[ceejayoz]

From the memo:

> FSS makes no representation regarding the sufficiency of the information provided to FSS and all inquiries made by FSS have been directed to the Client and/or third party personnel responsible for maintaining such information, and the data has been obtained from the Client and/or third party personnel responsible for maintaining such information.

In other words, "unencumbered" here means "Tether told us they're unencumbered".