clocks. Source-specific clocks remain unknown. |
This replacement changes only provenance wording. It does not alter the substantive CDC or Civil Code use in PASS-07.
Full replacement for PASS-11 coverage G17
| Coverage ID |
Correction question |
Finding / claim refs |
Status and exact residual |
| G17 |
S009/S010 provenance |
Corrected C_BR-P11-C013 |
Original P07 researcher rows remain researcher-reported fresh generation-stage access. The later BR7 coordinator review used prior BR6 primary-check reuse for those two bodies, and PASS-11 did not reopen them. Neither the review reuse nor the BR6/BR7 workflow timestamps establishes any source-specific opening clock or upgrades the work to all-source/current-consolidation certification. |
PASS-12 atomic provenance claims
| Claim ID |
Exact provenance proposition |
Evidence and limit |
| C_BR-P12-C001 |
The 4 operative/amending + 4 limited/timing + 1 historical + 2 index/unread = 11 partition is a content classification, not an access-actor or access-stage classification. |
Original PASS-07 source rows and supplied review record. |
| C002 |
S007 and S008 were reported as fresh limited reads by the original P07 researcher; the BR7 coordinator later fresh-checked selected provisions independently of that generation claim; P11 did not reopen them. |
Original P07 S007–S008 cells and supplied BR7 review bounds. |
| C003 |
S009 and S010 were reported as fresh limited/timing reads by the original P07 researcher; the later BR7 coordinator used prior BR6 check reuse; P11 did not reopen them. |
Original P07 S009–S010 cells plus BR6/BR7 workflow records. |
| C004 |
S011 was reported as a historical revoked-body read by the original P07 researcher; BR7 did not reopen that body but confirmed repeal through Decreto 9.936 art. 22; P11 did not reopen it. |
Original P07 S011 cell and supplied BR7/P11 record. |
| C005 |
S004’s consolidated 4.737 read and visible 4.990 annotations do not establish a standalone S005 read; S006 remains unread. |
Preserved P07/P11 source limits. |
| C006 |
BR6 completion at 2026-10-27T04:25:31.766016Z and BR7 review completion at 2026-10-27T04:35:55.546223Z are workflow checkpoints, not source-opening times. PASS-12 opened no additional source. |
Supplied coordinator records and PASS-12 execution boundary. |
PASS-12 atomic-claim count: 6.
Complete PASS-12 correction coverage
| Coverage ID |
Provenance issue |
Finding / claim refs |
Status and exact residual |
| P12-G01 |
Source-content count |
C001 |
Preserved: 4 + 4 + 1 + 2 = 11. |
| G02 |
Content class versus access stage |
C001 |
Corrected: they are independent dimensions. |
| G03 |
S007/S008 actor-stage provenance |
C002 |
Corrected: original researcher fresh report, later coordinator fresh check, no P11 reopening. |
| G04 |
S009/S010 actor-stage provenance |
C003 |
Corrected: original researcher fresh report, later BR7 review reuse, no P11 reopening. |
| G05 |
S011 actor-stage provenance |
C004 |
Corrected: original historical read preserved; later repeal confirmation is not a reread. |
| G06 |
S004/S005/S006 boundaries |
C005 |
Preserved: standalone 4.990 and BCB 14 remain unread. |
| G07 |
Workflow versus source-opening clocks |
C006 |
Corrected/held: all per-source clocks remain unknown. |
| G08 |
P11 substantive corrections |
Preserved P11 C001–C012 and C014–C015 |
Unchanged: prior-information right, H06 receipt assumption and legal holds remain. |
| G09 |
Additional source access in P12 |
C006 |
None. No source register is created. |
| G10 |
Whole component/country acceptance |
Preserved holds |
Unchanged HOLD. |
PASS-12 core-coverage count: 10.
Retained holds
| Hold ID |
Preserved status |
| P12-H01 |
All PASS-11 substantive prior-information findings and sequencing uncertainty remain unchanged. |
| H02 |
H06 still conditionally assumes source receipt on Friday, October 16, 2026; its October 20 result remains hypothetical and unchanged. |
| H03 |
Standalone Resolução CMN 4.990 and the detailed Resolução BCB 14 procedure remain unread. |
| H04 |
No source-specific opening clock is established for P07 generation, BR6 review, BR7 review, P11 or P12. |
| H05 |
Full current-consolidation, all-source, private-contract, actual-record, foreign, state, DF, municipal and local-procedure questions remain held. |
| H06 |
No provider, database, person, consent, notice, cancellation, score, remedy, A097/A098, parent, publication or Brazil-wide acceptance follows. |
Retained-hold count: 6.
Accurate counts and self-check
| Item |
PASS-12 result |
| New legal research |
0 |
| New web/source openings |
0 |
| New source-register rows |
0 |
| Original PASS-07 source rows audited |
11 |
| Content partition |
4 operative/amending + 4 limited/timing + 1 historical + 2 index/unread = 11 |
| Old-to-new affected cells |
10 |
| Actor-stage matrix rows |
6 |
| Full replaced PASS-11 claims |
1: C013 |
| Full replaced PASS-11 coverage rows |
1: G17 |
| New PASS-12 provenance claims |
6 |
| PASS-12 core coverage rows |
10 |
| Retained-hold rows |
6 |
| New or recalculated legal deadlines |
0 |
| New arithmetic |
0 |
| New workflow examples |
0 |
| Modified P11 legal conclusions |
0 |
| Source-specific clock claims added |
0 |
| API, Deep Research, Work/Codex, subagents or new chats |
None |
| Private or named record lookup |
None |
| Contact, filing, complaint or account action |
None |
| Coordinator-file write |
None performed or claimed |
| Review status |
Provenance correction only; no independent-review or all-source-certification claim. |
Final provenance disposition
PASS-12 preserves the immutable original PASS-07 researcher source cells as reported:
- S007 and S008: researcher-reported fresh limited reads;
- S009: researcher-reported FRESH-READ—LIMITED;
- S010: researcher-reported FRESH-READ—TIMING ONLY;
- S011: researcher-reported historical revoked-body read.
It separately records the later BR7 coordinator process:
- selected fresh checks for S001–S004 and S007–S008;
- prior BR6 check reuse for S009–S010;
- repeal confirmation through Decreto 9.936 rather than reopening S011.
It separately records PASS-11 access:
- narrow fresh reopening of only PASS-11 S001–S003;
- no reopening of P07 S004 or S007–S011.
The BR6 and BR7 completion timestamps remain workflow checkpoints only. They do not establish when any source was opened.
END C_BR PASS-12