Tennessee Code Annotated

Tenn. Code Ann. § 66-34-103 (2026)

Withholding of retainage - Violations - Penalties

✓ current as of May 2026
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Amended by 2020 Tenn. Acts, ch. 749, s 16, eff. 7/1/2020.

Acts 2007 , ch. 201, § 3; 2008 , ch. 804, § 3; 2012 , ch. 609, § 1.


Notes of Decisions
Cited in 10 cases (5 in the last 5 years), 2013–2022 · leading case: Beacon4, LLC v. I & L Investments, LLC, 514 S.W.3d 153 (Tenn. Ct. App. 2016).
Beacon4, LLC v. I & L Investments, LLC, 514 S.W.3d 153 (Tenn. Ct. App. 2016). · cites it 27× “Beacon4’s lien claim against I & L consists essentially of two parts: (1) a retainage withheld by I & L for work that the parties agree Beacon4 completed within the scope of the Site Contract, see Tenn. Code Ann. § 66-34-103 (a) (providing for the withholding of a retainage of…”
Snake Steel, Inc. v. Holladay Constr. Grp., LLC (2021). · cites it 5× “, Tenn. Code Ann. § 66-34-103 (d). 8 The parties also continued to dispute Holladay’s liability for Snake Steel’s attorney fees and costs.”
Aarene Contracting, LLC v. Krispy Kreme Doughnut (Tenn. Ct. App. 2016). · cites it 4× “Tenn. Code Ann. § 66-34-103 (a). Krispy Kreme was also required to create a separate escrow account with a third party for retained amounts.”
Twin K Constr., Inc. v. UMA, Geotechnical Constr., Inc. (E.D. Tenn. 2022). · cites it 4× “Tenn. Code Ann. § 66-34-103 (a); Snake Steel, Inc.”
Fed. Engineers & Constructors, Inc. v. Relyant Global LLC (E.D. Tenn. 2022). · cites it 4× “” Tenn. Code Ann. § 66-34-103 (a) (2017) (emphasis added).”
Snake Steel, Inc. v. Holladay Constr. Grp., LLC (Tenn. Ct. App. 2020). · cites it 3× “Tenn. Code Ann. § 66-34-103 (a). When the prime contract is $500,000 or greater, as was the case here, the PPA mandates that all retained amounts “shall be deposited in a separate, interest- bearing, escrow account with a third party which must be established upon the…”
Twin K Constr., Inc. v. UMA, Geotechnical Constr., Inc. (E.D. Tenn. 2022). · cites it 2× “” Tenn. Code Ann. § 66-34-303 ; see also Tenn.”
James G. Akers v. Sessions Paving Co. (Tenn. Ct. App. 2013). · cites it 2× “”); - 201 (“Performance by a contractor in accordance with the provisions of a written contract with an owner . . . .”); -301 (“Performance by a subcontractor, materialman or furnisher in accordance with the provisions of such person’s written contract with a contractor .”
Vic Davis Constr., Inc. v. Lauren Engineers & Constructors, Inc. (Tenn. Ct. App. 2019). “§ 66-34-103(a) (2015). Here, the trial court properly concluded that the escrow provision of the Prompt Pay Act did not apply.”
Snake Steel, Inc. v. Holladay Constr. Grp., LLC - Concurring (2021). “” Tenn. Code Ann. § 66-34-103 (b). Notably, section -103(b) contains no language requiring the prime contractor to deposit such retainages into a separate, interest-bearing escrow account upon receipt from the owner.”
Tenn. Code Ann. § 66-34-103(a): 2 cases
Beacon4, LLC v. I & L Investments, LLC, 514 S.W.3d 153 (Tenn. Ct. App. 2016). “Beacon4’s lien claim against I & L consists essentially of two parts: (1) a retainage withheld by I & L for work that the parties agree Beacon4 completed within the scope of the Site Contract, see Tenn. Code Ann. § 66-34-103 (a) (providing for the withholding of a retainage of…”
Vic Davis Constr., Inc. v. Lauren Engineers & Constructors, Inc. (Tenn. Ct. App. 2019). “§ 66-34-103(a) (2015). Here, the trial court properly concluded that the escrow provision of the Prompt Pay Act did not apply.”
Tenn. Code Ann. § 66-34-103(b): 2 cases
Beacon4, LLC v. I & L Investments, LLC, 514 S.W.3d 153 (Tenn. Ct. App. 2016). “Beacon4’s lien claim against I & L consists essentially of two parts: (1) a retainage withheld by I & L for work that the parties agree Beacon4 completed within the scope of the Site Contract, see Tenn. Code Ann. § 66-34-103 (a) (providing for the withholding of a retainage of…”
Snake Steel, Inc. v. Holladay Constr. Grp., LLC (Tenn. Ct. App. 2020). “Tenn. Code Ann. § 66-34-103 (a). When the prime contract is $500,000 or greater, as was the case here, the PPA mandates that all retained amounts “shall be deposited in a separate, interest- bearing, escrow account with a third party which must be established upon the…”
Tenn. Code Ann. § 66-34-103(e): 1 case
Beacon4, LLC v. I & L Investments, LLC, 514 S.W.3d 153 (Tenn. Ct. App. 2016). “Beacon4’s lien claim against I & L consists essentially of two parts: (1) a retainage withheld by I & L for work that the parties agree Beacon4 completed within the scope of the Site Contract, see Tenn. Code Ann. § 66-34-103 (a) (providing for the withholding of a retainage of…”
Tenn. Code Ann. § 66-34-103(e)(3): 1 case
Beacon4, LLC v. I & L Investments, LLC, 514 S.W.3d 153 (Tenn. Ct. App. 2016). “Beacon4’s lien claim against I & L consists essentially of two parts: (1) a retainage withheld by I & L for work that the parties agree Beacon4 completed within the scope of the Site Contract, see Tenn. Code Ann. § 66-34-103 (a) (providing for the withholding of a retainage of…”
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