{
  "FIT": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project.",
  "STATE_DATA": {
    "California": {
      "verified": true,
      "tagline": "California already requires a neutral, independent hold for investor-funded loan money. PHOCIS is built to be it.",
      "summary": "Undisbursed funds on investor-funded loans must sit with a neutral, independent escrow agent — the lender can't hold them.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Two main paths. The <b>DRE Real Estate Broker license</b> carries the fund-handling duties: trust-fund accounting with quarterly trust-fund reporting, the §10232.3 neutral-escrow mandate for investor-funded loans, and the ability to sell to individual investors — and an unlicensed person making more than 8 secured loans in 12 months gets pulled into it. The <b>CFL license (DFPI)</b> is the balance-sheet lender's lane: net worth + surety bond, usury exemption, lending strictly from your own balance sheet, brokering only to other CFL licensees. A third path, the CRMLA, also exists. Many firms hold both DRE and CFL."
        },
        {
          "h": "The rule",
          "p": "When a private lender funds with investor money or sells the note to investors, Bus. &amp; Prof. Code §10232.3 requires the loan fully funded into escrow and the undisbursed balance held by a neutral, independent escrow agent — not the lender. Fractionalized multi-investor notes carry added structure under §10238."
        },
        {
          "h": "What it means for you",
          "p": "Construction reserves, rehab holdbacks, and controlled disbursements on investor-backed deals can't legally sit in your own operating accounts. They belong in independent custody, released against the draw schedule — and if you're DRE-licensed, your trust-fund reporting has to prove it."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project. Structured to match what §10232.3 contemplates, with the daily reconciliation that makes DRE trust-fund reporting painless."
        }
      ],
      "cite": "Cal. Bus. & Prof. Code §10232.3; §10238; Cal. Fin. Code (CFL/DFPI); CRMLA"
    },
    "Texas": {
      "verified": true,
      "tagline": "In Texas, construction loan money is statutory trust money — and misapplying it is a crime.",
      "summary": "The Construction Trust Fund Act makes lien-secured construction loan receipts trust funds, with civil and criminal liability for whoever controls and misapplies them.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Under Property Code Ch. 162, loan receipts borrowed to improve specific Texas real property — when the loan is lien-secured — are statutory trust funds. Anyone who receives or controls them is a trustee; misapplication carries civil and criminal liability, reaching individual officers and agents. Banks, other lenders, and title/closing agents are carved out under §162.004. <b>Lender licensing:</b> Texas generally doesn't require a license for business-purpose, non-owner-occupied lending, but practitioner guidance flags additional Texas obligations (usury, owner-occupied rules) — verify your structure."
        },
        {
          "h": "What it means for you",
          "p": "Once your loan funds, the money in the chain is trust money. Funds that sit commingled or get diverted expose whoever controls them — and clean segregation per project is your defense and your contractors' protection."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project. Per-project segregation in segregated custody keeps trust funds traceable to the job — exactly what Ch. 162 is reaching for."
        }
      ],
      "cite": "Tex. Prop. Code §§162.001–162.033"
    },
    "Florida": {
      "verified": true,
      "tagline": "Florida treats entrusted loan funds as trust funds — segregated and federally insured until disbursement.",
      "summary": "Funds entrusted to a mortgage business are held in trust in a segregated, federally insured account; Ch. 494 defines the business-purpose lane and adds registration obligations.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Ch. 494 governs mortgage lending and defines business-purpose loans by CFPB interpretation. Funds entrusted in connection with a mortgage business must be placed immediately into a segregated account at a federally insured institution and held in trust for the payor until disbursement. <b>Lender licensing:</b> Florida's Ch. 494 Mortgage Lender License governs the consumer lane; business-purpose lending generally sits outside company/LO licensure today, though registration-related obligations are flagged in practitioner guidance — verify your posture."
        },
        {
          "h": "What it means for you",
          "p": "Holdbacks and reserves you take in around Florida deals carry trust character: segregated, insured, traceable. Sitting in a general operating account is the exposure pattern regulators and E&amp;O carriers flag."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Fla. Stat. Ch. 494 (incl. §494.001)"
    },
    "Arizona": {
      "verified": true,
      "tagline": "Arizona licenses the act of holding and disbursing other people's funds — and licenses lenders regardless of collateral.",
      "summary": "Holding funds for delivery on a contingent event is licensed 'escrow business' under A.R.S. Title 6; mortgage licensing applies even to business-purpose loans, and a construction trust-fund statute adds civil remedies.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Carrying on escrow business — holding property for delivery on a contingent event — generally requires a DIFI Escrow Agent license (A.R.S. §6-801 et seq.), with exemptions including Commercial Mortgage Banker licensees (§6-811). <b>Lender license: the Arizona Mortgage Banker license</b> — required for business-purpose loans regardless of collateral (with carve-outs, e.g., larger commercial deals), and demanding an in-state qualified employee, a brick-and-mortar Arizona office, audited financials, and ~$100K net worth. A construction trust-fund statute adds civil remedies."
        },
        {
          "h": "What it means for you",
          "p": "Both sides of the transaction are licensed here: your lending and whoever holds your undisbursed funds. Unlicensed fund-holding is a regulatory exposure even when the loan itself is clean."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "A.R.S. §§6-801–6-846; §6-811; Title 6 Ch. 9 (mortgage)"
    },
    "Nevada": {
      "verified": true,
      "tagline": "Nevada requires licensed, bonded 'construction controls' to disburse construction loan money.",
      "summary": "NRS 627 puts construction-loan disbursement in the hands of licensed, bonded construction controls under Mortgage Lending Division oversight; lender licensing applies regardless of collateral, and exchange facilitators are regulated too.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Under NRS Ch. 627, construction controls — the entities that disburse construction loan money — must be licensed and bonded, verify plans, contracts, and budgets against available loan proceeds, and disburse by category. Banks, title insurers, and certain FHA/VA dwelling lenders are exempt. <b>Lender license: the Nevada Mortgage Company license (NRS 645B)</b> — required for business-purpose loans regardless of collateral, with a physical Nevada office and a qualified employee with MLO experience. Exchange facilitators are licensed under NRS 645G."
        },
        {
          "h": "What it means for you",
          "p": "Draw disbursement in Nevada is a regulated activity, not an admin task. The state already mandates the discipline — budget-verified, categorized, bonded disbursement — that informal fund handling lacks."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "NRS Ch. 627; NRS 645A; 645B; 645G"
    },
    "New York": {
      "verified": true,
      "tagline": "In New York, your construction loan proceeds become statutory trust assets the moment the owner receives them.",
      "summary": "Lien Law Article 3-A makes construction loan proceeds received by an owner trust assets for contractors and subs — with books-and-records duties and a diversion presumption if records fail.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Under Lien Law Art. 3-A, funds an owner receives for the improvement of real property — most commonly construction loan proceeds — are assets of a statutory trust, applied first to the cost of improvement. Trustees must keep compliant books and records; failure creates a presumption of diversion (§75(4)), and beneficiaries can enforce within one year of completion (§77)."
        },
        {
          "h": "What it means for you",
          "p": "Every draw you fund lands in a statutory trust on arrival. Clean per-project records aren't best practice here — they're the borrower's legal shield, and your collateral's."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project. Per-project segregation and daily reconciliation give the trustee the records Art. 3-A demands."
        }
      ],
      "cite": "N.Y. Lien Law §§70–79a (Art. 3-A)"
    },
    "Washington": {
      "verified": true,
      "tagline": "Washington regulates the 1031 facilitators holding exchange funds — bond or qualified escrow, by statute.",
      "summary": "Exchange facilitators must keep a $1M+ fidelity bond or hold all client funds in a qualified escrow or trust account (RCW 19.310.040); Washington also appears on the construction trust-fund list.",
      "blocks": [
        {
          "h": "The rule",
          "p": "RCW 19.310.040 requires an exchange facilitator to maintain a fidelity bond of at least $1 million or hold all client funds in a qualified escrow or qualified trust account, with disclosure of any financial benefit from recommended products. Washington is also identified among states with construction trust-fund protections (citation under verification)."
        },
        {
          "h": "What it means for you",
          "p": "If 1031 money touches your deal flow, the holder's structure is statutory: bonded, or qualified-escrow. Informal holding isn't an option."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "RCW 19.310.040; CTF citation pending verification"
    },
    "Colorado": {
      "verified": true,
      "tagline": "Colorado regulates exchange facilitators and protects construction money through a trust-fund statute.",
      "summary": "One of the few states with an exchange-facilitator law, plus a construction trust-fund statute carrying personal and criminal liability for misapplication.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Colorado is among the eight states with a 1031 exchange-facilitator statute governing how QIs safeguard exchange proceeds, and among states whose construction trust-fund statute can impose personal and criminal liability for diverting funds owed down the chain (C.R.S. §38-22-127)."
        },
        {
          "h": "What it means for you",
          "p": "Construction money you lend into Colorado projects carries trust character with teeth. Segregation and traceability protect your borrower's principals — and the project you're secured by."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "C.R.S. §38-22-127; CO exchange-facilitator law"
    },
    "Idaho": {
      "verified": true,
      "tagline": "Idaho licenses business-purpose lending on residential collateral and regulates exchange facilitators.",
      "summary": "A license is required for business-purpose loans secured by 1–4 family residential property, and Idaho is among the eight states regulating 1031 facilitators.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Idaho requires a mortgage license to make business-purpose loans secured by 1–4 family residential property — fix-and-flip collateral squarely included — and maintains exchange-facilitator regulation for QIs holding 1031 proceeds."
        },
        {
          "h": "What it means for you",
          "p": "Residential-collateral BPL is licensed activity here, and any exchange funds in your pipeline sit under facilitator rules. The fund-holding chain has to be as clean as the license."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Idaho mortgage licensing; ID exchange-facilitator law (sections pending verification)"
    },
    "Maine": {
      "verified": true,
      "tagline": "Maine is one of the few states that statutorily disciplines who holds 1031 exchange money, and how.",
      "summary": "Exchange facilitators must carry a $1M+ fidelity bond (or qualified escrow), $250K+ E&O, follow a prudent-investment standard, and never commingle exchange proceeds with operating funds.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Maine's exchange-facilitator law requires a fidelity bond of $1M or more (or a qualified escrow account in its place), an E&amp;O policy of $250K or more, prudent investment of exchange proceeds, strict separation from the QI's operating account, and client notice on ownership changes."
        },
        {
          "h": "What it means for you",
          "p": "Where exchange money meets your lending, the standard is already statutory: bonded or escrowed, segregated, prudently held."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Maine exchange-facilitator law (sections pending verification)"
    },
    "Oregon": {
      "verified": true,
      "tagline": "In Oregon, the collateral — not the purpose — triggers the license.",
      "summary": "Any loan secured by 1–4 family residential property requires a mortgage license, business-purpose or not; Oregon also regulates 1031 facilitators.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Oregon defines 'residential mortgage loan' by the collateral: 1–4 family residential property requires licensing even when the loan is purely business-purpose. Oregon is also among the eight exchange-facilitator states."
        },
        {
          "h": "What it means for you",
          "p": "Fix-and-flip lending on Oregon houses is licensed lending, full stop. And exchange proceeds in the deal sit under facilitator rules."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Or. mortgage lending law; OR exchange-facilitator law (sections pending verification)"
    },
    "Virginia": {
      "verified": true,
      "tagline": "Virginia regulates exchange facilitators and criminalizes construction-fund misapplication.",
      "summary": "An exchange-facilitator statute governs QIs holding 1031 proceeds, and misapplying construction funds carries criminal exposure.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Virginia is among the eight states with an exchange-facilitator law protecting taxpayer exchange proceeds, and among the states imposing criminal liability for misapplication of construction funds."
        },
        {
          "h": "What it means for you",
          "p": "Both the exchange money and the construction money in your Virginia deals carry statutory protection — diversion isn't a civil slap here."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "VA exchange-facilitator law; misapplication statute (sections pending verification)"
    },
    "North Dakota": {
      "verified": true,
      "tagline": "North Dakota licenses business-purpose lending regardless of what secures it.",
      "summary": "One of six states requiring a mortgage license to originate business-purpose loans on any collateral type.",
      "blocks": [
        {
          "h": "The rule",
          "p": "North Dakota requires a license to originate business-purpose mortgage loans regardless of collateral — commercial, residential investment, or construction alike. <b>Lender license: the North Dakota Money Broker license.</b>"
        },
        {
          "h": "What it means for you",
          "p": "There's no business-purpose pass here. Licensed origination plus disciplined fund handling is the whole posture."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "N.D. money-broker/mortgage licensing (sections pending verification)"
    },
    "South Dakota": {
      "verified": true,
      "tagline": "South Dakota licenses all business-purpose lending — and protects construction funds by statute.",
      "summary": "A license is required regardless of collateral, and South Dakota appears among the construction trust-fund states.",
      "blocks": [
        {
          "h": "The rule",
          "p": "South Dakota requires a mortgage license to originate business-purpose loans on any collateral — <b>lender license: the South Dakota Non-Residential Mortgage Lender license</b> (company and LO) — and is identified among states with a construction trust-fund statute."
        },
        {
          "h": "What it means for you",
          "p": "Licensed lending plus trust-character construction money: segregation and traceability are the operating standard."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "S.D. licensing; CTF statute (sections pending verification)"
    },
    "Vermont": {
      "verified": true,
      "tagline": "Vermont licenses business-purpose lending and protects construction money in trust.",
      "summary": "A lender license applies to business-purpose loans (commonly cited for loans under ~$1M), and Vermont sits on the construction trust-fund list.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Vermont requires lender licensing for business-purpose loans regardless of collateral (practitioner sources note a threshold around $1M), and is among states with construction trust-fund protections."
        },
        {
          "h": "What it means for you",
          "p": "Smaller-balance private lending — the heart of fix-and-flip — is licensed activity, and the construction money downstream carries trust character."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "8 V.S.A. licensed-lender law; CTF citation pending verification"
    },
    "Utah": {
      "verified": true,
      "tagline": "Residential collateral triggers Utah licensing — with its distinctive Principal Lending Manager structure.",
      "summary": "Business-purpose loans secured by 1–4 family residential property require licensing, tied to an individual Principal Lending Manager.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Utah requires licensing for business-purpose loans secured by 1–4 family residential property — <b>lender license: under the Utah Residential Mortgage Practices Act, anchored to an individual Principal Lending Manager license</b> tied to the company."
        },
        {
          "h": "What it means for you",
          "p": "Your Utah residential BPL book runs through a named, licensed individual — accountability is personal here, and fund handling should match that standard."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Utah Residential Mortgage Practices Act (sections pending verification)"
    },
    "Minnesota": {
      "verified": true,
      "tagline": "Minnesota licenses residential-collateral BPL and protects construction proceeds by statute.",
      "summary": "A license is required for business-purpose loans on 1–4 family residential collateral, and Minnesota appears among the construction trust-fund states (Minn. Stat. §514.02).",
      "blocks": [
        {
          "h": "The rule",
          "p": "Minnesota requires licensing for business-purpose loans secured by 1–4 family residential property — <b>lender license: the Minnesota Residential Mortgage Originator license</b> (regulators have acknowledged BPL doesn't require MLOs) — and its statute makes proceeds of construction payments subject to trust treatment with misapplication penalties."
        },
        {
          "h": "What it means for you",
          "p": "Licensed origination on the front end; trust-character construction money on the back end. Segregated, traceable funds serve both."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Minn. licensing; Minn. Stat. §514.02"
    },
    "Michigan": {
      "verified": true,
      "tagline": "Michigan's Builders' Trust Fund Act puts personal — even criminal — weight behind construction money.",
      "summary": "Construction funds are held in trust down the payment chain; misapplication can mean personal and criminal liability, surviving bankruptcy.",
      "blocks": [
        {
          "h": "The rule",
          "p": "The Michigan Builders' Trust Fund Act (MCL 570.151 et seq.) makes building-contract funds trust funds for subs and suppliers. Violations can reach individuals with civil and criminal liability, and trust-fund debts are routinely held non-dischargeable in bankruptcy."
        },
        {
          "h": "What it means for you",
          "p": "The money you lend into Michigan projects is trust money in your borrower's hands. Per-project segregation protects them, the subs — and your collateral."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "MCL 570.151 et seq."
    },
    "Wisconsin": {
      "verified": true,
      "tagline": "Wisconsin treats misapplied construction money as theft — with treble damages on the table.",
      "summary": "A theft-by-contractor statute gives construction funds trust character; some violations carry triple damages.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Wisconsin's theft-by-contractor framework (Wis. Stat. §779.02(5)) makes amounts received for improvements a trust fund for labor and material claims; misapplication is treated as theft, and certain circumstances warrant treble damages. Debts from violations are often non-dischargeable."
        },
        {
          "h": "What it means for you",
          "p": "Few states put a sharper edge on construction-fund discipline. Clean, segregated draws are the protection."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Wis. Stat. §779.02(5)"
    },
    "Maryland": {
      "verified": true,
      "tagline": "Maryland's trust-fund statute follows the money even without a separate account — making traceability everything.",
      "summary": "Construction payments are held in trust for subs and suppliers; the statute doesn't require a separate account, which makes clean records the entire defense.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Maryland's construction trust statute (Md. Real Prop. §9-201 et seq.) makes payments under certain contracts trust money for subcontractors and suppliers. Notably, it expressly does not require a separate account — so when disputes hit, traceability decides."
        },
        {
          "h": "What it means for you",
          "p": "Because the statute lets funds sit unsegregated, the borrower who segregates anyway is the one who can prove no diversion. That proof protects your loan."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Md. Code, Real Prop. §9-201 et seq."
    },
    "New Jersey": {
      "verified": true,
      "tagline": "New Jersey applies trust principles to construction money flowing down the chain.",
      "summary": "Identified among construction trust-fund states; misapplied funds can carry criminal exposure under New Jersey's misapplication-of-entrusted-property law.",
      "blocks": [
        {
          "h": "The rule",
          "p": "New Jersey appears among states with construction trust-fund protections, and misapplication of entrusted property carries criminal exposure. The precise statutory contours (public vs. private projects) are under verification."
        },
        {
          "h": "What it means for you",
          "p": "Construction funds here are not free cash in anyone's hands. Segregation and records are the safe harbor while the fine print is confirmed."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Citation pending verification"
    },
    "Pennsylvania": {
      "verified": true,
      "tagline": "Pennsylvania protects construction money in trust down the payment chain.",
      "summary": "Identified among the construction trust-fund states; contractor-received funds carry trust obligations toward subs and suppliers.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Pennsylvania appears among states with construction trust-fund protections obligating those who receive project funds to apply them to project claims first. Exact statutory citation under verification."
        },
        {
          "h": "What it means for you",
          "p": "Draws you fund carry downstream obligations the moment they land. Traceable, per-project disbursement keeps everyone clean."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Citation pending verification"
    },
    "Illinois": {
      "verified": true,
      "tagline": "Illinois gives construction funds trust protection on their way down the chain.",
      "summary": "Identified among the construction trust-fund states; funds received for improvements carry trust obligations to those who did the work.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Illinois appears among states with construction trust-fund protections for subcontractors and suppliers. Exact statutory citation under verification."
        },
        {
          "h": "What it means for you",
          "p": "Project money is obligated money. Segregated draws against verified work are the discipline the law expects."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Citation pending verification"
    },
    "Delaware": {
      "verified": true,
      "tagline": "Delaware protects construction payments in trust for those who built the work.",
      "summary": "Identified among the construction trust-fund states.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Delaware appears among states with construction trust-fund protections; misapplication exposes those controlling the funds. Exact statutory citation under verification."
        },
        {
          "h": "What it means for you",
          "p": "Loan proceeds for Delaware projects carry downstream trust obligations — clean disbursement is the protection."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Citation pending verification"
    },
    "Oklahoma": {
      "verified": true,
      "tagline": "Oklahoma's lien-and-trust framework obligates construction money to the people who earned it.",
      "summary": "Identified among the construction trust-fund states (Okla. Stat. tit. 42 trust provisions).",
      "blocks": [
        {
          "h": "The rule",
          "p": "Oklahoma appears among states whose statutes give construction payments trust character for lien claimants (Okla. Stat. tit. 42, trust-fund provisions; sections under verification)."
        },
        {
          "h": "What it means for you",
          "p": "Trust-character money demands traceability — per-project segregation answers it."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Okla. Stat. tit. 42 (sections pending verification)"
    },
    "South Carolina": {
      "verified": true,
      "tagline": "South Carolina backs construction payments with trust obligations and misapplication penalties.",
      "summary": "Identified among the construction trust-fund states.",
      "blocks": [
        {
          "h": "The rule",
          "p": "South Carolina appears among states with construction trust-fund protections, with penalties for misapplying funds owed down the chain. Exact statutory citation under verification."
        },
        {
          "h": "What it means for you",
          "p": "Funds you lend into projects here carry obligations the moment they're received. Disbursement discipline is the shield."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Citation pending verification"
    },
    "Georgia": {
      "verified": true,
      "tagline": "Georgia answers construction-fund diversion with criminal law.",
      "summary": "No general civil trust-fund action — but misapplying construction funds is a crime.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Georgia imposes criminal liability for misapplication of construction funds rather than a general civil trust-fund cause of action. Licensing can also attach for loans to natural-person borrowers."
        },
        {
          "h": "What it means for you",
          "p": "The deterrent is criminal, the protection is procedural: verified draws and traceable funds keep your borrower — and your project — out of that lane."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Ga. misapplication statute (sections pending verification)"
    },
    "Arkansas": {
      "verified": true,
      "tagline": "Arkansas criminalizes the misapplication of construction trust money.",
      "summary": "Criminal statutes impose liability for misapplying construction funds.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Arkansas is among states imposing criminal liability for misapplication of construction funds, without a broad civil trust-fund regime. Exact statutory citation under verification."
        },
        {
          "h": "What it means for you",
          "p": "Clean, documented disbursement is the borrower's protection — and your collateral's."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Citation pending verification"
    },
    "North Carolina": {
      "verified": true,
      "tagline": "North Carolina adds registration-level obligations to business-purpose lending.",
      "summary": "Among states with licensing/registration-related obligations for BPL lenders beyond the consumer lane.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Practitioner guidance places North Carolina among states with licensing- or registration-related obligations affecting business-purpose mortgage lenders. Exact provisions under verification."
        },
        {
          "h": "What it means for you",
          "p": "BPL isn't frictionless here — registration posture and fund handling both need to be clean."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Pending verification"
    },
    "Alabama": {
      "verified": true,
      "tagline": "Alabama carries registration-level obligations for business-purpose lenders.",
      "summary": "Among states with licensing/registration-related issues for BPL.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Practitioner guidance places Alabama among states with licensing- or registration-related obligations for business-purpose mortgage lenders. Exact provisions under verification."
        },
        {
          "h": "What it means for you",
          "p": "Confirm registration posture before scaling — and keep the fund chain segregated regardless."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Pending verification"
    },
    "Kentucky": {
      "verified": true,
      "tagline": "Kentucky carries registration-level obligations for business-purpose lenders.",
      "summary": "Among states flagged with licensing/registration-related issues for BPL.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Practitioner guidance places Kentucky among states with licensing- or registration-related obligations for business-purpose mortgage lenders. Exact provisions under verification."
        },
        {
          "h": "What it means for you",
          "p": "Posture check first; disciplined fund handling always."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Pending verification"
    },
    "Rhode Island": {
      "verified": true,
      "tagline": "Rhode Island's trigger is unusual: small loans to natural persons need a license.",
      "summary": "A license is required for loans to a natural person under $25,000 — a trap for small-balance lending.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Rhode Island requires a license when lending to a natural person below $25,000 — an unusual threshold that can catch small-balance or gap pieces. Broader provisions under verification."
        },
        {
          "h": "What it means for you",
          "p": "Structure and borrower entity matter here; small side-advances can trigger licensing."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Pending verification"
    },
    "Tennessee": {
      "verified": true,
      "tagline": "Tennessee layers special rules onto business-purpose lending.",
      "summary": "Among states imposing obligations beyond licensure — usury, bonding, or exemption-specific rules.",
      "blocks": [
        {
          "h": "The rule",
          "p": "Practitioner guidance places Tennessee among states imposing additional obligations on business-purpose lenders — exceptions, usury, bonding, or exemption conditions. Exact provisions under verification."
        },
        {
          "h": "What it means for you",
          "p": "The lane exists but has rails — confirm them before scaling, and keep fund handling segregated throughout."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Pending verification"
    },
    "Hawaii": {
      "verified": true,
      "tagline": "Hawaii dropped commercial mortgage licensing in 2011 — discipline here is structural, not licensed.",
      "summary": "No license has been required for commercial/business-purpose mortgage lending since 1/1/2011; the licensing definition covers residential/consumer loans only.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "As of January 1, 2011, Hawaii's licensing definition was narrowed to residential mortgages — commercial and business-purpose mortgage companies no longer require a Hawaii license. Consumer-side lending remains licensed under the state's mortgage loan originator regime."
        },
        {
          "h": "What it means for you",
          "p": "With no licensing gate on BPL, there's also no licensing-driven oversight of how your funds are held. The discipline — segregation, draw control, reconciliation — is yours to impose structurally."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "HRS Ch. 454F (consumer lane); commercial licensing eliminated eff. 1/1/2011"
    },
    "Ohio": {
      "verified": true,
      "tagline": "Ohio's RMLA registration regime reaches broadly into residential mortgage activity.",
      "summary": "The Residential Mortgage Lending Act runs on a Certificate of Registration; its reach into business-purpose residential lending is the question to clear before scaling.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Ohio operates under the Residential Mortgage Lending Act via a <b>Certificate of Registration</b> (with licensed MLOs underneath). The RMLA's reach is broad on residential collateral; its precise application to business-purpose, non-owner-occupied lending is under verification — practitioner treatment varies."
        },
        {
          "h": "What it means for you",
          "p": "Treat Ohio residential-collateral BPL as a posture-check state: confirm registration status before scaling, and keep the fund chain segregated regardless."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Ohio RMLA (ORC Ch. 1322) — BPL applicability pending verification"
    },
    "Missouri": {
      "verified": true,
      "tagline": "Missouri runs a Mortgage Company license regime and recognizes construction trust arrangements.",
      "summary": "Licensing flows through the Missouri Mortgage Company License; Missouri is also identified among states providing for construction trust agreements.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Missouri licenses mortgage activity through the <b>Missouri Mortgage Company License</b> (Division of Finance); application to business-purpose, non-owner-occupied lending is under verification. Missouri is also identified among states whose law provides for construction trust agreements."
        },
        {
          "h": "What it means for you",
          "p": "Where trust arrangements attach to construction money, traceability is the protection — and the proof."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Mo. Mortgage Company License; trust-agreement provisions pending verification"
    },
    "Massachusetts": {
      "verified": true,
      "tagline": "Massachusetts licenses mortgage lending tightly on the consumer side — the BPL boundary is the thing to confirm.",
      "summary": "The Mortgage Lender License regime governs residential lending; business-purpose treatment turns on how the loan and collateral are classified.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Massachusetts operates a <b>Mortgage Lender License / Mortgage Broker License</b> regime through the Division of Banks, governing residential mortgage activity. Its application to business-purpose, non-owner-occupied loans is under verification — classification of loan purpose and collateral decides the lane."
        },
        {
          "h": "What it means for you",
          "p": "A consumer-protective state with active enforcement: get the classification right up front, and keep fund handling clean enough to survive a look."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Mass. Mortgage Lender License (Div. of Banks) — BPL applicability pending verification"
    },
    "New Mexico": {
      "verified": true,
      "tagline": "New Mexico's Mortgage Loan Company license frames the lending lane.",
      "summary": "Licensing runs through the Mortgage Loan Company License; business-purpose applicability is the open item.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "New Mexico licenses mortgage activity through the <b>Mortgage Loan Company License</b> (Financial Institutions Division). Its application to business-purpose, non-owner-occupied lending is under verification."
        },
        {
          "h": "What it means for you",
          "p": "Posture-check before scaling; segregated, documented fund handling is the constant either way."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "N.M. Mortgage Loan Company License — BPL applicability pending verification"
    },
    "Connecticut": {
      "verified": true,
      "tagline": "Connecticut licenses the residential lane and registers the exempt one.",
      "summary": "Mortgage Lender licensing runs through NMLS via the Department of Banking — and even exempt companies register to sponsor licensed staff.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Connecticut operates a <b>Mortgage Lender License</b> regime through the Department of Banking on NMLS, alongside an <b>Exempt Mortgage Company Registration</b> — notable because registering as exempt is itself a filing, not a free pass, and doesn't constitute a determination of exemption. BPL applicability is under verification."
        },
        {
          "h": "What it means for you",
          "p": "Even the exemption is paperwork here. Confirm your lane formally, and keep fund handling disciplined enough to match a registration-minded regulator."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Conn. Dept. of Banking — Mortgage Lender License; Exempt Mortgage Company Registration"
    },
    "Iowa": {
      "verified": true,
      "tagline": "Iowa's licensing trigger is the borrower's primary residence — even on a business-purpose loan.",
      "summary": "A license is required for a business-purpose loan secured by the borrower's primary residence; the Iowa Mortgage Banker License is the lane.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Iowa requires a license to make a business-purpose loan when the collateral is the borrower's <b>primary residence</b> — a trap on cash-out BPL deals where the flipper pledges their own home. License lane: the <b>Iowa Mortgage Banker License</b>. Pure investment-property BPL sits outside that trigger."
        },
        {
          "h": "What it means for you",
          "p": "Underwrite the collateral's occupancy, not just the loan's purpose. A side-pledge of a primary residence changes your licensing posture."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Iowa Mortgage Banker License — primary-residence trigger per practitioner guidance"
    },
    "Kansas": {
      "verified": true,
      "tagline": "Kansas triggers on the borrower's primary residence — and on rate, above 12%.",
      "summary": "A license attaches to business-purpose loans secured by a primary residence, and supervised-lender licensing attaches to loans priced above 12%.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Kansas requires a license for business-purpose loans secured by the borrower's <b>primary residence</b>, and its <b>Supervised Lender</b> framework attaches to loans above a 12% rate — squarely relevant to private-money pricing. Verify which lane your book triggers."
        },
        {
          "h": "What it means for you",
          "p": "At hard-money rates, the 12% supervised-lender line matters even on deals that feel commercial. Posture-check before scaling."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Kan. supervised-lender framework (UCCC); primary-residence trigger per practitioner guidance"
    },
    "West Virginia": {
      "verified": true,
      "tagline": "West Virginia licenses lenders and brokers by statute, with enumerated exemptions.",
      "summary": "W. Va. Code §31-17-2 requires licensure for mortgage lenders and brokers, with specific exemptions including federally insured depositories.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "<b>W. Va. Code §31-17-2</b> requires a license for mortgage lenders and broker-originators, with enumerated exemptions (federally insured depositories, certain nonprofits, securitization holders under conditions). License lanes: the <b>WV Mortgage Lender License</b> and <b>WV Mortgage Broker License</b>. BPL applicability under verification."
        },
        {
          "h": "What it means for you",
          "p": "The statute names who's in and who's out — read your structure against the exemption list before lending, and keep funds segregated either way."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "W. Va. Code §31-17-2"
    },
    "Wyoming": {
      "verified": true,
      "tagline": "Wyoming splits the lanes: mortgage lending and consumer lending each carry their own license.",
      "summary": "The Wyoming Mortgage Lender/Broker License and the Consumer Lender License define the two lanes; BPL treatment under verification.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Wyoming licenses through the <b>Mortgage Lender/Broker License</b> and a separate <b>Consumer Lender License</b> (Division of Banking). Business-purpose applicability is under verification."
        },
        {
          "h": "What it means for you",
          "p": "Two lanes, two filings — confirm which your book touches, and keep the fund chain clean in both."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Wyo. Mortgage Lender/Broker License; Consumer Lender License"
    },
    "Alaska": {
      "verified": true,
      "tagline": "Alaska runs a combined Mortgage Broker/Lender license.",
      "summary": "The Alaska Mortgage Broker/Lender License is the lane; business-purpose treatment under verification.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Alaska licenses through the combined <b>Alaska Mortgage Broker/Lender License</b> (Division of Banking &amp; Securities). Business-purpose applicability is under verification."
        },
        {
          "h": "What it means for you",
          "p": "Posture-check before scaling; segregated, documented fund handling is the constant."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Alaska Mortgage Broker/Lender License — BPL applicability pending verification"
    },
    "Montana": {
      "verified": true,
      "tagline": "Montana licenses mortgage lending and servicing as separate lanes.",
      "summary": "The Montana Mortgage Lender License (with a separate Servicer License) defines the lanes; BPL treatment under verification.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Montana licenses through the <b>Montana Mortgage Lender License</b>, with a separate <b>Mortgage Servicer License</b> for servicing. Business-purpose applicability is under verification."
        },
        {
          "h": "What it means for you",
          "p": "If you service what you originate, both lanes may apply. Confirm posture, segregate funds."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Mont. Mortgage Lender License; Mortgage Servicer License"
    },
    "Nebraska": {
      "verified": true,
      "tagline": "Nebraska's lanes are the Mortgage Banker license and the Loan Broker filing.",
      "summary": "The Nebraska Mortgage Banker License and a separate Loan Broker framework define the lanes; BPL treatment under verification.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Nebraska licenses through the <b>Nebraska Mortgage Banker License</b>, with a separate <b>Loan Broker</b> framework. Business-purpose applicability is under verification."
        },
        {
          "h": "What it means for you",
          "p": "Confirm the lane that matches your model — banker vs broker — before scaling."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Neb. Mortgage Banker License; Loan Broker framework"
    },
    "Mississippi": {
      "verified": true,
      "tagline": "Mississippi runs a Mortgage Lender License through the Department of Banking.",
      "summary": "The Mississippi Mortgage Lender License is the lane; business-purpose treatment under verification.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Mississippi licenses through the <b>Mississippi Mortgage Lender License</b> (Dept. of Banking &amp; Consumer Finance). Business-purpose applicability is under verification."
        },
        {
          "h": "What it means for you",
          "p": "Posture-check, then keep the fund chain segregated and documented."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Miss. Mortgage Lender License — BPL applicability pending verification"
    },
    "Indiana": {
      "verified": true,
      "tagline": "Indiana splits mortgage oversight between two regulators — SOS and DFI.",
      "summary": "Licensing runs through both the Secretary of State and the Department of Financial Institutions, depending on activity; BPL treatment under verification.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Indiana is unusual in splitting mortgage oversight between the <b>Secretary of State</b> (loan brokers) and the <b>Department of Financial Institutions</b> (lenders) — two regulators, two filings, depending on your activity. Business-purpose applicability is under verification."
        },
        {
          "h": "What it means for you",
          "p": "Map your activity to the right regulator first — broker-side and lender-side filings live in different buildings here."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "Ind. SOS (loan broker) / DFI (lender) — BPL applicability pending verification"
    },
    "Louisiana": {
      "verified": true,
      "tagline": "Louisiana sits on the may-require-licensing list for residential-collateral BPL.",
      "summary": "Practitioner guidance flags Louisiana licensing for non-owner-occupied business-purpose residential loans; exact lane under verification.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "Practitioner licensing guidance places Louisiana among states where non-owner-occupied, business-purpose residential mortgage lending may require licensing under its residential mortgage lending framework. Exact provisions under verification."
        },
        {
          "h": "What it means for you",
          "p": "Treat residential-collateral BPL here as licensed-until-confirmed-otherwise, and keep fund handling disciplined regardless."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "La. residential mortgage lending framework — pending verification"
    },
    "New Hampshire": {
      "verified": true,
      "tagline": "New Hampshire licenses mortgage activity through its Banking Department.",
      "summary": "Mortgage banker/broker licensing runs through the NH Banking Department; business-purpose treatment under verification.",
      "blocks": [
        {
          "h": "Lender licensing",
          "p": "New Hampshire licenses mortgage bankers and brokers through the <b>NH Banking Department</b>. Business-purpose applicability and exemptions are under verification."
        },
        {
          "h": "What it means for you",
          "p": "Posture-check before scaling; the fund-handling discipline is the constant in every state."
        },
        {
          "h": "Where PHOCIS fits",
          "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
        }
      ],
      "cite": "NH Banking Dept. licensing — BPL applicability pending verification"
    }
  },
  "defaultRecord": {
    "verified": false,
    "tagline": "Profile in legal verification — here's what holds true in every state.",
    "summary": "State profile in legal verification. Universal fund-holding principles apply.",
    "blocks": [
      {
        "h": "What to confirm",
        "p": "Fund-control, licensing, account and disbursement requirements depend on the transaction and jurisdiction. Confirm the governing documents and applicable professional guidance before proceeding."
      },
      {
        "h": "Where PHOCIS fits",
        "p": "A project-specific workflow can connect supporting documents, approved draws and payment records. Account structure and provider availability must be confirmed for each project."
      }
    ],
    "cite": "State-specific citations pending counsel verification"
  },
  "TIERS": {
    "t1": [
      "California",
      "Nevada",
      "Arizona"
    ],
    "t2": [
      "Texas",
      "New York",
      "Florida",
      "Colorado",
      "Michigan",
      "Wisconsin",
      "Maryland",
      "Minnesota",
      "New Jersey",
      "Pennsylvania",
      "Illinois",
      "Delaware",
      "Oklahoma",
      "South Carolina",
      "South Dakota",
      "Vermont",
      "Washington",
      "Georgia",
      "Arkansas",
      "Virginia"
    ],
    "t3": [
      "North Dakota",
      "Utah",
      "Oregon",
      "Idaho",
      "Iowa",
      "Kansas",
      "Rhode Island",
      "North Carolina",
      "Alabama",
      "Kentucky",
      "Tennessee",
      "Maine",
      "West Virginia"
    ],
    "t4": [
      "Hawaii",
      "Ohio",
      "Missouri",
      "Massachusetts",
      "New Mexico",
      "Connecticut",
      "Wyoming",
      "Alaska",
      "Montana",
      "Nebraska",
      "Mississippi",
      "Indiana",
      "Louisiana",
      "New Hampshire"
    ]
  },
  "TIER_NAMES": {
    "t1": "Tier 1 · Mandated fund control",
    "t2": "Tier 2 · Statutory trust state",
    "t3": "Tier 3 · Licensing-trigger state",
    "t4": "Tier 4 · Standard framework"
  },
  "TIER_OF": {
    "California": "t1",
    "Nevada": "t1",
    "Arizona": "t1",
    "Texas": "t2",
    "New York": "t2",
    "Florida": "t2",
    "Colorado": "t2",
    "Michigan": "t2",
    "Wisconsin": "t2",
    "Maryland": "t2",
    "Minnesota": "t2",
    "New Jersey": "t2",
    "Pennsylvania": "t2",
    "Illinois": "t2",
    "Delaware": "t2",
    "Oklahoma": "t2",
    "South Carolina": "t2",
    "South Dakota": "t2",
    "Vermont": "t2",
    "Washington": "t2",
    "Georgia": "t2",
    "Arkansas": "t2",
    "Virginia": "t2",
    "North Dakota": "t3",
    "Utah": "t3",
    "Oregon": "t3",
    "Idaho": "t3",
    "Iowa": "t3",
    "Kansas": "t3",
    "Rhode Island": "t3",
    "North Carolina": "t3",
    "Alabama": "t3",
    "Kentucky": "t3",
    "Tennessee": "t3",
    "Maine": "t3",
    "West Virginia": "t3",
    "Hawaii": "t4",
    "Ohio": "t4",
    "Missouri": "t4",
    "Massachusetts": "t4",
    "New Mexico": "t4",
    "Connecticut": "t4",
    "Wyoming": "t4",
    "Alaska": "t4",
    "Montana": "t4",
    "Nebraska": "t4",
    "Mississippi": "t4",
    "Indiana": "t4",
    "Louisiana": "t4",
    "New Hampshire": "t4"
  }
}