Ten years after it took effect, Subchapter M is no longer a new regulation. It is the operating framework for the entire U.S. towing industry, and the phase-in that occupied everyone's attention between 2016 and 2022 is long finished. What has replaced it is a renewal cycle, and that cycle is producing a specific set of problems right now for operators who obtained their first Certificate of Inspection early. Requirements that were deferred for five years are coming due, and
