Tennessee Aqua Finance Settlement: $1.86M and Lien Removals

Tennessee's $1.86 Million Aqua Finance Settlement: Debt Cancellation, Credit Deletions and Lien Removals

Tennessee Attorney General Jonathan Skrmetti announced on October 8, 2026 that Aqua Finance, Inc. will pay $1,864,319.86 over financing for water treatment systems sold to Tennessee consumers. The relief is unusually mechanical: debt cancellation, refunds, credit report deletions, and the removal of UCC fixture filings from property records.

Information last verified on October 11, 2026. Every figure, deadline and injunctive term below comes from the Tennessee Attorney General's October 8, 2026 press release PR26-44, from the Federal Trade Commission's stipulated order in its own Aqua Finance case, or from the FTC's own later announcements, each of which we opened and read on October 11, 2026.

Jurisdiction scope: This article covers the Tennessee Attorney General's October 8, 2026 settlement with Aqua Finance, Inc., and the separate federal order the Federal Trade Commission obtained against the same company in the Western District of Wisconsin in 2024. It also explains federal consumer credit and credit reporting statutes that apply nationwide. It does not cover any other state's separate action against this company, and it does not assess any individual account, debt or credit file.

What Happened

The Tennessee Attorney General's office published press release PR26-44 at 2:10 p.m. on Thursday, October 8, 2026. It announced that Aqua Finance, Inc. "will pay $1,864,319.86 to resolve allegations that the company engaged in unfair and deceptive practices involving financing for water treatment systems sold to Tennessee consumers."

The split matters more than the headline number. Of the total, $1,564,319.86 goes to consumers "through debt cancellation and refunds." The remaining $300,000 is a payment to the State of Tennessee. Attorney General Skrmetti said in the release that "Aqua Finance's deceptive financing scheme hurt Tennesseans, leaving them with burdensome financial surprises," adding that "companies that operate in Tennessee must deal honestly with consumers, or they will be held accountable by my consumer protection team."

What the State alleged

The release describes the conduct as originating with the sellers rather than with the finance company's own sales force. According to the Attorney General, "the State alleged that dealers made serious misrepresentations about water treatment systems and the terms of financing offered through Aqua Finance." The release then identifies the structural problem that made those misrepresentations hard for consumers to unwind: "Some dealers later went out of business, leaving consumers with limited recourse but stuck with their financing obligations."

That is the shape of the harm. A homeowner bought equipment from a dealer, financed it through a third party, and was later left with a financing obligation and no counterparty to complain to about the sales pitch. Readers who want background on how this sales channel generally works will find it in our explainer on home repair and contractor sales practices.

The conduct bans

The settlement, as the Attorney General describes it, "permanently bars Aqua Finance from misrepresenting key terms of credit agreements, including interest rates, minimum monthly payments, payment schedules, and the total cost of credit." Three of those four items are the ones that go wrong in a deferred-interest or introductory-rate pitch, where the number a buyer remembers is the teaser payment rather than the contract rate.

The release lists four further affirmative obligations. Aqua Finance "must also provide enhanced disclosures of important financing terms." It must "ensure its dealers have accurate financing information." It must "prohibit current and future dealers from misrepresenting financing terms and conditions." And it must "establish procedures for appropriately handling complaints involving dealers," which is the obligation aimed squarely at the dealer-went-out-of-business problem.

The three mechanical remedies, and the clocks on them

This is the part of the settlement most worth understanding, because it does things most readers do not know a state consumer protection order can do.

First, notice. Covered consumers "will receive direct notice from Aqua Finance, by mail and email (if available), within 15 business days of the settlement order." Nobody has to find this news story to be told.

Then, within 30 business days of the settlement order, the release says Aqua Finance must do three things:

• "Issue refunds to eligible consumers who made payments after November 30, 2024";
• "Request that credit reporting agencies delete covered debts from affected consumers' credit reports"; and
• "Remove any Uniform Commercial Code fixture filings from property records related to the water treatment systems."

Note what those deadlines are measured from. Both the 15-business-day and the 30-business-day clocks run from the settlement order, not from the October 8, 2026 announcement, and the Attorney General's release does not state the date of the order. So there is no calendar date to put on these obligations from the public record as it stood on October 11, 2026, and this article does not convert them into one.

The release also does not name a court, a case number or a judge, and it refers to the instrument only as a "settlement order." We therefore describe the obligations as what the settlement requires and what the Attorney General announced, rather than asserting that any court has entered a judgment in Tennessee.

The reason Tennessee acted at all

The release closes by placing itself against a federal backdrop: "The Tennessee settlement follows a May 2024 resolution between Aqua Finance and the Federal Trade Commission that provided $43.6 million in financial relief for consumers nationwide. Tennessee pursued its separate settlement to secure relief specifically for Tennesseans and to preserve independent authority to enforce the injunctive protections."

Two distinct reasons are stated there, and they are worth separating. One is money targeted at a particular state's residents. The other is standing: an injunction enforceable by the Tennessee Attorney General can be enforced by the Tennessee Attorney General, on Tennessee's timetable, without waiting on a federal agency's enforcement priorities.

The 2024 FTC Order Behind the Tennessee Settlement

The federal action is the reason the Tennessee remedies look the way they do, so it is worth reading closely.

The FTC filed a complaint and a stipulated order for permanent injunction, monetary judgment, and other relief in the U.S. District Court for the Western District of Wisconsin. The document the Commission publishes is the order as filed with the complaint on May 1, 2024, docketed as Document #: 1-1 under Case: 3:24-cv-00288. Because it is the stipulated version submitted for the court's signature, the case number is blank in its caption and the signature block is undated, leaving the day and month blank above the line for a United States District Judge and the year as "202__." We do not quote a case number from the caption for that reason. That the order took effect is established instead by the Commission's own subsequent announcement, on February 19, 2025, that it was sending more than $19.8 million in refunds by check to 29,653 affected consumers, with recipients advised to cash their checks within 90 days as indicated on the check.

What the complaint charged

The order's findings section states the charges precisely. Paragraph 2 records that "the Complaint charges that Defendant participates in deceptive and unfair acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45, in connection with the promotion, offering for sale, or sale of water treatment systems."

Paragraph 3 adds two more theories. It records that the complaint "also charges that Defendant, in the offering or extension of credit to consumers for purchase of Dealers' products or services, fails to properly disclose the terms of the credit in violation of the Truth in Lending Acting ('TILA'), 15 U.S.C. §§ 1631 and 1638, and its implementing Regulation Z, 12 C.F.R. §§ 1026.17 and 1026.18, and that Defendant is violating the Fair Credit Reporting Act ('FCRA'), 15 U.S.C. §§ 1681-1681x, and the Duties of Furnishers of Information to Consumer Reporting Agencies Rule, issued pursuant to section 623(e)(1) of the FCRA, 15 U.S.C. § 1681s-2(e)(1), and recodified as Duties of Furnishers of Information, 12 C.F.R. § 1022, subpart E ('Furnisher Rule')."

Paragraph 4 records the usual settlement posture: "Defendant neither admits nor denies any of the allegations in the Complaint, except as specifically stated in this Order." Nothing in this article should be read as a finding of liability against the company.

The Commission's May 1, 2024 announcement described the vote to authorize the filing as 3-0-2, with Commissioners Melissa Holyoak and Andrew Ferguson not participating, and characterized the relief as $20 million in refunds plus an additional $23.6 million in debt forgiveness.

The federal judgment

Section V of the order enters "Judgment in the amount of Forty-Three Million Six Hundred and Five Thousand and Nine Hundred Eighty Dollars ($43,605,980) ... in favor of Plaintiff Federal Trade Commission against Defendant, as monetary relief." It then breaks that figure into two components.

The first is a cash payment: "Payment of Twenty Million Dollars ($20,000,000) to the Commission," which the order says the defendant's "undersigned counsel holds in escrow for no purpose other than payment to the Commission," due "within 7 days of entry of this Order by electronic fund transfer."

The second is not cash at all. It is "Ceased collection of a minimum of Twenty-Three Million Six Hundred and Five Thousand and Nine Hundred Eighty Dollars ($23,605,980) in Covered Consumer Debt." That is why the two figures do not behave alike: $20 million was paid out as refund checks by the Commission, while $23.6 million was a book of debt the company was permanently enjoined from collecting.

The federal order is the template for the Tennessee one

Read side by side, the Tennessee remedies track the federal order provision for provision.

Section VII of the FTC order requires notification "within 15 business days of entry of this Order ... to each consumer with Covered Consumer Debt," in both English and Spanish, by electronic mail to the consumer's most recent known email address "if any" and by written notice to the most recent address of the consumer known to the company. Tennessee's 15-business-day notice by mail and email mirrors it.

Section V.A.2.c requires that, "for any Covered Consumer Debt that has been reported to a CRA, Defendant shall, within 30 business days of entry of this Order, request that each CRA delete the Covered Consumer Debt from the consumer's credit reporting file." Tennessee's 30-business-day deletion request mirrors it.

Section V.A.2.d is the fixture filing provision. It requires that, for any consumer whose covered debt came with a recorded UCC fixture filing for the associated water treatment equipment, the company "cause to be filed, within 30 business days of entry of this order, a termination statement with the recorder's office where each fixture filing for water treatment equipment is recorded." It then closes the loop that makes such provisions work in practice: if the company "is informed that any additional action is necessary to effectuate the termination of all such fixture filings, including but not limited to additional information requested by the agency with which the termination statement has been filed," it must take that action "as soon as practicable but within 14 business days of learning that additional action is necessary," and must give the Commission a list of every consumer whose fixture filing it terminated within 10 business days of filing. Tennessee's requirement to "remove any Uniform Commercial Code fixture filings from property records" mirrors it.

The federal order also carries collection-side mechanics Tennessee's release does not describe: a permanent injunction against collecting covered debt, a duty to stop collecting and notify third-party collectors within 10 business days of entry, a duty to "recall, purchase, or otherwise obtain" any covered debt already referred or sold to a collection agency within 60 business days, a duty to refund any covered-debt payments received after "the effective date of this Order," in the order's phrase, within 30 days of receipt, and a signed compliance declaration within 90 business days.

One definitional difference worth noticing

The federal order defines its covered population as a closed list. "Covered Consumer Debt" means debt owed to the company "by consumers who financed the purchase of water treatment equipment goods or services and that was identified in an email from counsel for Defendant to counsel for the Commission on October 12, 2023," including "any outstanding principal balance and all unpaid interest and fees." The order also defines "Dealer(s)" narrowly, as "any Person engaged in the promotion, offering for sale, or sale of water treatment systems door-to-door."

The Tennessee release, by contrast, does not state how covered debts are identified, and its refund obligation reaches payments made after November 30, 2024, roughly seven months after the FTC's stipulated order was filed on May 1, 2024. The public record we could open does not state the date the federal order was entered, so the two dates cannot be lined up precisely. The release gives no explanation for the November 30, 2024 date, and this article offers none.

What the Law Actually Says

Tennessee's unfair and deceptive practices statute

The Attorney General's October 8, 2026 release does not cite a Tennessee code section, so this article does not attach one to the allegations in this particular matter. What the office's own Consumer Affairs page does say, as read on October 11, 2026, is that its Division of Consumer Affairs "is the clearinghouse for consumer complaints about unfair or deceptive acts or practices conducted within this state," protecting consumers and legitimate businesses "from those who engage in illegal activity as provided under the 'Tennessee Consumer Protection Act of 1977,' T.C.A. §§ 47-18-101 et seq." The same page states that "the Attorney General has authority to enforce the Consumer Protection Act and other consumer protection related laws, both state and federal."

That is the general framework a Tennessee unfair-and-deceptive-practices settlement sits in. It is not a statement that any particular count in this matter was brought under a particular subsection, because the release does not say. For the broader picture of how Tennessee handles deceptive sales conduct and where a complaint goes, see our overview of Tennessee's fraud and deceptive practice rules.

The federal statutes the FTC charged

Section 5 of the FTC Act is the broad prohibition. As published in the 2023 edition of the U.S. Code, 15 U.S.C. § 45(a)(1) provides that "unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful." Section 45(a)(2) empowers and directs the Commission to prevent persons, partnerships and corporations from using such practices, subject to a list of carve-outs that includes banks, savings and loan institutions, federal credit unions and common carriers. A consumer finance company of this kind is not within those carve-outs.

The Truth in Lending Act supplies the disclosure duty. 15 U.S.C. § 1638(a) provides that "for each consumer credit transaction other than under an open end credit plan, the creditor shall disclose each of the following items, to the extent applicable," and then lists them, beginning with the identity of the creditor and "the 'amount financed', using that term, which shall be the amount of credit of which the consumer has actual use." The limiting phrase there is "to the extent applicable," which is doing real work: TILA requires the listed items where they apply to the transaction, not a fixed universal script.

Regulation Z puts the same duty in operational form. 12 C.F.R. § 1026.18, as in force on the version we retrieved from the eCFR on October 11, 2026, provides that "for each transaction other than a mortgage transaction subject to § 1026.19(e) and (f), the creditor shall disclose the following information as applicable," including the amount financed under paragraph (b) and, under paragraph (d), "the finance charge, using that term, and a brief description such as 'the dollar amount the credit will cost you.'"

What a UCC fixture filing is, and why removing it matters

This is the remedy almost nobody recognizes on sight, and it is the one with the longest latency for a homeowner.

When equipment is financed and then installed into a home, the lender can take a security interest in that equipment. Where the equipment becomes a fixture, that interest can be perfected by a filing made in the real property records rather than in the general business filing index. The practical consequence is that the filing sits with the other recorded instruments against the property, which is where a title search looks.

The FTC's stipulated order treats this exact risk as a mandatory disclosure. Among the terms the order requires the company to disclose are "that the creditor, or any party that subsequently assumes the Credit Agreement, can record a purchase money security interest under the Uniform Commercial Code ('UCC') in the product being financed, when such is true," and, in the next item, "that the consumer's ability to sell or refinance their property where the water treatment system is installed may be affected by such a UCC filing." A federal order does not require disclosure of a theoretical inconvenience. The Commission's May 1, 2024 announcement described the security interest, as alleged in its complaint, as functioning essentially like a lien that could make it difficult, and at times impossible, for many consumers to sell their homes.

Tennessee treats these filings as recorded instruments. The Tennessee Department of Revenue's recordation tax manual, which explains the taxes collected by county registers, the secretary of state and any other official who receives an instrument for recordation, states that recordation tax under Tenn. Code Ann. § 67-4-409 consists of a realty transfer tax "on the privilege of publicly recording documents evidencing all transfers of realty" and an indebtedness tax "on the privilege of publicly recording debt instruments." The manual then states that "generally, Uniform Commercial Code ('UCC') fixture filings are subject to indebtedness tax," and that such filings "always require a value to be stated as maximum principal indebtedness."

In other words, in Tennessee a UCC fixture filing is a publicly recorded debt instrument carrying a stated maximum principal amount. We were unable to open an official Tennessee source for the Article 9 filing-office provision itself on October 11, 2026, so this article does not cite a section for which office holds the filing. The operative point does not depend on that citation: both the federal order and the Tennessee settlement require the filing to be removed from the records where it was recorded, and that is what clears the title picture.

A recorded encumbrance that survives a cancelled debt is the kind of problem that shows up years later at the closing table rather than in a monthly statement. For context on what happens when a disputed consumer debt is left to run its course instead, see our guide to how wage garnishment proceeds and how to stop it.

What the FCRA requires of the company reporting the debt

Two FCRA provisions carry the credit reporting half of this settlement.

The first is the furnisher's accuracy duty. 15 U.S.C. § 1681s-2(a)(1)(A) provides that "a person shall not furnish any information relating to a consumer to any consumer reporting agency if the person knows or has reasonable cause to believe that the information is inaccurate." Subparagraph (B) adds a second prohibition: a person shall not furnish information if the person "has been notified by the consumer, at the address specified by the person for such notices, that specific information is inaccurate" and "the information is, in fact, inaccurate." Both limiting conditions are part of the rule; a consumer's assertion alone does not trigger subparagraph (B).

The second is the dispute mechanism. Subject to the reseller and veteran-medical-debt exceptions in subsections (f) and (g), 15 U.S.C. § 1681i(a)(1)(A) requires that, where a consumer disputes the completeness or accuracy of an item in the consumer's file and notifies the agency directly or indirectly through a reseller, the agency "shall, free of charge, conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate and record the current status of the disputed information, or delete the item from the file in accordance with paragraph (5), before the end of the 30-day period beginning on the date on which the agency receives the notice of the dispute from the consumer or reseller." Two further qualifications sit inside paragraph (1) itself. Subparagraph (B) permits an extension "for not more than 15 additional days" if the agency receives relevant information from the consumer during the 30-day period. Subparagraph (C) then disables that extension where, during the original 30 days, the information "is found to be inaccurate or incomplete or the consumer reporting agency determines that the information cannot be verified."

A deletion request from a furnisher under a settlement order and a consumer-initiated dispute under § 1681i are different routes to the same result. The settlement obligates the company to ask. The statute gives the consumer an independent process if the asking does not work.

Analysis: Why This Matters

The following is analysis from the Recording Law Editorial Team.

The reflex when a state attorney general settles after a federal agency has already settled with the same company is to read it as a second helping of the same dish. The documents do not support that reading here.

The federal relief was anchored to a fixed list. "Covered Consumer Debt" in the FTC's order means debt "identified in an email from counsel for Defendant to counsel for the Commission on October 12, 2023." Whatever was on that list in October 2023 defined the federal remedy's reach. The Commission then distributed the cash component as checks: more than $19.8 million to 29,653 consumers, announced February 19, 2025, with a 90-day window to cash them. A list fixed in 2023 and a check-cashing window that closed in 2025 are both, by design, finite.

Tennessee's settlement, as announced, reaches payments made after November 30, 2024. We take no position on why that date was chosen, and the release does not say. But a state obligation measured from a later date is not duplicative of a federal one measured from an earlier list, and that is the plainest reading of the Attorney General's own stated purpose of securing "relief specifically for Tennesseans."

The second stated purpose is the one with the longer tail. The release says Tennessee acted "to preserve independent authority to enforce the injunctive protections." Conduct bans are only worth what their enforcement is worth, and the federal injunction is enforceable by the Commission. Four of the Tennessee obligations are forward-looking supervision duties rather than one-time payments: enhanced disclosures, ensuring dealers have accurate financing information, prohibiting current and future dealers from misrepresenting terms, and establishing complaint-handling procedures. Those are the provisions that govern the next sale rather than remedying the last one, and a state that holds them in its own instrument does not have to persuade a federal agency to act when a Tennessee dealer breaks them.

The third point is the one we would most want a reader to take away, because it is the one the press release states without explaining. Of the three mechanical remedies, the fixture filing removal is the one with no monthly statement attached to it. A refund arrives. A deleted tradeline shows up the next time somebody pulls a credit report. A stale UCC fixture filing recorded against a home does neither. It simply sits in the property records, invisible until a title search runs, which typically means at a sale or a refinance. That is years of latency between the defect and the moment it bites. The FTC thought that risk serious enough to make its disclosure mandatory in the order's own terms, requiring the company to tell consumers that their "ability to sell or refinance their property where the water treatment system is installed may be affected by such a UCC filing." A settlement that cancels the debt but leaves the filing recorded would have fixed the visible half of the problem.

Which leads to the practical limit of any paper remedy of this kind. All three Tennessee obligations are requests and filings made by the company into systems the company does not control: credit reporting agencies hold the tradelines, and a recorder's office holds the property records. The federal order anticipated exactly this friction, which is why it added the clause requiring further action within 14 business days of learning that further action is necessary, and a consumer-level list delivered to the Commission. An obligation to ask is not the same as a guarantee that the record changed. That is not a criticism of the settlement; it is the reason the verification steps below are worth doing rather than assuming.

How This Affects You

This section is general information about processes that are available to consumers. It is not advice about any individual account, and nothing here establishes that any particular person is covered by this settlement or entitled to any payment.

Who the settlement covers, and what arrives unprompted

The Attorney General's release says affected consumers "whose debts are covered by the settlement will receive direct notice from Aqua Finance, by mail and email (if available), within 15 business days of the settlement order." Coverage is determined by the settlement, not by anything a consumer files. There is no claim form described in the release, no application and no deadline for a consumer to meet. Whether a given account is covered, and whether any refund is due on it, are questions the notice and the company's records answer; this article cannot and does not answer them.

Two practical consequences follow. One is that a letter or email about a water treatment system loan from this company is worth reading rather than discarding as marketing. The other is that an unsolicited message demanding a fee, a Social Security number or a bank account number "to release your settlement funds" does not match anything in the announced settlement. Tennessee's consumer complaint channel runs through the Attorney General's Division of Consumer Affairs.

Checking whether a tradeline actually came off a credit report

The settlement requires the company to request deletion. Confirming the request landed is a separate step, and the tools for it are federal and free.

The FTC's consumer guidance explains that consumers can get free copies of their credit report from each of the three nationwide credit bureaus through AnnualCreditReport.com, and that the bureaus have made weekly free reports permanently available there. A deletion request made within 30 business days of a settlement order will not appear instantly, so the useful approach is to pull a report, note what the tradeline currently says, and pull again after the window has run.

If the entry is still there and the consumer believes it is inaccurate, the FTC's guidance describes disputing it in writing with each bureau reporting the error and separately with the company that furnished it, including copies rather than originals of supporting documents and keeping copies of everything sent. The statutory backstop is § 1681i(a)(1)(A): once a bureau receives the dispute, it must conduct a reasonable reinvestigation and either record the current status or delete the item before the end of the 30-day period, extendable by no more than 15 additional days under subparagraph (B) and not extendable at all in the circumstances subparagraph (C) describes. A settlement-driven deletion and a consumer-initiated dispute are independent of each other, and the second does not depend on the first having worked.

Checking whether a fixture filing actually came off the property records

This is the check nobody thinks to run, and it is the one with the longest shadow.

Both the Tennessee settlement and the federal order direct the removal of UCC fixture filings tied to the financed water treatment equipment from the records where they were recorded. The FTC order locates that step at "the recorder's office where each fixture filing for water treatment equipment is recorded," and the Tennessee Department of Revenue's recordation tax manual confirms that a UCC fixture filing is a recorded debt instrument carrying a stated maximum principal indebtedness. We could not open an official Tennessee source for the Article 9 filing-office provision on October 11, 2026, so this article does not state which Tennessee office holds the filing.

So the verification is a records question, not a credit question. The filing would sit in the county property records for the property where the system was installed, alongside the other recorded instruments indexed against it, so pulling those recorded instruments is how a homeowner sees whether a filing is still there and whether a termination statement has been recorded against it. The notice the company is required to send within 15 business days of the settlement order is the other starting point, because it comes from the party that made the filing and is obliged to remove it. Doing either proactively is materially easier than discovering the filing during a title search while a sale or refinance is pending. The federal order's own structure assumed that removals sometimes need a second pass: it required further action within 14 business days of the company learning that further action was necessary.

If the debt is still being collected

The Tennessee release describes debt cancellation as part of the relief. If collection activity continues on a debt a consumer understands to be cancelled, the relevant rules are both state and federal. Our page on Tennessee's debt collection rules sets out what collectors in the state may and may not do, and the broader debt collection section covers the federal framework that applies alongside it.

This is legal information, not legal advice. This article describes a Tennessee Attorney General settlement announced on October 8, 2026 and a separate federal order obtained by the Federal Trade Commission in the U.S. District Court for the Western District of Wisconsin, together with federal consumer credit and credit reporting statutes that apply nationwide. It covers Tennessee and federal law only, and it does not address any other state's separate action. Nothing here establishes that any particular person is covered by this settlement, owed a refund, or entitled to a credit report deletion or a fixture filing removal, and nothing here is an opinion about any individual account, credit file or property record. Consult a licensed attorney in your jurisdiction about your own situation. Details verified on October 11, 2026.

Related articles

• Tennessee debt collection laws
• Home repair and contractor scams
• Tennessee scam and fraud laws
• Debt collection law hub
• How to stop wage garnishment

---

Last updated: 2026-10-11. This is a developing story; details verified as of 2026-10-11.

Frequently Asked Questions

What is the Tennessee Aqua Finance settlement?

On October 8, 2026, Tennessee Attorney General Jonathan Skrmetti announced that Aqua Finance, Inc. will pay $1,864,319.86 to resolve allegations of unfair and deceptive practices involving financing for water treatment systems sold to Tennessee consumers. Of that total, $1,564,319.86 goes to consumers through debt cancellation and refunds and $300,000 is paid to the State of Tennessee. The State alleged that dealers made serious misrepresentations about the systems and about the financing terms offered through the company, and that some dealers later went out of business, leaving consumers with limited recourse but still bound to their financing obligations.

Do Tennessee consumers have to file a claim to receive relief?

The release does not describe any claim form, application or consumer deadline. It says affected consumers whose debts are covered by the settlement will receive direct notice from Aqua Finance, by mail and email where an address is available, within 15 business days of the settlement order. Whether a particular account is covered is determined by the settlement and the company's records, not by anything a consumer submits.

When do the settlement's deadlines actually run?

They run from the settlement order, not from the October 8, 2026 announcement. Notice is due within 15 business days of the order, and the refunds, the credit reporting deletion requests and the fixture filing removals are due within 30 business days of the order. The Attorney General's release does not state the date of the order, so as of October 11, 2026 there is no calendar date for these obligations in the public record.

What is a UCC fixture filing on a financed water treatment system?

When equipment is financed and installed in a home and becomes a fixture, the lender's security interest in it can be perfected by a filing recorded in the real property records rather than in the general business filing index. Because it sits with the other recorded instruments against the property, it can surface in a title search. The FTC's stipulated order against Aqua Finance required the company to disclose that a consumer's ability to sell or refinance the property where the system is installed may be affected by such a UCC filing.

How can someone check whether a covered debt came off a credit report?

The settlement requires the company to request deletion from credit reporting agencies; confirming the request took effect is a separate step. The FTC's consumer guidance explains that free credit reports are available from each of the three nationwide bureaus through AnnualCreditReport.com, including on a weekly basis. If an entry remains and appears inaccurate, the FTC describes disputing it in writing with each bureau and with the furnisher. Under 15 U.S.C. 1681i(a)(1)(A) the bureau must reinvestigate and either record the current status or delete the item before the end of the 30-day period, extendable by no more than 15 additional days in the circumstances the statute specifies.

How can someone check whether a fixture filing came off the property records?

The filing sits in the county property records for the property where the system was installed, so pulling the recorded instruments indexed against that property shows whether a filing is still recorded and whether a termination statement has been recorded against it. We could not open an official Tennessee source for the Article 9 filing-office provision as of October 11, 2026, so this article does not state which Tennessee office holds the filing. The notice the company must send within 15 business days of the settlement order is the other starting point. The federal order anticipated that some removals need follow-up, requiring additional action within 14 business days of the company learning that additional action was necessary.

Is the Tennessee settlement the same as the FTC's Aqua Finance case?

No. They are separate actions. The FTC obtained a stipulated order for permanent injunction, monetary judgment and other relief in the U.S. District Court for the Western District of Wisconsin, filed May 1, 2024 under Case 3:24-cv-00288, carrying a $43,605,980 judgment made up of a $20,000,000 payment to the Commission plus ceased collection of at least $23,605,980 in covered consumer debt. The Tennessee release says the State pursued its separate settlement to secure relief specifically for Tennesseans and to preserve independent authority to enforce the injunctive protections.

Did the FTC already send refunds in the federal case?

Yes. The Commission announced on February 19, 2025 that it was sending more than $19.8 million in refunds, by check, to 29,653 affected consumers, and advised recipients to cash their checks within 90 days as indicated on the check.

Which Tennessee law covers unfair or deceptive business practices?

The Attorney General's October 8, 2026 release does not cite a statute section for this matter. The office's own Consumer Affairs page states that its Division of Consumer Affairs is the clearinghouse for complaints about unfair or deceptive acts or practices conducted within the state under the Tennessee Consumer Protection Act of 1977, T.C.A. sections 47-18-101 et seq., and that the Attorney General has authority to enforce that Act and other state and federal consumer protection laws.

What conduct does the settlement prohibit going forward?

The release states that the settlement permanently bars Aqua Finance from misrepresenting key terms of credit agreements, including interest rates, minimum monthly payments, payment schedules and the total cost of credit. It also requires enhanced disclosures of important financing terms, that the company ensure its dealers have accurate financing information, that it prohibit current and future dealers from misrepresenting financing terms and conditions, and that it establish procedures for appropriately handling complaints involving dealers.