Disagree!You have to be a little careful with apportioning blame without being able to see under the hood. TACC slowdowns are often triggered by objects the car sees that then turn out not to be there. Unless you can see the speed limit AND the TACC set speed change, it is perfectly unclear to the unwashed what the actual cause of the slowdown is.
If the Speed Limit and TACC Max speed both changed, it would make sense. Car detects a speed limit change and slows accordingly (although we already know it won't currently do this on a motorway).
If neither the Speed Limit nor the TACC Max speed change, it also makes some sense. The car thinks it has detected an obstacle and slows down to avoid a collision. This happens under normal conditions when you come up behind a slower car. It also happens under phantom braking conditions but only because the car "thinks" there is an obstacle. Bloody annoying but there is at least some logic behind it - just poor detection.
To change the TACC Max speed (and leave it changed) when there is neither a perceived obstacle nor a speed limit change is just plain wrong and there is no logic to it. Clearly it is a bug that was mostly likely introduced with 2021.36.5.n as it did not occur prior to that.