{"meta":{"key":"s_tn--pass-02","task":"S_TN","title":"Tennessee current-law authentication, 2026 rules, transition/overlap, and indexed amounts","parent_title":"Tennessee debt and debt relief law","edition":"pass-02","path":"/research/s_tn--pass-02/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-24","tables":7,"claims":13,"sources":10,"review_status":"revise","review_complete":true,"sha256":"dcefb7912814dcf5034b263a0aca9793e45b465dc5126be0d59359ff60c5cf26","headings":["Tennessee current-law authentication, 2026 rules, transition/overlap, and indexed amounts","PASS-02 bottom line","1. Current Part 55 and Part 58 are authenticated as current statutory programs","The TDCI “Part 48” discrepancy","2. The transition statute has three distinct grandfathering rules","§5820(a): transactions","§5820(b): existing licenses","§5820(c): services other than debt resolution","Section 3: new-law temporal rule","Result for post-January 1, 2026 new debt-resolution contracts","3. Agency transition guidance helps, but creates an interpretation issue rather than eliminating it","Present PASS-02 interpretation boundary","4. Permanent 2026 rules are authenticated as effective, but their complete operative text still is not","Important limitation","5. Indexed Part 55 consumer-fee amounts remain held—and the reason is now sharper","What this pass could not authenticate","Why no calculation is supplied","6. No new final-rule authority resolves the custodial/overlap question","7. Targeted interpretation/case check"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Medium","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_TN/pass-02","facets":{"geography":["us","us-tn"],"debt_type":[],"stage":[],"subject":["policy-history"]},"scope":"Authenticate ONLY currentPart55/58/2026rules and the specific transition/overlap and indexed-amount authority. Existing SOS PDFs repeatedly403; oldMay2026packet exceeds ordinary reader capacity. Try a materially different readable PUBLIC official final filing/agency-hosted text or authenticated enactment chain, record exact actual results; do not endlessly repeat identical blocked URLs. Amendment HA0187 is not itself final/current codification. No fresh broad classification/examples/TSR recap.","pending_corrections":0},"markdown":"# SettleADebt — S_TN PASS-02\n\n## Tennessee current-law authentication, 2026 rules, transition/overlap, and indexed amounts\n\n**Research baseline:** October 22, 2026, Pacific.\n**Actual PASS-02 public-source research date:** **October 24, 2026, Pacific.**\n\nThis pass was deliberately restricted to the unresolved authentication issues from PASS-01. I did **not** rerun Tennessee’s classification overview, worked fee examples, or federal TSR analysis.\n\n## PASS-02 bottom line\n\nFour conclusions changed or became materially stronger.\n\n**First, Tennessee’s current agency materials now independently authenticate Part 55 and Part 58 as the two current statutory homes.** TDCI’s current program page expressly says current debt-management requirements are in **TCA Title 47, Chapter 18, Part 55**, and current debt-resolution requirements are in **Part 58**. The separate TDCI “Laws” page that says “Part 48” for debt resolution is therefore an agency-site inconsistency/typo, not a competing legal classification. The enacted legislative chain also places the 2025 Debt Resolution Services Act in Part 58. [Tennessee.gov+2](https://www.tn.gov/commerce/regboards/debt.html?utm_source=chatgpt.com)\n\n**Second, the exact transition statute materially narrows—but does not eliminate—the PASS-01 transition uncertainty.** Section 47-18-5820 separately preserves: pre-January 1, 2026 transactions of Part 55 licensees; pre-January 1, 2026 Part 55 licenses and rights arising from issuance; and continued Part 55 licensing for businesses offering services **other than debt-resolution services**. Section 3 makes the new Act applicable to conduct occurring and licenses applied for or renewed on or after January 1, 2026. That structure does **not expressly say that an old Part 55 license authorizes new post-January 1 debt-resolution contracts.** [Tennessee General Assembly+1](https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf?utm_source=chatgpt.com)\n\nTDCI’s operational instruction says an already licensed debt-management provider can continue operating under that license until it expires and, at expiration, must seek an initial debt-resolution license if it meets the debt-resolution criteria. But TDCI’s January 5, 2026 public notice simultaneously says providers offering debt-resolution services to Tennessee consumers must obtain a debt-resolution license before providing those services. Those materials do not establish that new post-effective-date debt-resolution contracts may simply remain governed by old Part 55 rules. **That specific overlap remains held.** [Tennessee.gov](https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html?utm_source=chatgpt.com)\n\n**Third, the existence and effective status of the permanent 2026 rules are now much better authenticated.** Tennessee Secretary of State archived-rule metadata identifies permanent rulemaking-hearing rules for **0780-05-18** and **0780-05-19**, filed March 17, 2026, sequence **03-16-26**, effective **June 15, 2026**. The earlier Part 19 emergency rule was temporary. However, the operative final PDFs themselves remain unreadable through the available public reader, so this pass authenticates their **filing/effective status, not every final clause**.\n\n**Fourth, the exact current indexed consumer-fee dollar amounts remain genuinely unresolved.** A historical official rule establishes a 2014 base year and provides that an adjustment year itself becomes the new base year. The January 2026 agency hearing text proposed continuing the annual 10% threshold/rounding mechanism and requiring the current base year and adjusted fees to be placed on a commissioner-selected website. But because the final June 2026 text and the resulting current dollar schedule could not be read, neither “2014 is still the current base year” nor any October 2026 adjusted dollar amount can responsibly be asserted. A fresh CPI calculation from 2014 could be wrong precisely because an intervening adjustment would reset the base year.\n\nNo hypothetical charge or homemade CPI calculation is substituted for that missing authority.\n\n# A. Focused substantive findings\n\n## 1. Current Part 55 and Part 58 are authenticated as current statutory programs\n\nTDCI’s current Debt Management, Debt Resolution, and Credit Services page states:\n\n- current debt-management registration requirements are in **TCA Title 47, Chapter 18, Part 55**; and\n- current debt-resolution registration requirements are in **TCA Title 47, Chapter 18, Part 58**. [Tennessee.gov](https://www.tn.gov/commerce/regboards/debt.html?utm_source=chatgpt.com)\n\nThat is current agency material, not itself a substitute for reading every codified provision. But it resolves the question whether the programs remain current and where TDCI presently locates them.\n\nThe General Assembly’s official House Journal independently records the operative 2025 amendment as adding a new **§47-18-5801 et seq.** and labels it the “Debt Resolution Services Act.” The official bill history says HB0743/SB1078 was enacted and became Public Chapter 287. [Tennessee General Assembly+1](https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf?utm_source=chatgpt.com)\n\n### The TDCI “Part 48” discrepancy\n\nTDCI’s separate Laws page has been indexed as listing debt resolution under “47-18-48.” That conflicts with:\n\n1. TDCI’s current main program page;\n2. the official enacted legislative materials;\n3. the 2026 rulemaking materials defining the Debt Resolution Services Act as Part 58.\n\nAccordingly, **“Part 48” should not be propagated into SettleADebt’s Tennessee data.** It is an agency webpage inconsistency, not evidence that the 2025 Act was codified somewhere other than Part 58.\n\n**Disposition:** current statutory homes authenticated; full official consolidated code text remains a separate retrieval gap.\n\n## 2. The transition statute has three distinct grandfathering rules\n\nThe House Journal reproduces §47-18-5820 in the amendment that the House adopted and passed. The official bill history shows the companion became Public Chapter 287. The three subsections should not be collapsed into one generalized “grandfathering” statement. [Tennessee General Assembly+1](https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf?utm_source=chatgpt.com)\n\n### §5820(a): transactions\n\nThis provision protects **transactions entered into before January 1, 2026** by licensees whose licenses were issued under Part 55. Rights, duties, and interests resulting from those transactions may continue under the prior-law framework.\n\nThe temporal object is the **transaction**, not simply the existence of the provider’s license.\n\n### §5820(b): existing licenses\n\nThis separately preserves **licenses issued under Part 55 before January 1, 2026**, and rights, duties, and interests resulting from issuance of those licenses.\n\nThat is broader than subsection (a) in protecting the existing license itself, but it does not expressly say: “Every new debt-resolution transaction entered into after January 1, 2026 remains a Part 55 transaction until that license expires.”\n\n### §5820(c): services other than debt resolution\n\nThis provision expressly allows a business offering services **other than debt-resolution services**, whose license was issued under Part 55, to continue under the Part 55 license without transitioning to Part 58.\n\nThat qualifier is consequential. It strongly supports continued Part 55 treatment for legacy businesses whose activity is genuinely outside the new definition of debt-resolution services. It does **not** itself solve the treatment of an activity satisfying both the older debt-management concept and the new debt-resolution definition.\n\n### Section 3: new-law temporal rule\n\nThe enacted amendment makes the Act effective:\n\n- July 1, 2025 for rulemaking; and\n- January 1, 2026 for other purposes,\n\nand states that it applies to conduct occurring and licenses applied for or renewed on or after that later date. [Tennessee General Assembly](https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf?utm_source=chatgpt.com)\n\n### Result for post-January 1, 2026 new debt-resolution contracts\n\n**Held—not converted into a grandfathered permission.**\n\nThe safest current statement is:\n\nA Part 55 license issued before January 1, 2026 receives statutory transition protection, but §5820(a) expressly grandfathers transactions only when entered into before January 1, 2026. Section 5820(c) separately protects continued Part 55 operation for services other than debt-resolution services. The statute as actually retrieved does not expressly authorize a legacy Part 55 licensee to originate unlimited new Part 58-type debt-resolution transactions after January 1 merely because its older license remains unexpired.\n\nThat conclusion is reinforced by TDCI’s current public announcement that, starting January 1, providers offering debt-resolution services to Tennessee consumers must first obtain the relevant TDCI license. [Tennessee.gov](https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html?utm_source=chatgpt.com)\n\n## 3. Agency transition guidance helps, but creates an interpretation issue rather than eliminating it\n\nTDCI’s licensing instructions state in substance that a provider already licensed as a Debt Management Services Provider may continue to operate under the license until it expires; at expiration, if it meets the criteria for a Debt Resolution Services Provider, it can apply for an initial debt-resolution license.\n\nThat is meaningful agency operational evidence.\n\nIt should **not** be rewritten as either:\n\n- “all new settlement contracts may stay under Part 55 until old-license expiration,” or\n- “every legacy provider had to obtain a Part 58 license immediately on January 1 regardless of its existing license.”\n\nThe statutory transition language is more granular than either proposition.\n\nTDCI’s January 5 announcement makes the tension clearer. It says the DRSA took effect January 1 and warns providers not to engage in activity requiring licensure until their license has been approved. It describes debt-resolution services broadly enough to encompass traditional settlement operations. [Tennessee.gov](https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html?utm_source=chatgpt.com)\n\n### Present PASS-02 interpretation boundary\n\nThree situations can now be separated:\n\n| Situation | Present evidentiary result |\n| --- | --- |\n| Part 55 transaction entered before Jan. 1, 2026 | Statutory grandfathering established under §5820(a) |\n| Legacy Part 55 licensee continuing services that are **not** debt-resolution services | Continued Part 55 license pathway expressly established under §5820(c) |\n| Legacy Part 55 licensee entering a **new post-Jan. 1, 2026 transaction that satisfies the Part 58 debt-resolution definition** | **Still unresolved at the required publication-grade level**; TDCI operational language cannot be turned into an unstated substantive grandfathering rule |\n\nThat is a substantial narrowing of PASS-01 C013.\n\n## 4. Permanent 2026 rules are authenticated as effective, but their complete operative text still is not\n\nA materially different official source route succeeded: the Tennessee Secretary of State’s archived-rule index.\n\nIt identifies:\n\n- **Chapter 0780-05-18 — Rules and Regulations for Debt Management Services**\n- **Chapter 0780-05-19 — Rules and Regulations for Debt Resolution Services**\n\nas **Rulemaking Hearing Rules**, filed **March 17, 2026**, effective **June 15, 2026**, under filing/sequence **03-16-26**.\n\nThat is sufficient to improve PASS-01’s status finding: these are not merely proposed January rules or an emergency-rule hypothesis. The permanent package reached an effective date.\n\nThe same official archive identifies the earlier 0780-05-19 emergency rule as a temporary rule with an emergency period extending only into June 2026. Thus an October 24, 2026 analysis should not treat the December 2025 emergency text as current merely because a copy remains available in the archive.\n\n### Important limitation\n\nThe archive result authenticates filing metadata. It does **not** make every clause of the final 03-16-26 filing readable.\n\nThe direct final-rule and filing PDFs previously returned 403, and this pass did not repeatedly hammer the same blocked URLs. New TDCI rule landing-page routes were attempted instead and also returned 403.\n\nAccordingly:\n\n**Verified now:** final permanent rule package exists; Chapters 18 and 19; filing date; effective date; sequence.\n\n**Not verified now:** exact final wording of each 2026 amendment, including whether every January redline provision survived exactly unchanged.\n\n## 5. Indexed Part 55 consumer-fee amounts remain held—and the reason is now sharper\n\nThe earlier official Chapter 0780-05-18 version contains the inflation-adjustment rule. Its historical text establishes that:\n\n- **2014 was adopted as the base year**;\n- the administrator determines index movement;\n- when the statutory threshold is reached, specified statutory dollar amounts are adjusted;\n- an adjustment year becomes the **new base year**; and\n- the current base year and adjusted fees are to be publicly listed.\n\nThat historical rule is useful because it shows why a simple “2014 CPI → 2026 CPI” computation is not legally reliable. If an adjustment occurred in between, the base year would reset.\n\nThe January 2026 official TDCI hearing/redline material proposed amending parts of Rule 0780-05-18-.14. The indexed text retains an annual index determination, the 10% threshold and statutory rounding, and states that the current base year and adjusted fees are to be placed on a website selected by the commissioner.\n\nBut that January material was a **notice/hearing-stage redline**, not final operative authority.\n\n### What this pass could not authenticate\n\nNo readable official current schedule was located that states, for October 2026:\n\n- the current inflation base year;\n- the adjusted §47-18-5523 initial fee amount;\n- the adjusted per-creditor/monthly maximum;\n- the adjusted counseling/education amount;\n- the adjusted returned-payment amount; or\n- the date on which the last adjustment took effect.\n\nTherefore PASS-01’s nominal statutory base amounts must remain identified as **base figures**, not October 2026 verified maxima.\n\n### Why no calculation is supplied\n\nBecause the historic rule says an adjustment year itself becomes the next base year, calculating a CPI percentage from 2014 without knowing whether one or more administrator adjustments occurred would risk compounding from the wrong legal base.\n\n**No exact current amount should be published until the administrator’s current adjusted-fee schedule or readable final operative rule is obtained.**\n\n## 6. No new final-rule authority resolves the custodial/overlap question\n\nPASS-01 C004 established from enacted Part 58 language that a Part 58 licensee does not simply take custody or control of consumer funds apart from properly earned fees.\n\nPASS-02 did **not** retrieve readable final Rule 0780-05-19 language sufficient to establish whether the final regulations contain an additional interpretation harmonizing:\n\n- traditional custodial DMP activity under Part 55;\n- noncustodial concessions;\n- an activity that independently meets Part 58’s debt-resolution definition; and\n- legacy-license transition.\n\nConsequently, the statutory result is preserved, but **no new regulatory inference is added.**\n\n## 7. Targeted interpretation/case check\n\nA focused official-domain search for §47-18-5820 and Tennessee debt-resolution interpretation did not return a Tennessee appellate decision or Attorney General opinion resolving the post-2026 legacy-license/new-contract issue. The results instead surfaced TDCI’s current announcement and legislative materials. [Tennessee.gov+1](https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html?utm_source=chatgpt.com)\n\nThat is a search result, **not a statement that no relevant case, administrative order, or interpretation exists anywhere**.\n\nPASS-01 C040 therefore remains an evidence-gap finding, with the scope narrowed to the specific transition/overlap questions investigated here.\n\n# B. PASS-02 source register\n\n| Source ID | Source / issuer / direct literal URL | Exact material used | Status on 2026-10-24 | Actual access and limitation |\n| --- | --- | --- | --- | --- |\n| **S_TN-P2-S001** | TDCI, **Debt Management, Debt Resolution, and Credit Services** — https://www.tn.gov/commerce/regboards/debt.html | Purpose section: current registration requirements in TCA Title 47, Ch.18, **Part 55** and **Part 58** | Current agency webpage | **Read.** Authenticates TDCI’s current statutory program locations; does not substitute for consolidated code text. [Tennessee.gov](https://www.tn.gov/commerce/regboards/debt.html?utm_source=chatgpt.com) |\n| **S_TN-P2-S002** | Tennessee House Journal, March 31, 2025 — https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf | Amendment No.1 adding §§47-18-5801 et seq.; PDF pp.65–66 for §5820 transition and Section 3; adoption/passages immediately following | Official legislative journal / adopted House text | **Text read and relevant PDF page screenshot inspected.** This is stronger than relying on HA0187 alone, but remains part of the enactment chain rather than the unread signed chapter. [Tennessee General Assembly](https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf?utm_source=chatgpt.com) |\n| **S_TN-P2-S003** | Tennessee General Assembly, SB1078/HB0743 bill information — https://wapp.capitol.tn.gov/apps/BillInfo/Default?BillNumber=SB1078&ga=114 | Enacted status; companion became Public Chapter 287; House adopted Amendments 1 & 2; bill summary | Enacted legislative history | **Read.** Authenticates enactment chain and Public Chapter status. [Tennessee Capitol](https://wapp.capitol.tn.gov/apps/BillInfo/Default?BillNumber=SB1078&utm_source=chatgpt.com) |\n| **S_TN-P2-S004** | Tennessee Secretary of State, Archived Rules — https://tnsosorg.tnsosfiles.com/rules/ArchivedRules.php?direction=DESC&sort=FileDate | Entries for 0780-05-18 and 0780-05-19: Rulemaking Hearing Rule, filed 3/17/2026, effective 6/15/2026, sequence 03-16-26; emergency-rule history | Official filing/effective-status index | **Official indexed metadata retrieved; direct archive open subsequently returned 403.** Used only for filing/effective status, not operative clause text |\n| **S_TN-P2-S005** | TDCI, Jan. 13, 2026 Rulemaking Hearing Redline — https://www.ext.glb.mytn.gov/content/dam/tn/commerce/documents/regboards/debtmanage/meetings/2026/Hearing_1-13.pdf | Proposed Ch.0780-05-19 organization and definitions; proposed Rule 0780-05-18-.14 amendments concerning annual index determination/publication | **Proposed/hearing-stage**, not final | Search retrieval exposed substantive text. Direct PDF open later timed out/failed, preventing reliable page-image inspection. **Not used as final operative authority** |\n| **S_TN-P2-S006** | Tennessee SOS historical compiled Chapter 0780-05-18 — https://publications.tnsosfiles.com/rules/0780/0780-05/0780-05-18.20170126.pdf | Rule 0780-05-18-.14: 2014 base year, adjustment threshold/mechanism, new-base-year after adjustment, public listing | Historical rule, effective 2017; subsequently amended | Indexed official text read. Used only to establish historical mechanism, not as October 2026 final wording |\n| **S_TN-P2-S007** | TDCI, **How to Get a License** — https://www.extglb.tn.gov/commerce/regboards/debt/license/get.html | Existing DMP-license transition instruction: operate until expiry; if debt-resolution criteria apply at expiry, initial DRSP application | Current agency procedure | **Read.** Useful agency operational treatment; cannot supersede §5820 or establish governing law for post-effective-date contracts |\n| **S_TN-P2-S008** | TDCI, **Laws** — https://www.tn.gov/commerce/regboards/debt/rules/laws.html | Lists Part 55 correctly but debt resolution as “47-18-48” | Current agency navigation page containing inconsistency | Read/indexed. **Not relied on for Part 58 location** because S001/S002/S003 directly contradict that entry |\n| **S_TN-P2-S009** | TDCI, Jan. 5, 2026 **New Licensing Requirements...Debt Resolution Services Act** — https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html | Jan. 1 effective date; providers must obtain license before providing covered services; statement concerning transition and current enforcement expectation | Current official agency interpretation/procedure | **Read.** Agency guidance, not statutory amendment or adjudication. [Tennessee.gov](https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html?utm_source=chatgpt.com) |\n| **S_TN-P2-S010** | TDCI, current debt news page — https://www.tn.gov/commerce/regboards/debt/news/news.html | Current statement that DRSA took effect Jan. 1, 2026 and persons offering debt-resolution services must first obtain license | Current agency page | **Read.** Corroborative only. [Tennessee.gov](https://www.tn.gov/commerce/regboards/debt/news/news.html?utm_source=chatgpt.com) |\n\n# C. PASS-02 material claim register\n\n| Claim ID | Precise assertion | Sources / pinpoints | Conditions and confidence limits |\n| --- | --- | --- | --- |\n| **S_TN-P2-C001** | TDCI currently identifies Part 55 as the debt-management statute and Part 58 as the debt-resolution statute | P2-S001 Purpose section; P2-S002 §§5801 et seq.; P2-S003 enacted history | High confidence as to current statutory homes; current consolidated code wording itself remains unread |\n| **S_TN-P2-C002** | Part 58’s enacted transition has separate protection for old transactions, old licenses, and non-debt-resolution legacy businesses | P2-S002 §5820(a)–(c), PDF pp.65–66 | High confidence in enacted legislative-chain text |\n| **S_TN-P2-C003** | §5820(a) expressly protects transactions entered before Jan. 1, 2026; it does not expressly grandfather new post-Jan. 1 debt-resolution transactions | P2-S002 §5820(a); Section 3 | Textual conclusion; final adjudicative interpretation not located |\n| **S_TN-P2-C004** | §5820(c) expressly permits continued Part 55 licensing for businesses offering services other than debt-resolution services | P2-S002 §5820(c) | Does not answer an activity meeting the Part 58 definition |\n| **S_TN-P2-C005** | TDCI says an existing DMP licensee may continue under its current license until expiry, but that instruction does not expressly assign old Part 55 law to every new post-2026 debt-resolution agreement | P2-S007 transition instruction; P2-S009 current licensing notice | Agency procedure/interpretation only; statutory overlap remains unresolved |\n| **S_TN-P2-C006** | Permanent rules for Chapters 0780-05-18 and 0780-05-19 were filed March 17, 2026 and became effective June 15, 2026 | P2-S004 official archived-rule entries | **Filing/effective metadata authenticated; substantive final rule clauses not authenticated** |\n| **S_TN-P2-C007** | The January 2026 hearing/redline cannot be treated as the final June 2026 rule | P2-S005 versus P2-S004 | High confidence status distinction |\n| **S_TN-P2-C008** | Historical Rule .14 used 2014 as base year and made an adjustment year the new base year | P2-S006 Rule 0780-05-18-.14(2)–(5) | Historical proposition only; no claim 2014 remains the current base year |\n| **S_TN-P2-C009** | Exact October 2026 adjusted Part 55 consumer dollar amounts remain unverified | P2-S004–S006 and failed current schedule search | High-confidence hold; no CPI computation permissible as substitute |\n| **S_TN-P2-C010** | Computing current fees directly from a 2014 CPI baseline would be unsafe because an intervening statutory adjustment could have reset the base year | P2-S006 Rule .14 historical reset mechanism | Logical consequence of verified historical mechanism; exact current rule remains unread |\n| **S_TN-P2-C011** | TDCI’s “Part 48” reference is inconsistent with current agency, legislative, and rulemaking materials identifying Part 58 | P2-S001, S002, S003, S008 | Treat as webpage error/inconsistency; do not publish Part 48 as controlling |\n| **S_TN-P2-C012** | No new final-rule text was retrieved that resolves the for-profit custodial-DMP/debt-resolution overlap | P2-S004/S005 plus failed routes | Evidence-gap claim only; not a holding that no such clause exists |\n| **S_TN-P2-C013** | Focused official-source searching did not locate a controlling court or AG interpretation of §5820’s new-contract overlap | Focused Tennessee court/AG searches; P2-S009 was agency material instead | Search-result statement only, not proof no decision/order exists |\n\n# D. Original PASS-01 claim patch map\n\nThe original IDs are retained rather than silently replacing them.\n\n| Original claim | PASS-02 disposition | Precise patch |\n| --- | --- | --- |\n| **S_TN-P1-C001** — Part 58 operates Jan. 1, 2026 with Part 55 transition | **STRENGTHEN** | Current TDCI materials expressly identify Part 58; official House Journal supplies §5820/Section 3; official bill history authenticates PC287 enactment. Signed PC287 PDF remains unread, but the enactment/current-program chain is materially stronger. |\n| **S_TN-P1-C004** — Part 58 consumer-fund custody limitation | **NO SUBSTANTIVE CHANGE** | No readable final June 2026 regulatory text was obtained that alters or interprets this statutory proposition. Preserve prior enacted-text finding and prior limitation. |\n| **S_TN-P1-C013** — old-license/new-contract and custodial overlap unresolved | **NARROW / PARTIAL PATCH** | §5820 now establishes three distinct transition buckets. Pre-2026 transactions are clearly grandfathered; old licenses themselves receive protection; non-debt-resolution businesses may continue under Part 55. **New post-Jan. 1 Part 58-type transactions under an unexpired legacy Part 55 license remain held.** |\n| **S_TN-P1-C016** — ordinary DMP base fees | **STATUS PATCH ONLY** | TDCI confirms Part 55 remains a current statutory program. No current adjusted dollar schedule was authenticated, so PASS-01’s “unadjusted bases only” limitation remains. |\n| **S_TN-P1-C017** — education fee limits | **STATUS PATCH ONLY** | Same: current Part 55 program authenticated, current indexed amount still held. |\n| **S_TN-P1-C018** — 90-day education-fee refund | **NO SUBSTANTIVE CHANGE** | Enacted 2014 substance remains supported; exact current codifier paragraph numbering was not independently authenticated in a readable consolidated Part 55. |\n| **S_TN-P1-C019** — CPI mechanism / exact adjusted amount held | **MATERIALLY STRENGTHEN** | Permanent 2026 rule package’s filing/effective status is now authenticated. Historical rule confirms 2014 base and reset-on-adjustment mechanism; January 2026 proposed text shows continued indexing/publication design. **Exact current base year and adjusted amounts remain unverified.** |\n| **S_TN-P1-C033** — federal TSR advance fees | **UNCHANGED / OUTSIDE PASS-02** | Federal baseline intentionally not rerun. |\n| **S_TN-P1-C039** — current rules/code not retrieved | **PARTIAL PATCH** | Final rule **existence, filing date, sequence, and effective date are now authenticated**. The final operative clauses and complete current consolidated Part 55/58 statutory text remain unread through the available routes. |\n| **S_TN-P1-C040** — no controlling interpretation retrieved | **NARROWLY RECONFIRMED** | No controlling court or AG interpretation was found in this focused transition/overlap search. TDCI guidance was found but is agency procedural/interpretive material, not a court holding or final adjudicative order. |\n\n# E. Failed-route table\n\nThese failures are preserved separately from substantive authority.\n\n| Route | Actual result in PASS-02 | Consequence |\n| --- | --- | --- |\n| TDCI debt-management rules page https://www.tn.gov/commerce/regboards/debt/rules/debt-management-rules.html | **403** | Did not expose current operative Chapter 0780-05-18 text |\n| TDCI debt-resolution rules page https://www.tn.gov/commerce/regboards/debt/rules/debt-resolution-rules.html | **403** | Did not expose current operative Chapter 0780-05-19 text |\n| TDCI Jan. 13 hearing PDF at P2-S005 | Search retrieval exposed indexed text; direct open later timed out/failed and could not be reliably rendered as a PDF for page inspection | Used solely as **proposed/hearing-stage** evidence, not final authority |\n| SOS Archived Rules HTML direct opening | **403** after official metadata had been returned through indexed retrieval | Metadata supports filing status; no operative text inferred |\n| Final SOS PDFs 0780-05-18.20260615.pdf, 0780-05-19.20260615.pdf, and 03-16-26.pdf | Prior PASS-01 routes repeatedly returned **403** | Deliberately **not repeatedly retried**; remain operative-text dependency |\n| May 2026 Joint Government Operations rule packet | Prior attempt exceeded ordinary reader capacity | Not repeated; effective-status issue was instead addressed through a materially different official SOS route |\n| Official current Lexis Tennessee Code route | PASS-01 yielded shell/no operative statutory text | Not represented as current-code reading here |\n\n# F. Remaining dependency / exact next-evidence table\n\n| Remaining question | Current status | Exact missing authority | Next evidence action, within current constraints |\n| --- | --- | --- | --- |\n| Exact final wording of Rule 0780-05-18-.14 after June 15, 2026 | **Unresolved** | Readable final 03-16-26 filing or current compiled Chapter 18 | Retrieve only if an official public HTML/text/mirror becomes readable; do not infer from hearing redline |\n| Exact current CPI base year | **Unresolved** | Administrator’s current published base year or final operative .14 plus intervening adjustment history | Locate official TDCI/SOS public schedule; do not calculate from 2014 |\n| Exact current adjusted §5523 amounts | **Unresolved** | Current administrator-published adjusted fee table/notice | Hold every exact adjusted amount until official schedule is readable |\n| Whether any adjustment occurred between 2014 and Oct. 2026 | **Unresolved** | Official notices/fee adjustment history | Search specifically for administrator adjustment notices rather than general CPI data |\n| Exact final Chapter 0780-05-19 standards affecting custody/overlap | **Unresolved** | Current final Part 19 operative clauses | Read public final filing/compiled rule if accessible later |\n| New post-Jan. 1, 2026 debt-resolution contract under legacy Part 55 license | **Partially resolved but held** | Formal rule, agency adjudication, court decision, or authoritative interpretation reconciling §5820(a)/(b), Section 3, and TDCI transition guidance | Target this exact issue; do not generalize “operate until expiry” into fee/licensing permission |\n| Complete current consolidated Part 55 text | **Partially authenticated only** | Readable official current code sections, especially §§5502, 5523, 5532/adjustment-related provisions | Retrieve current official code text when public reader returns substantive content |\n| Complete current consolidated Part 58 text | **Substantially authenticated through enactment chain, not consolidated-code read** | Official current consolidated §§5801–5820 | Retrieve readable official code; compare against PC287 chain and any later amendments |\n| Controlling judicial/AG interpretation | **Not located** | Any actual opinion/order interpreting transition or overlap | Search specific section/case language in a later pass if needed; absence here is not negative authority |\n\n# G. PASS-02 scope coverage\n\n| Assigned item | Result |\n| --- | --- |\n| Authenticate current Part 55 statutory existence/location | **Answered** — TDCI currently identifies Part 55 |\n| Authenticate current Part 58 statutory existence/location | **Answered** — current TDCI page + official enactment chain identify Part 58 |\n| Authenticate Part 58 enactment/transition beyond HA0187 alone | **Answered materially** — official House Journal adoption plus official bill history/Public Chapter chain |\n| Read signed PC287 itself | **Unresolved** — prior official PDF inaccessible |\n| Authenticate permanent 2026 rule legal status | **Answered** — filed 3/17/26, effective 6/15/26, sequence 03-16-26 |\n| Authenticate every final 2026 rule clause | **Unresolved** — operative final PDFs remain inaccessible |\n| Determine whether January hearing redline is current law | **Answered: no** — hearing/proposed material cannot substitute for final filing |\n| Resolve legacy Part 55 pre-2026 transactions | **Answered** — express §5820(a) protection |\n| Resolve continued non-debt-resolution Part 55 businesses | **Answered** — express §5820(c) protection |\n| Resolve new post-2026 debt-resolution contracts by old Part 55 licensee | **Partial/held** |\n| Resolve custodial-DMP/Part 58 overlap through final rules | **Unresolved** |\n| Authenticate historic inflation base mechanism | **Answered historically** |\n| Authenticate current base year | **Unresolved** |\n| Authenticate October 2026 adjusted consumer dollar limits | **Unresolved** |\n| Produce new fee examples | **Not warranted** — no new verified current dollar authority |\n| Revisit TSR | **Excluded by assignment** |\n| Other Tennessee agreement/funds/bond/remedy/litigation/etc. categories | **Remain open; no implication of completion** |\n| Full Tennessee / A066 acceptance | **Not addressed and remains open** |\n\n# H. Researcher self-check\n\nI read current TDCI program and agency guidance, the General Assembly’s current bill-history material, and the relevant enacted-transition language exposed in the official House Journal. For the House Journal PDF, the relevant transition page was also inspected through the available PDF-page rendering rather than relying only on an index extract.\n\nI obtained new official Secretary of State **filing metadata** proving the June 15, 2026 permanent-rule effective date. I did **not** turn that metadata into an assertion that I had read the final operative rule clauses.\n\nThe January 2026 TDCI redline was kept explicitly in **proposed/hearing-stage** status. Its direct PDF route subsequently failed, so its indexed text was not promoted to final-law status.\n\nI did not recompute indexed amounts, assume that 2014 remains the current base year, or turn a statutory nominal amount into an October 2026 ceiling.\n\nI did not treat the TDCI “Part 48” typo as law where multiple stronger official sources identify Part 58.\n\nI did not create other chats, use Deep Research/Work/Codex, file anything, contact Tennessee, change accounts or permissions, purchase access, use private borrower data, or claim a local save.\n\nThis is a **researcher self-check, not independent review**. It does not establish full-state completion, A066 acceptance, or publication readiness.\n\n**END S_TN PASS-02.**\n\n","tables":[{"headers":["Situation","Present evidentiary result"],"index":0,"links":[],"row_links":[[],[],[],[]],"rows":[["Situation","Present evidentiary result"],["Part 55 transaction entered before Jan. 1, 2026","Statutory grandfathering established under §5820(a)"],["Legacy Part 55 licensee continuing services that are not debt-resolution services","Continued Part 55 license pathway expressly established under §5820(c)"],["Legacy Part 55 licensee entering a new post-Jan. 1, 2026 transaction that satisfies the Part 58 debt-resolution definition","Still unresolved at the required publication-grade level; TDCI operational language cannot be turned into an unstated substantive grandfathering rule"]]},{"headers":["Source ID","Source / issuer / direct literal URL","Exact material used","Status on 2026-10-24","Actual access and limitation"],"index":1,"links":[{"href":"https://www.tn.gov/commerce/regboards/debt.html?utm_source=chatgpt.com","text":"Tennessee.gov"},{"href":"https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf?utm_source=chatgpt.com","text":"Tennessee General Assembly"},{"href":"https://wapp.capitol.tn.gov/apps/BillInfo/Default?BillNumber=SB1078&utm_source=chatgpt.com","text":"Tennessee Capitol"},{"href":"https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html?utm_source=chatgpt.com","text":"Tennessee.gov"},{"href":"https://www.tn.gov/commerce/regboards/debt/news/news.html?utm_source=chatgpt.com","text":"Tennessee.gov"}],"row_links":[[],[{"href":"https://www.tn.gov/commerce/regboards/debt.html?utm_source=chatgpt.com","text":"Tennessee.gov"}],[{"href":"https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf?utm_source=chatgpt.com","text":"Tennessee General Assembly"}],[{"href":"https://wapp.capitol.tn.gov/apps/BillInfo/Default?BillNumber=SB1078&utm_source=chatgpt.com","text":"Tennessee Capitol"}],[],[],[],[],[],[{"href":"https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html?utm_source=chatgpt.com","text":"Tennessee.gov"}],[{"href":"https://www.tn.gov/commerce/regboards/debt/news/news.html?utm_source=chatgpt.com","text":"Tennessee.gov"}]],"rows":[["Source ID","Source / issuer / direct literal URL","Exact material used","Status on 2026-10-24","Actual access and limitation"],["S_TN-P2-S001","TDCI, Debt Management, Debt Resolution, and Credit Services — https://www.tn.gov/commerce/regboards/debt.html","Purpose section: current registration requirements in TCA Title 47, Ch.18, Part 55 and Part 58","Current agency webpage","Read. Authenticates TDCI’s current statutory program locations; does not substitute for consolidated code text. \nTennessee.gov"],["S_TN-P2-S002","Tennessee House Journal, March 31, 2025 — https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf","Amendment No.1 adding §§47-18-5801 et seq.; PDF pp.65–66 for §5820 transition and Section 3; adoption/passages immediately following","Official legislative journal / adopted House text","Text read and relevant PDF page screenshot inspected. This is stronger than relying on HA0187 alone, but remains part of the enactment chain rather than the unread signed chapter. \nTennessee General Assembly"],["S_TN-P2-S003","Tennessee General Assembly, SB1078/HB0743 bill information — https://wapp.capitol.tn.gov/apps/BillInfo/Default?BillNumber=SB1078&ga=114","Enacted status; companion became Public Chapter 287; House adopted Amendments 1 & 2; bill summary","Enacted legislative history","Read. Authenticates enactment chain and Public Chapter status. \nTennessee Capitol"],["S_TN-P2-S004","Tennessee Secretary of State, Archived Rules — https://tnsosorg.tnsosfiles.com/rules/ArchivedRules.php?direction=DESC&sort=FileDate","Entries for 0780-05-18 and 0780-05-19: Rulemaking Hearing Rule, filed 3/17/2026, effective 6/15/2026, sequence 03-16-26; emergency-rule history","Official filing/effective-status index","Official indexed metadata retrieved; direct archive open subsequently returned 403. Used only for filing/effective status, not operative clause text"],["S_TN-P2-S005","TDCI, Jan. 13, 2026 Rulemaking Hearing Redline — https://www.ext.glb.mytn.gov/content/dam/tn/commerce/documents/regboards/debtmanage/meetings/2026/Hearing_1-13.pdf","Proposed Ch.0780-05-19 organization and definitions; proposed Rule 0780-05-18-.14 amendments concerning annual index determination/publication","Proposed/hearing-stage, not final","Search retrieval exposed substantive text. Direct PDF open later timed out/failed, preventing reliable page-image inspection. Not used as final operative authority"],["S_TN-P2-S006","Tennessee SOS historical compiled Chapter 0780-05-18 — https://publications.tnsosfiles.com/rules/0780/0780-05/0780-05-18.20170126.pdf","Rule 0780-05-18-.14: 2014 base year, adjustment threshold/mechanism, new-base-year after adjustment, public listing","Historical rule, effective 2017; subsequently amended","Indexed official text read. Used only to establish historical mechanism, not as October 2026 final wording"],["S_TN-P2-S007","TDCI, How to Get a License — https://www.extglb.tn.gov/commerce/regboards/debt/license/get.html","Existing DMP-license transition instruction: operate until expiry; if debt-resolution criteria apply at expiry, initial DRSP application","Current agency procedure","Read. Useful agency operational treatment; cannot supersede §5820 or establish governing law for post-effective-date contracts"],["S_TN-P2-S008","TDCI, Laws — https://www.tn.gov/commerce/regboards/debt/rules/laws.html","Lists Part 55 correctly but debt resolution as “47-18-48”","Current agency navigation page containing inconsistency","Read/indexed. Not relied on for Part 58 location because S001/S002/S003 directly contradict that entry"],["S_TN-P2-S009","TDCI, Jan. 5, 2026 New Licensing Requirements...Debt Resolution Services Act — https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html","Jan. 1 effective date; providers must obtain license before providing covered services; statement concerning transition and current enforcement expectation","Current official agency interpretation/procedure","Read. Agency guidance, not statutory amendment or adjudication. \nTennessee.gov"],["S_TN-P2-S010","TDCI, current debt news page — https://www.tn.gov/commerce/regboards/debt/news/news.html","Current statement that DRSA took effect Jan. 1, 2026 and persons offering debt-resolution services must first obtain license","Current agency page","Read. Corroborative only. \nTennessee.gov"]]},{"headers":["Claim ID","Precise assertion","Sources / pinpoints","Conditions and confidence limits"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Precise assertion","Sources / pinpoints","Conditions and confidence limits"],["S_TN-P2-C001","TDCI currently identifies Part 55 as the debt-management statute and Part 58 as the debt-resolution statute","P2-S001 Purpose section; P2-S002 §§5801 et seq.; P2-S003 enacted history","High confidence as to current statutory homes; current consolidated code wording itself remains unread"],["S_TN-P2-C002","Part 58’s enacted transition has separate protection for old transactions, old licenses, and non-debt-resolution legacy businesses","P2-S002 §5820(a)–(c), PDF pp.65–66","High confidence in enacted legislative-chain text"],["S_TN-P2-C003","§5820(a) expressly protects transactions entered before Jan. 1, 2026; it does not expressly grandfather new post-Jan. 1 debt-resolution transactions","P2-S002 §5820(a); Section 3","Textual conclusion; final adjudicative interpretation not located"],["S_TN-P2-C004","§5820(c) expressly permits continued Part 55 licensing for businesses offering services other than debt-resolution services","P2-S002 §5820(c)","Does not answer an activity meeting the Part 58 definition"],["S_TN-P2-C005","TDCI says an existing DMP licensee may continue under its current license until expiry, but that instruction does not expressly assign old Part 55 law to every new post-2026 debt-resolution agreement","P2-S007 transition instruction; P2-S009 current licensing notice","Agency procedure/interpretation only; statutory overlap remains unresolved"],["S_TN-P2-C006","Permanent rules for Chapters 0780-05-18 and 0780-05-19 were filed March 17, 2026 and became effective June 15, 2026","P2-S004 official archived-rule entries","Filing/effective metadata authenticated; substantive final rule clauses not authenticated"],["S_TN-P2-C007","The January 2026 hearing/redline cannot be treated as the final June 2026 rule","P2-S005 versus P2-S004","High confidence status distinction"],["S_TN-P2-C008","Historical Rule .14 used 2014 as base year and made an adjustment year the new base year","P2-S006 Rule 0780-05-18-.14(2)–(5)","Historical proposition only; no claim 2014 remains the current base year"],["S_TN-P2-C009","Exact October 2026 adjusted Part 55 consumer dollar amounts remain unverified","P2-S004–S006 and failed current schedule search","High-confidence hold; no CPI computation permissible as substitute"],["S_TN-P2-C010","Computing current fees directly from a 2014 CPI baseline would be unsafe because an intervening statutory adjustment could have reset the base year","P2-S006 Rule .14 historical reset mechanism","Logical consequence of verified historical mechanism; exact current rule remains unread"],["S_TN-P2-C011","TDCI’s “Part 48” reference is inconsistent with current agency, legislative, and rulemaking materials identifying Part 58","P2-S001, S002, S003, S008","Treat as webpage error/inconsistency; do not publish Part 48 as controlling"],["S_TN-P2-C012","No new final-rule text was retrieved that resolves the for-profit custodial-DMP/debt-resolution overlap","P2-S004/S005 plus failed routes","Evidence-gap claim only; not a holding that no such clause exists"],["S_TN-P2-C013","Focused official-source searching did not locate a controlling court or AG interpretation of §5820’s new-contract overlap","Focused Tennessee court/AG searches; P2-S009 was agency material instead","Search-result statement only, not proof no decision/order exists"]]},{"headers":["Original claim","PASS-02 disposition","Precise patch"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Original claim","PASS-02 disposition","Precise patch"],["S_TN-P1-C001 — Part 58 operates Jan. 1, 2026 with Part 55 transition","STRENGTHEN","Current TDCI materials expressly identify Part 58; official House Journal supplies §5820/Section 3; official bill history authenticates PC287 enactment. Signed PC287 PDF remains unread, but the enactment/current-program chain is materially stronger."],["S_TN-P1-C004 — Part 58 consumer-fund custody limitation","NO SUBSTANTIVE CHANGE","No readable final June 2026 regulatory text was obtained that alters or interprets this statutory proposition. Preserve prior enacted-text finding and prior limitation."],["S_TN-P1-C013 — old-license/new-contract and custodial overlap unresolved","NARROW / PARTIAL PATCH","§5820 now establishes three distinct transition buckets. Pre-2026 transactions are clearly grandfathered; old licenses themselves receive protection; non-debt-resolution businesses may continue under Part 55. New post-Jan. 1 Part 58-type transactions under an unexpired legacy Part 55 license remain held."],["S_TN-P1-C016 — ordinary DMP base fees","STATUS PATCH ONLY","TDCI confirms Part 55 remains a current statutory program. No current adjusted dollar schedule was authenticated, so PASS-01’s “unadjusted bases only” limitation remains."],["S_TN-P1-C017 — education fee limits","STATUS PATCH ONLY","Same: current Part 55 program authenticated, current indexed amount still held."],["S_TN-P1-C018 — 90-day education-fee refund","NO SUBSTANTIVE CHANGE","Enacted 2014 substance remains supported; exact current codifier paragraph numbering was not independently authenticated in a readable consolidated Part 55."],["S_TN-P1-C019 — CPI mechanism / exact adjusted amount held","MATERIALLY STRENGTHEN","Permanent 2026 rule package’s filing/effective status is now authenticated. Historical rule confirms 2014 base and reset-on-adjustment mechanism; January 2026 proposed text shows continued indexing/publication design. Exact current base year and adjusted amounts remain unverified."],["S_TN-P1-C033 — federal TSR advance fees","UNCHANGED / OUTSIDE PASS-02","Federal baseline intentionally not rerun."],["S_TN-P1-C039 — current rules/code not retrieved","PARTIAL PATCH","Final rule existence, filing date, sequence, and effective date are now authenticated. The final operative clauses and complete current consolidated Part 55/58 statutory text remain unread through the available routes."],["S_TN-P1-C040 — no controlling interpretation retrieved","NARROWLY RECONFIRMED","No controlling court or AG interpretation was found in this focused transition/overlap search. TDCI guidance was found but is agency procedural/interpretive material, not a court holding or final adjudicative order."]]},{"headers":["Route","Actual result in PASS-02","Consequence"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Route","Actual result in PASS-02","Consequence"],["TDCI debt-management rules page https://www.tn.gov/commerce/regboards/debt/rules/debt-management-rules.html","403","Did not expose current operative Chapter 0780-05-18 text"],["TDCI debt-resolution rules page https://www.tn.gov/commerce/regboards/debt/rules/debt-resolution-rules.html","403","Did not expose current operative Chapter 0780-05-19 text"],["TDCI Jan. 13 hearing PDF at P2-S005","Search retrieval exposed indexed text; direct open later timed out/failed and could not be reliably rendered as a PDF for page inspection","Used solely as proposed/hearing-stage evidence, not final authority"],["SOS Archived Rules HTML direct opening","403 after official metadata had been returned through indexed retrieval","Metadata supports filing status; no operative text inferred"],["Final SOS PDFs 0780-05-18.20260615.pdf, 0780-05-19.20260615.pdf, and 03-16-26.pdf","Prior PASS-01 routes repeatedly returned 403","Deliberately not repeatedly retried; remain operative-text dependency"],["May 2026 Joint Government Operations rule packet","Prior attempt exceeded ordinary reader capacity","Not repeated; effective-status issue was instead addressed through a materially different official SOS route"],["Official current Lexis Tennessee Code route","PASS-01 yielded shell/no operative statutory text","Not represented as current-code reading here"]]},{"headers":["Remaining question","Current status","Exact missing authority","Next evidence action, within current constraints"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Remaining question","Current status","Exact missing authority","Next evidence action, within current constraints"],["Exact final wording of Rule 0780-05-18-.14 after June 15, 2026","Unresolved","Readable final 03-16-26 filing or current compiled Chapter 18","Retrieve only if an official public HTML/text/mirror becomes readable; do not infer from hearing redline"],["Exact current CPI base year","Unresolved","Administrator’s current published base year or final operative .14 plus intervening adjustment history","Locate official TDCI/SOS public schedule; do not calculate from 2014"],["Exact current adjusted §5523 amounts","Unresolved","Current administrator-published adjusted fee table/notice","Hold every exact adjusted amount until official schedule is readable"],["Whether any adjustment occurred between 2014 and Oct. 2026","Unresolved","Official notices/fee adjustment history","Search specifically for administrator adjustment notices rather than general CPI data"],["Exact final Chapter 0780-05-19 standards affecting custody/overlap","Unresolved","Current final Part 19 operative clauses","Read public final filing/compiled rule if accessible later"],["New post-Jan. 1, 2026 debt-resolution contract under legacy Part 55 license","Partially resolved but held","Formal rule, agency adjudication, court decision, or authoritative interpretation reconciling §5820(a)/(b), Section 3, and TDCI transition guidance","Target this exact issue; do not generalize “operate until expiry” into fee/licensing permission"],["Complete current consolidated Part 55 text","Partially authenticated only","Readable official current code sections, especially §§5502, 5523, 5532/adjustment-related provisions","Retrieve current official code text when public reader returns substantive content"],["Complete current consolidated Part 58 text","Substantially authenticated through enactment chain, not consolidated-code read","Official current consolidated §§5801–5820","Retrieve readable official code; compare against PC287 chain and any later amendments"],["Controlling judicial/AG interpretation","Not located","Any actual opinion/order interpreting transition or overlap","Search specific section/case language in a later pass if needed; absence here is not negative authority"]]},{"headers":["Assigned item","Result"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Assigned item","Result"],["Authenticate current Part 55 statutory existence/location","Answered — TDCI currently identifies Part 55"],["Authenticate current Part 58 statutory existence/location","Answered — current TDCI page + official enactment chain identify Part 58"],["Authenticate Part 58 enactment/transition beyond HA0187 alone","Answered materially — official House Journal adoption plus official bill history/Public Chapter chain"],["Read signed PC287 itself","Unresolved — prior official PDF inaccessible"],["Authenticate permanent 2026 rule legal status","Answered — filed 3/17/26, effective 6/15/26, sequence 03-16-26"],["Authenticate every final 2026 rule clause","Unresolved — operative final PDFs remain inaccessible"],["Determine whether January hearing redline is current law","Answered: no — hearing/proposed material cannot substitute for final filing"],["Resolve legacy Part 55 pre-2026 transactions","Answered — express §5820(a) protection"],["Resolve continued non-debt-resolution Part 55 businesses","Answered — express §5820(c) protection"],["Resolve new post-2026 debt-resolution contracts by old Part 55 licensee","Partial/held"],["Resolve custodial-DMP/Part 58 overlap through final rules","Unresolved"],["Authenticate historic inflation base mechanism","Answered historically"],["Authenticate current base year","Unresolved"],["Authenticate October 2026 adjusted consumer dollar limits","Unresolved"],["Produce new fee examples","Not warranted — no new verified current dollar authority"],["Revisit TSR","Excluded by assignment"],["Other Tennessee agreement/funds/bond/remedy/litigation/etc. categories","Remain open; no implication of completion"],["Full Tennessee / A066 acceptance","Not addressed and remains open"]]}],"claims":[{"claim_id":"S_TN-P2-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C001","Precise assertion":"TDCI currently identifies Part 55 as the debt-management statute and Part 58 as the debt-resolution statute","Sources / pinpoints":"P2-S001 Purpose section; P2-S002 §§5801 et seq.; P2-S003 enacted history","Conditions and confidence limits":"High confidence as to current statutory homes; current consolidated code wording itself remains unread"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C002","Precise assertion":"Part 58’s enacted transition has separate protection for old transactions, old licenses, and non-debt-resolution legacy businesses","Sources / pinpoints":"P2-S002 §5820(a)–(c), PDF pp.65–66","Conditions and confidence limits":"High confidence in enacted legislative-chain text"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C003","Precise assertion":"§5820(a) expressly protects transactions entered before Jan. 1, 2026; it does not expressly grandfather new post-Jan. 1 debt-resolution transactions","Sources / pinpoints":"P2-S002 §5820(a); Section 3","Conditions and confidence limits":"Textual conclusion; final adjudicative interpretation not located"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C004","Precise assertion":"§5820(c) expressly permits continued Part 55 licensing for businesses offering services other than debt-resolution services","Sources / pinpoints":"P2-S002 §5820(c)","Conditions and confidence limits":"Does not answer an activity meeting the Part 58 definition"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C005","Precise assertion":"TDCI says an existing DMP licensee may continue under its current license until expiry, but that instruction does not expressly assign old Part 55 law to every new post-2026 debt-resolution agreement","Sources / pinpoints":"P2-S007 transition instruction; P2-S009 current licensing notice","Conditions and confidence limits":"Agency procedure/interpretation only; statutory overlap remains unresolved"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C006","Precise assertion":"Permanent rules for Chapters 0780-05-18 and 0780-05-19 were filed March 17, 2026 and became effective June 15, 2026","Sources / pinpoints":"P2-S004 official archived-rule entries","Conditions and confidence limits":"Filing/effective metadata authenticated; substantive final rule clauses not authenticated"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C007","Precise assertion":"The January 2026 hearing/redline cannot be treated as the final June 2026 rule","Sources / pinpoints":"P2-S005 versus P2-S004","Conditions and confidence limits":"High confidence status distinction"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C008","Precise assertion":"Historical Rule .14 used 2014 as base year and made an adjustment year the new base year","Sources / pinpoints":"P2-S006 Rule 0780-05-18-.14(2)–(5)","Conditions and confidence limits":"Historical proposition only; no claim 2014 remains the current base year"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C009","Precise assertion":"Exact October 2026 adjusted Part 55 consumer dollar amounts remain unverified","Sources / pinpoints":"P2-S004–S006 and failed current schedule search","Conditions and confidence limits":"High-confidence hold; no CPI computation permissible as substitute"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C010","Precise assertion":"Computing current fees directly from a 2014 CPI baseline would be unsafe because an intervening statutory adjustment could have reset the base year","Sources / pinpoints":"P2-S006 Rule .14 historical reset mechanism","Conditions and confidence limits":"Logical consequence of verified historical mechanism; exact current rule remains unread"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C011","Precise assertion":"TDCI’s “Part 48” reference is inconsistent with current agency, legislative, and rulemaking materials identifying Part 58","Sources / pinpoints":"P2-S001, S002, S003, S008","Conditions and confidence limits":"Treat as webpage error/inconsistency; do not publish Part 48 as controlling"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C012","Precise assertion":"No new final-rule text was retrieved that resolves the for-profit custodial-DMP/debt-resolution overlap","Sources / pinpoints":"P2-S004/S005 plus failed routes","Conditions and confidence limits":"Evidence-gap claim only; not a holding that no such clause exists"},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"S_TN-P2-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_TN-P2-C013","Precise assertion":"Focused official-source searching did not locate a controlling court or AG interpretation of §5820’s new-contract overlap","Sources / pinpoints":"Focused Tennessee court/AG searches; P2-S009 was agency material instead","Conditions and confidence limits":"Search-result statement only, not proof no decision/order exists"},"coordinator_verification_status":"not_yet_checked"}],"sources":[{"source_id":"S_TN-P2-S001","urls":["https://www.tn.gov/commerce/regboards/debt.html","https://www.tn.gov/commerce/regboards/debt.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_TN-P2-S001","Source / issuer / direct literal URL":"TDCI, Debt Management, Debt Resolution, and Credit Services — https://www.tn.gov/commerce/regboards/debt.html","Exact material used":"Purpose section: current registration requirements in TCA Title 47, Ch.18, Part 55 and Part 58","Status on 2026-10-24":"Current agency webpage","Actual access and limitation":"Read. Authenticates TDCI’s current statutory program locations; does not substitute for consolidated code text. \nTennessee.gov"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_TN-P2-S002","urls":["https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf","https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_TN-P2-S002","Source / issuer / direct literal URL":"Tennessee House Journal, March 31, 2025 — https://capitol.tn.gov/bills/114/House/Journals/03312025RD20.pdf","Exact material used":"Amendment No.1 adding §§47-18-5801 et seq.; PDF pp.65–66 for §5820 transition and Section 3; adoption/passages immediately following","Status on 2026-10-24":"Official legislative journal / adopted House text","Actual access and limitation":"Text read and relevant PDF page screenshot inspected. This is stronger than relying on HA0187 alone, but remains part of the enactment chain rather than the unread signed chapter. \nTennessee General Assembly"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_TN-P2-S003","urls":["https://wapp.capitol.tn.gov/apps/BillInfo/Default?BillNumber=SB1078&ga=114","https://wapp.capitol.tn.gov/apps/BillInfo/Default?BillNumber=SB1078&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_TN-P2-S003","Source / issuer / direct literal URL":"Tennessee General Assembly, SB1078/HB0743 bill information — https://wapp.capitol.tn.gov/apps/BillInfo/Default?BillNumber=SB1078&ga=114","Exact material used":"Enacted status; companion became Public Chapter 287; House adopted Amendments 1 & 2; bill summary","Status on 2026-10-24":"Enacted legislative history","Actual access and limitation":"Read. Authenticates enactment chain and Public Chapter status. \nTennessee Capitol"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_TN-P2-S004","urls":["https://tnsosorg.tnsosfiles.com/rules/ArchivedRules.php?direction=DESC&sort=FileDate"],"researcher_record":{"Source ID":"S_TN-P2-S004","Source / issuer / direct literal URL":"Tennessee Secretary of State, Archived Rules — https://tnsosorg.tnsosfiles.com/rules/ArchivedRules.php?direction=DESC&sort=FileDate","Exact material used":"Entries for 0780-05-18 and 0780-05-19: Rulemaking Hearing Rule, filed 3/17/2026, effective 6/15/2026, sequence 03-16-26; emergency-rule history","Status on 2026-10-24":"Official filing/effective-status index","Actual access and limitation":"Official indexed metadata retrieved; direct archive open subsequently returned 403. Used only for filing/effective status, not operative clause text"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_TN-P2-S005","urls":["https://www.ext.glb.mytn.gov/content/dam/tn/commerce/documents/regboards/debtmanage/meetings/2026/Hearing_1-13.pdf"],"researcher_record":{"Source ID":"S_TN-P2-S005","Source / issuer / direct literal URL":"TDCI, Jan. 13, 2026 Rulemaking Hearing Redline — https://www.ext.glb.mytn.gov/content/dam/tn/commerce/documents/regboards/debtmanage/meetings/2026/Hearing_1-13.pdf","Exact material used":"Proposed Ch.0780-05-19 organization and definitions; proposed Rule 0780-05-18-.14 amendments concerning annual index determination/publication","Status on 2026-10-24":"Proposed/hearing-stage, not final","Actual access and limitation":"Search retrieval exposed substantive text. Direct PDF open later timed out/failed, preventing reliable page-image inspection. Not used as final operative authority"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_TN-P2-S006","urls":["https://publications.tnsosfiles.com/rules/0780/0780-05/0780-05-18.20170126.pdf"],"researcher_record":{"Source ID":"S_TN-P2-S006","Source / issuer / direct literal URL":"Tennessee SOS historical compiled Chapter 0780-05-18 — https://publications.tnsosfiles.com/rules/0780/0780-05/0780-05-18.20170126.pdf","Exact material used":"Rule 0780-05-18-.14: 2014 base year, adjustment threshold/mechanism, new-base-year after adjustment, public listing","Status on 2026-10-24":"Historical rule, effective 2017; subsequently amended","Actual access and limitation":"Indexed official text read. Used only to establish historical mechanism, not as October 2026 final wording"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_TN-P2-S007","urls":["https://www.extglb.tn.gov/commerce/regboards/debt/license/get.html"],"researcher_record":{"Source ID":"S_TN-P2-S007","Source / issuer / direct literal URL":"TDCI, How to Get a License — https://www.extglb.tn.gov/commerce/regboards/debt/license/get.html","Exact material used":"Existing DMP-license transition instruction: operate until expiry; if debt-resolution criteria apply at expiry, initial DRSP application","Status on 2026-10-24":"Current agency procedure","Actual access and limitation":"Read. Useful agency operational treatment; cannot supersede §5820 or establish governing law for post-effective-date contracts"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_TN-P2-S008","urls":["https://www.tn.gov/commerce/regboards/debt/rules/laws.html"],"researcher_record":{"Source ID":"S_TN-P2-S008","Source / issuer / direct literal URL":"TDCI, Laws — https://www.tn.gov/commerce/regboards/debt/rules/laws.html","Exact material used":"Lists Part 55 correctly but debt resolution as “47-18-48”","Status on 2026-10-24":"Current agency navigation page containing inconsistency","Actual access and limitation":"Read/indexed. Not relied on for Part 58 location because S001/S002/S003 directly contradict that entry"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_TN-P2-S009","urls":["https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html","https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_TN-P2-S009","Source / issuer / direct literal URL":"TDCI, Jan. 5, 2026 New Licensing Requirements...Debt Resolution Services Act — https://www.tn.gov/commerce/news/2026/1/5/new-licensing-requirements-consumer-protections-for-tn-consumers-through-debt-resolution-services-act.html","Exact material used":"Jan. 1 effective date; providers must obtain license before providing covered services; statement concerning transition and current enforcement expectation","Status on 2026-10-24":"Current official agency interpretation/procedure","Actual access and limitation":"Read. Agency guidance, not statutory amendment or adjudication. \nTennessee.gov"},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_TN-P2-S010","urls":["https://www.tn.gov/commerce/regboards/debt/news/news.html","https://www.tn.gov/commerce/regboards/debt/news/news.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_TN-P2-S010","Source / issuer / direct literal URL":"TDCI, current debt news page — https://www.tn.gov/commerce/regboards/debt/news/news.html","Exact material used":"Current statement that DRSA took effect Jan. 1, 2026 and persons offering debt-resolution services must first obtain license","Status on 2026-10-24":"Current agency page","Actual access and limitation":"Read. Corroborative only. \nTennessee.gov"},"coordinator_verification_status":"not_yet_checked"}],"coverage":[{"topic":"Exact final wording of Rule 0780-05-18-.14 after June 15, 2026","researcher_record":{"Remaining question":"Exact final wording of Rule 0780-05-18-.14 after June 15, 2026","Current status":"Unresolved","Exact missing authority":"Readable final 03-16-26 filing or current compiled Chapter 18","Next evidence action, within current constraints":"Retrieve only if an official public HTML/text/mirror becomes readable; do not infer from hearing redline"},"table_index":5,"coverage_kind":"remaining_dependency","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Exact current CPI base year","researcher_record":{"Remaining question":"Exact current CPI base year","Current status":"Unresolved","Exact missing authority":"Administrator’s current published base year or final operative .14 plus intervening adjustment history","Next evidence action, within current constraints":"Locate official TDCI/SOS public schedule; do not calculate from 2014"},"table_index":5,"coverage_kind":"remaining_dependency","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Exact current adjusted §5523 amounts","researcher_record":{"Remaining question":"Exact current adjusted §5523 amounts","Current status":"Unresolved","Exact missing authority":"Current administrator-published adjusted fee table/notice","Next evidence action, within current constraints":"Hold every exact adjusted amount until official schedule is readable"},"table_index":5,"coverage_kind":"remaining_dependency","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Whether any adjustment occurred between 2014 and Oct. 2026","researcher_record":{"Remaining question":"Whether any adjustment occurred between 2014 and Oct. 2026","Current status":"Unresolved","Exact missing authority":"Official notices/fee adjustment history","Next evidence action, within current constraints":"Search specifically for administrator adjustment notices rather than general CPI data"},"table_index":5,"coverage_kind":"remaining_dependency","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Exact final Chapter 0780-05-19 standards affecting custody/overlap","researcher_record":{"Remaining question":"Exact final Chapter 0780-05-19 standards affecting custody/overlap","Current status":"Unresolved","Exact missing authority":"Current final Part 19 operative clauses","Next evidence action, within current constraints":"Read public final filing/compiled rule if accessible later"},"table_index":5,"coverage_kind":"remaining_dependency","coordinator_acceptance":"not_yet_reviewed"},{"topic":"New post-Jan. 1, 2026 debt-resolution contract under legacy Part 55 license","researcher_record":{"Remaining question":"New post-Jan. 1, 2026 debt-resolution contract under legacy Part 55 license","Current status":"Partially resolved but held","Exact missing authority":"Formal rule, agency adjudication, court decision, or authoritative interpretation reconciling §5820(a)/(b), Section 3, and TDCI transition guidance","Next evidence action, within current constraints":"Target this exact issue; do not generalize “operate until expiry” into fee/licensing permission"},"table_index":5,"coverage_kind":"remaining_dependency","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Complete current consolidated Part 55 text","researcher_record":{"Remaining question":"Complete current consolidated Part 55 text","Current status":"Partially authenticated only","Exact missing authority":"Readable official current code sections, especially §§5502, 5523, 5532/adjustment-related provisions","Next evidence action, within current constraints":"Retrieve current official code text when public reader returns substantive content"},"table_index":5,"coverage_kind":"remaining_dependency","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Complete current consolidated Part 58 text","researcher_record":{"Remaining question":"Complete current consolidated Part 58 text","Current status":"Substantially authenticated through enactment chain, not consolidated-code read","Exact missing authority":"Official current consolidated §§5801–5820","Next evidence action, within current constraints":"Retrieve readable official code; compare against PC287 chain and any later amendments"},"table_index":5,"coverage_kind":"remaining_dependency","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Controlling judicial/AG interpretation","researcher_record":{"Remaining question":"Controlling judicial/AG interpretation","Current status":"Not located","Exact missing authority":"Any actual opinion/order interpreting transition or overlap","Next evidence action, within current constraints":"Search specific section/case language in a later pass if needed; absence here is not negative authority"},"table_index":5,"coverage_kind":"remaining_dependency","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Authenticate current Part 55 statutory existence/location","researcher_record":{"Assigned item":"Authenticate current Part 55 statutory existence/location","Result":"Answered — TDCI currently identifies Part 55"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Authenticate current Part 58 statutory existence/location","researcher_record":{"Assigned item":"Authenticate current Part 58 statutory existence/location","Result":"Answered — current TDCI page + official enactment chain identify Part 58"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Authenticate Part 58 enactment/transition beyond HA0187 alone","researcher_record":{"Assigned item":"Authenticate Part 58 enactment/transition beyond HA0187 alone","Result":"Answered materially — official House Journal adoption plus official bill history/Public Chapter chain"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Read signed PC287 itself","researcher_record":{"Assigned item":"Read signed PC287 itself","Result":"Unresolved — prior official PDF inaccessible"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Authenticate permanent 2026 rule legal status","researcher_record":{"Assigned item":"Authenticate permanent 2026 rule legal status","Result":"Answered — filed 3/17/26, effective 6/15/26, sequence 03-16-26"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Authenticate every final 2026 rule clause","researcher_record":{"Assigned item":"Authenticate every final 2026 rule clause","Result":"Unresolved — operative final PDFs remain inaccessible"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Determine whether January hearing redline is current law","researcher_record":{"Assigned item":"Determine whether January hearing redline is current law","Result":"Answered: no — hearing/proposed material cannot substitute for final filing"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Resolve legacy Part 55 pre-2026 transactions","researcher_record":{"Assigned item":"Resolve legacy Part 55 pre-2026 transactions","Result":"Answered — express §5820(a) protection"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Resolve continued non-debt-resolution Part 55 businesses","researcher_record":{"Assigned item":"Resolve continued non-debt-resolution Part 55 businesses","Result":"Answered — express §5820(c) protection"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Resolve new post-2026 debt-resolution contracts by old Part 55 licensee","researcher_record":{"Assigned item":"Resolve new post-2026 debt-resolution contracts by old Part 55 licensee","Result":"Partial/held"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Resolve custodial-DMP/Part 58 overlap through final rules","researcher_record":{"Assigned item":"Resolve custodial-DMP/Part 58 overlap through final rules","Result":"Unresolved"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Authenticate historic inflation base mechanism","researcher_record":{"Assigned item":"Authenticate historic inflation base mechanism","Result":"Answered historically"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Authenticate current base year","researcher_record":{"Assigned item":"Authenticate current base year","Result":"Unresolved"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Authenticate October 2026 adjusted consumer dollar limits","researcher_record":{"Assigned item":"Authenticate October 2026 adjusted consumer dollar limits","Result":"Unresolved"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Produce new fee examples","researcher_record":{"Assigned item":"Produce new fee examples","Result":"Not warranted — no new verified current dollar authority"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Revisit TSR","researcher_record":{"Assigned item":"Revisit TSR","Result":"Excluded by assignment"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Other Tennessee agreement/funds/bond/remedy/litigation/etc. categories","researcher_record":{"Assigned item":"Other Tennessee agreement/funds/bond/remedy/litigation/etc. categories","Result":"Remain open; no implication of completion"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"},{"topic":"Full Tennessee / A066 acceptance","researcher_record":{"Assigned item":"Full Tennessee / A066 acceptance","Result":"Not addressed and remains open"},"table_index":6,"coverage_kind":"assigned_scope","coordinator_acceptance":"not_yet_reviewed"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}