PubLedge

Definitions

This document specifies the controlled vocabulary PubLedge uses for instrument status, alongside clarifying definitions for the terms of art that appear in the registry.

Scope

PubLedge tracks fact-specific written interpretations between two parties: Joint Interpretation Agreements (JIAs), Regulatory Mitigation Agreements (RMAs), SEC no-action letters, CFPB advisory opinions, IRS private letter rulings, CFTC interpretive letters, and analogous instruments. Statutes are tracked as first-class records where an interpretation is anchored to them, so that the statute-to-instrument relationship can be queried directly.

Terminology choices below reflect three concerns:

1. Precision: each term is a distinct legal term of art, not a synonym for its neighbors. 2. Interoperability: where the same concept appears in EveryAILaw, the vocabulary is identical so cross-registry joins work. 3. Disclosure: PubLedge itself is a reference project under development. The registry's status field describes the instrument's legal state, not the registry's editorial state. See the site-wide disclaimer banner.

Status vocabulary

The status: frontmatter field on every instrument record takes one of the following values.

Lifecycle transitions

proposed → enacted → enforcing → { expired, superseded, withdrawn, terminated }
                              ↘ pending-replacement → superseded
                              ↘ phased-enforcement → enforcing (per phase)

Values

StatusDefinitionAuthoritative source
proposedInstrument has been drafted but has not been executed, adopted, or issued. Applies to instruments PubLedge suggests as prior art, to unratified agreements, and to bills that have been introduced but not enacted.EveryAILaw convention
enactedInstrument has been signed, executed, or otherwise formally adopted by its issuing authority or parties, but is not yet in force. Used when a stated effective date, phase-in date, or commencement trigger has not been reached.EveryAILaw convention
enforcingInstrument is in force and its terms are operative. For statutes: enforceable by the relevant authority. For agreements: the term is active and the parties are bound. For agency instruments (no-action letters, advisory opinions, private letter rulings): the position remains the published view of the issuing office.EveryAILaw convention
phased-enforcementInstrument is in force but specific provisions take effect on rolling dates. Used when a single record covers multiple obligations that phase in over time.EveryAILaw convention
pending-replacementInstrument is known to be replaced by a forthcoming instrument covering the same subject matter. Forward-looking flag; once the replacement is executed, transition to superseded.EveryAILaw convention
expiredInstrument's stated term has ended and no extension or replacement was executed. Natural discharge by the passage of time; no party action required. Distinguish from terminated (action by a party) and superseded (replaced by a newer instrument). Legal basis: Restatement (Second) of Contracts §235, discharge by expiration.PubLedge addition
supersededInstrument has been replaced by a newer instrument on the same subject matter. The record should also populate the superseded_by: field with the canonical identifier of the replacing instrument.PubLedge addition
withdrawnInstrument has been rescinded unilaterally by the issuing authority before its stated term ended. Applies to agency instruments (advisory opinions, no-action letters, interpretive letters) where the agency pulls back the position. Does not apply to statutes (which are "repealed") or to two-party agreements (which are "terminated").PubLedge addition
terminatedBilateral or multilateral instrument has been ended early by action — party notice, mutual consent, or material breach. Distinguish from expired (natural term end) and withdrawn (unilateral issuer action on a one-sided instrument).PubLedge addition

Color and semantic intent

The site renders status as a badge colored by semantic group:

Instrument types

The type: frontmatter field identifies the genre of instrument. The URL segment is derived from this value via project.yml > hierarchy.type_segments.

TypeURL segmentDefinition
rmarmaRegulatory Mitigation Agreement. A written agreement between a regulator and a participating entity that waives specified statutory or regulatory provisions for a stated term, in exchange for scope limits, safeguards, and reporting. Utah OAIP is the primary US issuer (Utah Code §13-72-401).
jiajiaJoint Interpretation Agreement. A written agreement between a regulator and a requesting party that clarifies how existing law applies to a specific fact pattern, without waiving the underlying law. Utah OAIP is authorized to issue JIAs under §13-72-401 (HB 320, 2026).
no-action-letternalA letter from SEC staff (typically the Division of Corporation Finance or Trading and Markets) stating that staff would not recommend enforcement action if the requester proceeds with a specified transaction. Binds staff, not the Commission; reliance typically limited to the requesting party or similarly-situated third parties.
advisory-opinionaoA formal statement by a regulatory agency (CFPB, FTC, HHS OIG) interpreting an ambiguous regulation as applied to specified facts. Public; binds the agency's enforcement posture; subsequent amendment or withdrawal is disclosed.
interpretive-letterilAn explanatory letter issued by agency staff (CFTC DSIO, OCC, FRB) addressing a specific factual scenario. Similar in function to a no-action letter but framed as an interpretation rather than non-enforcement.
private-letter-rulingplrAn IRS written determination issued to a specific taxpayer addressing their specific transaction. Relied upon only by the requesting taxpayer; publicly released with identifying information redacted.
statutestatuteA law enacted by a legislature, tracked as a first-class record in PubLedge when one or more registered instruments interpret or waive it. The statute type holds anchoring metadata; authoritative full text lives at the issuing body (for example, le.utah.gov) and at EveryAILaw.

Reliance scope

The reliance_scope: field describes who may rely on the instrument.

ValueMeaning
publicAnyone may rely on the instrument's stated interpretation — statutes, advisory opinions, rules of general applicability.
requesting-party-onlyOnly the entity that requested the instrument may rely on it (IRS PLRs, most RMAs and JIAs).
similarly-situated-third-partiesThe requesting party plus third parties who share the material facts. Typical for SEC no-action letters and some CFTC letters.

Identifier scheme

Every instrument carries two identifiers:

The record.json endpoint emits all identifiers alongside the full record payload and a Schema.org LegalDocument JSON-LD block.

Terms-of-art distinctions worth preserving

expired vs terminated vs withdrawn vs superseded

These four terms describe mutually exclusive modes of an instrument ceasing to be in force. Collapsing them loses legal precision.

enacted vs enforcing

This distinction matters for RMAs that are signed but held in abeyance pending a participant notice (Utah §13-72-401(2.B)-style commencement triggers), and for statutes with stated effective dates that postdate the signing.

advisory opinion vs no-action letter vs interpretive letter

The three instruments share a function (written agency position on a specific fact pattern) but differ in their legal posture:

PubLedge preserves the distinction in both the type: field and the URL type segment.

Authority response positions

The position value in an authority_response entry (see PROTOCOL.md → Authority response) is one of a closed set. It records how the responding authority characterizes its own relationship to the interpretation, not PubLedge's editorial judgment.

ValueMeaning
concursThe authority agrees the interpretation reflects its position.
disputesThe authority states the interpretation is wrong or misleading.
clarifiesThe authority neither fully agrees nor disputes; it adds or corrects detail.
declines-to-commentThe authority acknowledges the record but takes no position.
superseded-by-officialThe authority has since issued an official instrument that governs instead; pair with supersedes / superseded_by per Supersession.

declines-to-comment is a recorded response, not the same as the absence of any response. Absence is never interpreted (PROTOCOL.md → Authority response, non-goals).

Versioning and changes to this document

This document is canonical for the PubLedge project. Changes require a pull request to the GitHub repository and are published with the next site build.

Cross-project vocabulary alignment: proposed, enacted, enforcing, phased-enforcement, and pending-replacement track EveryAILaw's convention verbatim. Additions (expired, superseded, withdrawn, terminated) are PubLedge-specific because they describe dispositions that rarely apply to statutes but are routine for fact-specific instruments.

Disclaimer

PubLedge is a reference tool under development. This registry is not authoritative and does not constitute legal advice. Each record's status: field describes the underlying instrument's legal state based on public sources as of its last_verified: date. The registry's own editorial and review state is disclosed separately in the site-wide banner and in the project's README. For authoritative text, consult the issuing authority or the links in each record's official_url: and publication_citations: fields.