{"meta":{"key":"s_mt--pass-10","task":"S_MT","title":"SMT Montana ordinary consumer-debt credit reporting, furnishing, and dispute overlays","parent_title":"Montana debt and debt relief law","edition":"pass-10","path":"/research/s_mt--pass-10/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":8,"claims":53,"sources":23,"review_status":"five_bounded_corrections_pending_UNSENT_all_other_holds_retained","review_complete":true,"sha256":"bba40a6b55b9fff038e73982533dcd8f76a5eb0ad4d96313821660a4c0d3d207","headings":["I. Bottom-line findings","1. State actors and scope","2. Montana CRA accuracy and compliance duties","3. Montana file access","4. Montana dispute and correction process","5. Montana disclosure fees","6. Montana obsolete-information rule","7. Montana user and adverse-action information","8. Montana private-law provisions and federal furnisher preemption","9. Montana Consumer Data Privacy Act","10. Security freezes","1. CRA dispute under 15 U.S.C. §1681i","2. Furnisher investigation after CRA notice","3. Direct dispute to furnisher under Regulation V","4. FDCPA validation is separate","1. Accuracy, correction, and disputed status","2. Date of first delinquency","3. Financial-institution negative-information notice","4. Policies and integrity","1. Federal file disclosure","2. Free and paid disclosures","3. Resellers","1. Federal ordinary collection-account clock","2. Montana’s separate seven-year language","3. Sale, assignment, payment, and settlement","4. Paid and settled accounts","5. Transfers and duplicate reporting","Current-status qualification","Example 1 — CRA dispute, direct furnisher dispute, and FDCPA validation are not substitutes","CRA route","Direct furnisher route","FDCPA route","Example 2 — Federal reporting-age clock","Example 3 — Paid settlement versus deletion","Example 4 — Sold account and duplicate-balance risk","Potentially misleading presentation","Potentially accurate transfer presentation","Example 5 — Reinsertion","Example 6 — Incomplete direct dispute","Example 7 — Montana and federal CRA dispute periods","Example 8 — Security freeze does not halt existing-account collection","Freshly read on October 26, 2026","Access-limited or secondary","Bounded negative searches","Not read or resolved"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_MT/pass-10","facets":{"geography":["us","us-mt"],"debt_type":[],"stage":[],"subject":["credit-reporting"]},"scope":"Distinct ordinary consumer-debt reporting/furnishing and CRA-directdispute overlay requiredregistryitem2; P4/P6/P7/P8/P9unreviewed notpremises, sectors/fullremedieslater.","pending_corrections":5},"markdown":"# S_MT PASS-10 — Montana ordinary consumer-debt credit reporting, furnishing, and dispute overlays\n\n**Fresh research session:** October 26, 2026, Pacific / October 26, 2026, UTC\n**Actual model/mode:** GPT-5.6 Sol Pro, regular Chat\n**Relationship to prior work:** Distinct credit-reporting/furnishing component. The saved P4, P6, P7, P8, and P9 reports remain unreviewed and are not adopted as premises here. Necessary Montana and federal provisions were freshly inspected for this pass.\n\n**Component status:** **PARTIAL.** Montana has a real, longstanding state consumer-reporting statute with file-access, accuracy, dispute, user-notification, obsolescence, adverse-action, and fee provisions. The modern day-to-day furnisher workflow is principally governed by the FCRA and Regulation V. The exact enforceability of some Montana provisions is materially affected by federal express preemption, the pre-September 30, 1996 grandfather clauses, and Montana and Ninth Circuit case law. Medical debt, identity-theft blocking, specialty screening, litigation proof, remedies calculations, and local/tribal rules remain outside this pass.\n\n## I. Bottom-line findings\n\n1. **Montana does have a state consumer-reporting law.** Title 31, chapter 3, part 1 defines consumer reporting agencies, requires maximum-possible-accuracy procedures, gives consumers access to file information and sources, provides a state reinvestigation and dispute-statement process, restricts obsolete information, and links violations to Montana consumer-protection law. Most of those provisions originated in 1975. [Montana Code Annotated+4](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html)\n2. **Montana’s statute is primarily a CRA statute, not a complete modern furnisher code.** Original creditors, collectors, debt buyers, and servicers become “furnishers” under federal Regulation V when they provide consumer information to a CRA. A state collection or financial-services license neither authorizes furnishing nor determines CRA/furnisher status. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html)\n3. **Three dispute routes must be separated:**A dispute sent to a CRA under 15 U.S.C. §1681i.A CRA-transmitted furnisher investigation under §1681s-2(b).A direct dispute sent to the furnisher under 12 CFR §1022.43.An FDCPA validation dispute is a fourth, different process. An FCRA dispute does not itself stop debt collection, extinguish the account, or require production of a signed original contract. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1681i/)\n4. **Payment or settlement ordinarily does not require deletion.** If an account has been settled and the consumer no longer owes a balance under the governing agreement, a continued current balance must be corrected. But an accurate historical notation that an account was “paid in settlement” or paid for less than the full contractual balance is not automatically unlawful and can remain until the applicable reporting-age limit. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/)\n5. **The federal collection-account reporting clock generally follows the delinquency that immediately preceded collection or charge-off.** The federal seven-year period begins after a 180-day period beginning on that date of first delinquency. Sale, assignment, placement with another collector, payment, or settlement does not restart that federal clock. Montana also has an on-books seven-year rule for collection and charge-off information, but its starting language differs and its interaction with the federal clock has not been squarely resolved in a controlling Montana decision found here. [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681c/)\n6. **Federal preemption is not one all-or-nothing rule.**Montana’s pre-1996 CRA dispute and obsolescence provisions fall within the textual grandfather exceptions to the relevant FCRA subject-matter preemption clauses, to the extent they remain the same provisions.State duties concerning furnishers are broadly preempted by §1681t(b)(1)(F), which contains no Montana exception.State freeze rules are expressly preempted on the subjects regulated by the federal nationwide-freeze provisions.The CFPB’s October 28, 2025 interpretive rule takes a broad view of FCRA preemption, but it is interpretive guidance rather than a binding judicial decision. [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681t/)\n\n# II. Montana-specific layer\n\n## 1. State actors and scope\n\nMontana defines a “consumer” as an individual. A Montana “consumer report” is information communicated by a consumer reporting agency and used or expected to be used for personal, family, or household credit or insurance, employment, or another statutorily permissible purpose. A report containing only transaction or experience information between the consumer and the person making that report is excluded from Montana’s consumer-report definition. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html)\n\nA Montana consumer reporting agency is a person that regularly assembles or evaluates consumer-credit or other consumer information to furnish consumer reports to third parties. Its “file” consists of all information about the consumer that the agency records and retains, regardless of storage method. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html)\n\nConsequences of that classification:\n\n- An original creditor does not become a Montana CRA merely by maintaining or communicating only its own transaction-and-experience information.\n- A nationwide CRA, specialty CRA, or qualifying reseller can fall within the state definition when it assembles or evaluates information for third-party reports.\n- An original creditor, debt buyer, collector, or servicer that furnishes account information to a CRA is ordinarily analyzed federally as a **furnisher**, whether or not Montana separately licenses its collection activity.\n- A business can occupy more than one role for different functions, but the definitions cannot be collapsed into a single “credit-reporting company” label.\n\nRegulation V defines a furnisher as an entity that supplies consumer information to one or more CRAs for inclusion in a consumer report. “Accuracy” includes correct terms, liability, performance, and consumer identification; “integrity” includes substantiation by records and furnishing in a form designed to minimize misleading reflection in a report. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/41?utm_source=chatgpt.com)\n\n## 2. Montana CRA accuracy and compliance duties\n\nMontana requires a CRA to:\n\n- Maintain reasonable procedures to avoid obsolete information and impermissible-purpose reporting.\n- Verify prospective users and their certified purposes.\n- Decline to furnish reports when it has reasonable grounds to believe no permissible purpose exists.\n- Follow reasonable procedures to assure maximum possible accuracy.\n- Maintain a record of all persons using the information.\n- Maintain the source of each item of information.\n- Notify information suppliers that false information, or information furnished with malice or willful intent to injure, can expose them to suit. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0140/0310-0030-0010-0140.html)\n\nThese are affirmative state CRA duties. They are not a state-law substitute for the more detailed federal furnisher investigation requirements.\n\n## 3. Montana file access\n\nUpon request and proper identification, a Montana CRA must clearly and accurately disclose:\n\n- The nature and substance of all information in the consumer’s file, except medical information.\n- The sources of that information. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0220/0310-0030-0010-0220.html)\n\nMontana’s stated delivery conditions are old-fashioned but still printed in the current code:\n\n- Disclosure during normal business hours and on reasonable notice.\n- In-person disclosure with identification.\n- Telephone disclosure after a written request with proper identification and prepaid or directly charged toll.\n- Trained personnel to explain the information.\n- A right to be accompanied by one identified person, subject to written permission if required. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0230/0310-0030-0010-0230.html)\n\nThose Montana provisions do not eliminate broader federal file-access rights or modern federal delivery systems.\n\n## 4. Montana dispute and correction process\n\nWhen a consumer directly disputes the completeness or accuracy of file information with the Montana CRA, the CRA must reinvestigate within a **reasonable period** unless it has reasonable grounds to regard the dispute as frivolous or irrelevant. Montana does not supply a fixed number of days in §31-3-124. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html)\n\nIf the information is inaccurate or can no longer be verified, the CRA must:\n\n- Promptly delete it.\n- Notify all users of whom the CRA has records that the information was deleted.\n- Those users must also delete it. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html)\n\nIf the reinvestigation does not resolve the dispute:\n\n- The consumer may file a brief statement explaining the dispute.\n- Subsequent reports containing the item must clearly note that it is disputed and include the statement or a clear and accurate summary.\n- The CRA must tell the consumer which recorded users have the disputed information. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html)\n\nThis is broader in some respects than the federal prior-recipient notification process, which generally operates at the consumer’s request and uses federal lookback periods. Whether each Montana feature remains judicially enforceable in a particular case requires the preemption analysis below.\n\n## 5. Montana disclosure fees\n\nSection 31-3-125 delegates disclosure fees to administrative rule. The currently available secondary compilation of ARM 23.19.301 states:\n\n- No charge if the consumer requests disclosure within 30 days after specified adverse-credit notification.\n- Otherwise, no more than **$8.50**.\n- No charge for notifying users of deletion following verification.\n- The rule history lists amendments through August 23, 1996 and a later agency transfer. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0250/0310-0030-0010-0250.html)\n\nThe current official Montana rule-body route was not retrievable in this pass, so the $8.50 amount is **official-body-access qualified**. Federal law separately provides free annual and event-triggered disclosures and establishes a **$16 federal ceiling for 2026 only when no federal free-disclosure right applies**. The federal ceiling is not permission to charge $16 when Montana or federal law requires a lower or zero charge. [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681j/)\n\n## 6. Montana obsolete-information rule\n\nMontana’s on-books CRA statute bars reports containing:\n\n- Bankruptcies older than 14 years from adjudication.\n- Suits and judgments older than seven years or the governing limitations period, whichever is longer.\n- Paid tax liens older than seven years.\n- Accounts placed for collection or charged to profit and loss that antedate the report by more than seven years.\n- Arrest, indictment, or conviction records older than seven years from the listed event.\n- Other adverse information older than seven years. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html)\n\nFor ordinary collection accounts, the state text does not define a 180-day extension or expressly use the federal date-of-first-delinquency formulation. Because this provision dates to 1975, it falls within the textual pre-1996 exception in §1681t(b)(1)(E), but no controlling public Montana decision was found here harmonizing Montana’s starting event with the federal DOFD-plus-180-day framework. The safest legal conclusion is that a Montana report may need to satisfy both applicable rules; the later federal date is not automatically the only relevant date. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html)\n\n## 7. Montana user and adverse-action information\n\nWhen personal, family, or household credit or insurance is denied or made more expensive because of a consumer report, Montana requires the user to tell the consumer and provide the CRA’s name and address. When the adverse decision rests on non-CRA information, the user must disclose the nature of that information after a qualifying written request received within 60 days after the consumer learned of the action, and must advise the consumer of that request right when communicating the adverse action. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0310/0310-0030-0010-0310.html)\n\nThis is an adverse-action crossover, not a full credit-underwriting or ECOA analysis.\n\n## 8. Montana private-law provisions and federal furnisher preemption\n\nMontana’s statute says a consumer may sue for defamation, invasion of privacy, or negligence for noncompliance with the state part; it also speaks of liability for failure to delete or include a dispute statement and for furnishing false information or information supplied with malice or willful intent to injure. Montana additionally characterizes violations of the part as violations of its consumer-protection law. [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0410/0310-0030-0010-0410.html)\n\nThose provisions remain printed law, but they do not establish a currently viable claim against every furnisher:\n\n- §1681t(b)(1)(F) broadly preempts state requirements and prohibitions concerning furnisher responsibilities under §1681s-2.\n- The express exceptions name specified Massachusetts and California provisions—not Montana.\n- *Feller* held that Montana claims based on a bank’s duties to report accurately and respond to credit-report disputes were preempted.\n- *Morrow* likewise treated damages directly tied to credit-reporting duties as preempted while allowing distinct servicing-misrepresentation theories to proceed. [U.S. Code+4](https://uscode.house.gov/us/usc/119-124/t15/s1681t/)\n\nFull state and federal remedies, pleading standards, damages, and limitation periods remain outside this pass.\n\n## 9. Montana Consumer Data Privacy Act\n\nThe Montana Consumer Data Privacy Act exempts the collection, maintenance, disclosure, sale, communication, or use of credit-related personal information by a CRA, furnisher, or report user **only to the extent the activity is regulated by and authorized under the FCRA**. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html)\n\nThis is activity-specific, not blanket entity immunity. It does not prove that unauthorized conduct is exempt, and it does not create a second ordinary-debt correction or deletion workflow where the FCRA already governs.\n\n## 10. Security freezes\n\nMontana’s 2007 freeze provisions remain in the code. They provide, among other things:\n\n- Written or secure-electronic placement requests.\n- A five-business-day ordinary placement period.\n- A 24-hour identity-theft placement branch.\n- Written confirmation.\n- Temporary lifting procedures.\n- An existing-account and collection exception.\n- On-books fees of up to $3 for placement or temporary lifting and up to $5 for reissuing a lost access credential. [Montana Code Annotated+4](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html)\n\nFederal law now expressly preempts state laws concerning the subjects regulated by the nationwide federal freeze provisions. Federal law makes ordinary nationwide freezes free and generally uses faster request channels and timing. Federal law also states that a freeze does not prevent a creditor, assignee, affiliate, or collection agency for an existing account from obtaining the report to review or collect that account. [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/)\n\nTherefore, Montana’s older fee language and slower timing are not treated here as current permission on overlapping nationwide-freeze subjects. Any residual application to a file or actor outside the federally preempted subject remains held.\n\n# III. State/federal actor-duty matrix\n\n| Actor | Montana-specific duties relevant here | Federal duties relevant here | Principal boundary |\n| --- | --- | --- | --- |\n| Montana-defined CRA | Maximum-accuracy procedures; user/purpose controls; file/source disclosure; state reinvestigation; deletion; dispute notation; user notification; state obsolescence | FCRA accuracy, file access, 30-day reinvestigation, furnisher notice, deletion/modification, reinsertion controls, results, prior-recipient notice | Montana and federal CRA duties may coexist subject to specific preemption and conflict |\n| Nationwide CRA | Same Montana CRA duties when state definition/nexus applies | Full FCRA and Regulation V duties; free annual report; federal freeze | Nationwide status does not displace surviving state provisions |\n| Reseller | Potential Montana CRA status depending on activity | Special §1681i(f) process: own-error review within five business days; correction within 20 days or transmission to source CRA; reconvey results | Reseller does not simply use the ordinary CRA process for every dispute |\n| Original creditor furnishing its own account | Montana furnisher-liability text is materially constrained by federal preemption | §1681s-2 accuracy, updates, dispute notation, DOFD, CRA-routed investigation; direct-dispute rule if covered | Original-creditor status does not exempt furnishing from FCRA |\n| Collection agency furnishing | Same as any furnisher; collection license does not authorize reporting | Furnisher duties plus any independently applicable FDCPA duties | FCRA dispute does not automatically stop collection |\n| Debt buyer furnishing purchased debt | State duties depend on reporting activity, not ownership label | Accuracy, integrity, DOFD, direct and CRA-routed dispute duties | Purchase date does not reset DOFD |\n| Servicer furnishing | Same state/federal role analysis | Furnisher policies must account for transfers and source-data integrity | Actual servicing records and transfer fields remain essential |\n| Consumer-report user | Montana adverse-action and report-use duties | Federal permissible-purpose, adverse-action, and other user duties | This pass does not cover full underwriting/adverse-action law |\n| Successor furnisher | No general Montana rule located requiring transmission of every historical dispute to successor | Independently must furnish accurately and investigate disputes directed or transmitted to it | Transfer contract and actual data migration are unsupplied |\n| Financial institution furnishing negative information | No separate Montana ordinary-debt notice identified | Federal notice before or within 30 days after first negative furnishing, subject to statutory details | Notice does not prove accuracy or eliminate dispute rights |\n| CRA report recipient after correction | Montana CRA must notify recorded users of deletion; consumer gets user information for unresolved disputes | At consumer request, federal notice to designated employment recipients from prior two years and other recipients from prior six months | State and federal recipient mechanisms differ |\n\nThe Montana duties derive from §§31-3-102, 114, 122–125, and 131; federal roles derive from the FCRA and Regulation V. [Montana Code Annotated+6](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html)\n\n# IV. The three distinct reporting-dispute channels\n\n## 1. CRA dispute under 15 U.S.C. §1681i\n\nWhen the consumer disputes directly with a CRA—or indirectly through a reseller—the CRA must conduct a reasonable reinvestigation free of charge and complete it within 30 days after receiving the dispute. The CRA may extend by up to 15 days if it receives additional relevant consumer information during the initial period, except where the item is found inaccurate, incomplete, or unverifiable during the original period. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/)\n\nWithin five business days after receiving the dispute, the CRA must notify the furnisher and include all relevant consumer information received. It must forward later relevant information received before the reinvestigation period ends. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/)\n\nIf the CRA reasonably determines the dispute is frivolous or irrelevant, including because the consumer supplied insufficient information, it may terminate the reinvestigation but must notify the consumer within five business days after that determination and identify the reason and information needed. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/)\n\nIf the item is inaccurate, incomplete, or unverifiable, the CRA must promptly delete or modify it and notify the furnisher. If deleted information is later reinserted:\n\n- The furnisher must certify that it is complete and accurate.\n- The CRA must notify the consumer within five business days after reinsertion.\n- The notice must identify the furnisher and explain the consumer’s dispute-statement right.\n- The CRA must maintain procedures designed to prevent improper reappearance. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/)\n\nThe CRA must send results within five business days after completing the reinvestigation, including a revised report and information about further procedural rights. A requested description of the reinvestigation procedure is due within 15 days after the request. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/)\n\nIf unresolved, the consumer may add a statement of up to 100 words under federal law. At the consumer’s request, the CRA must notify designated prior recipients that received the disputed information for employment purposes within the prior two years or another purpose within the prior six months. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/)\n\n## 2. Furnisher investigation after CRA notice\n\nA furnisher’s §1681s-2(b) duties begin after it receives notice of the dispute from a CRA under §1681i—not merely because the consumer complained directly to the furnisher. The furnisher must:\n\n- Conduct an investigation.\n- Review all relevant information supplied by the CRA.\n- Report results to the CRA.\n- If the information is incomplete or inaccurate, report that result to every other nationwide CRA to which it furnished the information.\n- Modify, delete, or permanently block the information as appropriate.\n- Finish within the CRA reinvestigation period. [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/)\n\nUnder Ninth Circuit authority, that investigation must be reasonable in light of the information supplied. A furnisher cannot avoid inquiry where the dispute presents an objectively verifiable factual or legal-status error. But a CRA or furnisher is not universally required to adjudicate every unresolved legal controversy as if conducting a court proceeding. [Justia Law+4](https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html)\n\nA private federal furnisher action ordinarily lies, if at all, under subsection (b) after CRA notice. Congress restricted private enforcement of the subsection (a) accuracy, direct-dispute, dispute-notation, and DOFD duties; those subsection (a) duties are generally enforced by public authorities. [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/)\n\n## 3. Direct dispute to furnisher under Regulation V\n\nA direct dispute may concern:\n\n- Liability for the account.\n- Account terms.\n- Principal balance.\n- Scheduled payment amount or credit limit.\n- Payment status, high balance, payment dates or amounts, opening or closing dates.\n- Other account information bearing on creditworthiness. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com)\n\nThe rule does not apply to every direct complaint. Important exclusions include:\n\n- Most identifying-information disputes.\n- Employment identity.\n- Inquiries.\n- Public-record information, unless furnished by an account-related furnisher.\n- Fraud alerts and active-duty alerts.\n- Information furnished by another furnisher.\n- A dispute that the furnisher reasonably believes was submitted, prepared, or supplied on a form by a credit repair organization or an entity that would be one but for the specified nonprofit exclusion. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com)\n\nThe consumer must send the dispute to the furnisher’s designated dispute address, the address shown on the consumer report, or any business address if the furnisher has not designated one. The dispute must identify the account, specify the challenged information and basis, and include reasonably required supporting material. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com)\n\nThe furnisher must:\n\n- Conduct a reasonable investigation.\n- Review all relevant information.\n- Report results to the consumer within the period that would apply under §1681i.\n- If the information is inaccurate, promptly notify every CRA to which it furnished that information and provide the correction. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com)\n\nA furnisher may decline to investigate a frivolous or irrelevant direct dispute where information is insufficient, the dispute repeats a resolved dispute without new material information, or a regulatory exception applies. It must notify the consumer within five business days after the determination, explain the reason, and identify what information is needed. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com)\n\n## 4. FDCPA validation is separate\n\nFor comparison only, §1692g concerns a covered **debt collector’s** validation notice and collection activity. A timely written dispute or original-creditor request under that provision can pause collection until the collector supplies the specified response. An FCRA dispute addresses consumer-report accuracy and does not, by itself, create that debt-collection pause. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1692g/)\n\nThese processes are not interchangeable:\n\n| Feature | CRA dispute | Direct furnisher dispute | FDCPA validation dispute |\n| --- | --- | --- | --- |\n| Recipient | CRA | Furnisher | Covered debt collector |\n| Primary subject | Accuracy/completeness of report information | Accuracy of furnished account information | Validation of a covered collection debt |\n| Ordinary trigger | Consumer notifies CRA | Consumer sends compliant notice to correct furnisher address | Timely written notice within federal validation period |\n| Furnisher receives CRA-coded notice? | Yes | No | Not necessarily |\n| Investigation deadline | 30 days, possible 15-day extension | Same general period by cross-reference | No fixed response deadline; collection pauses until response |\n| Collection pause | No automatic FCRA pause | No automatic FCRA pause | Yes, for covered collector after timely written trigger |\n| Requires original signed contract? | No universal rule | No universal rule | No universal rule |\n| Debt extinguished if response inadequate? | No | No | No |\n| Typical private federal furnisher path | Possible after CRA notice under §1681s-2(b) | No private subsection (a) action merely for direct-dispute breach | Separate FDCPA remedy if coverage and elements exist |\n\n# V. Federal furnishing duties\n\n## 1. Accuracy, correction, and disputed status\n\nA furnisher may not provide information it knows or has reasonable cause to believe is inaccurate. If furnished information is later determined incomplete or inaccurate, it must promptly correct it and cannot continue furnishing it without correction. If the consumer disputes the information directly with the furnisher, the furnisher may not report the information without indicating that it is disputed. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/)\n\nThese duties apply based on the furnishing activity. They are not limited to collection agencies and are not created by a Montana collection license.\n\n## 2. Date of first delinquency\n\nWhen a furnisher supplies information concerning an account placed for collection, charged to profit or loss, or subjected to similar action, it must report the delinquency date to the CRA within 90 days after furnishing. The statutory method ties that date to the delinquency that immediately preceded the collection, charge-off, or similar action. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/)\n\nA furnisher cannot lawfully “re-age” an account by substituting:\n\n- The date of purchase.\n- The date of placement with a new collector.\n- The date of a later payment.\n- The date of a settlement.\n- The date the account was entered into a new servicing system.\n\n## 3. Financial-institution negative-information notice\n\nA financial institution furnishing negative information to a nationwide CRA must generally notify the customer before furnishing or within 30 days after furnishing. One notice may cover later negative furnishing. Model notices exist, but using a model does not prove the reported data is accurate. [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/)\n\nThis notice requirement is not universal to every nonbank creditor or collector.\n\n## 4. Policies and integrity\n\nEvery furnisher subject to Regulation V must maintain reasonable written policies and procedures concerning the accuracy and integrity of furnished information, appropriate to the furnisher’s size, complexity, and activities. It must consider the Appendix E guidelines and periodically update its procedures. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/42?utm_source=chatgpt.com)\n\nThe guidelines address, among other things:\n\n- Correct consumer matching.\n- Substantiation by records.\n- Correct balances, status, dates, and liability.\n- Prevention of duplicative reporting.\n- Transfers and sales of accounts.\n- Prevention of re-aging.\n- Reasonable dispute investigation.\n- Oversight of service providers.\n- Prompt updating and correction. [Consumer Financial Protection Bureau+1](https://www.consumerfinance.gov/rules-policy/regulations/1022/E?utm_source=chatgpt.com)\n\nAppendix E informs regulatory compliance and policy design. It is not a promise that every operational coding preference or Metro 2 convention is itself a separate private statutory cause of action.\n\n# VI. File access, corrections, and prior recipients\n\n## 1. Federal file disclosure\n\nUpon request and proper identification, the CRA must disclose:\n\n- All information in the consumer’s file at the time of the request.\n- Sources of the information, subject to statutory limits.\n- Identified report recipients, generally covering employment recipients for two years and other recipients for one year.\n- Other specified file and score information. [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t15/s1681g/)\n\nThe federal summary of rights expressly explains that accurate negative information ordinarily does not have to be removed merely because the consumer dislikes it; removal is required when information is outdated, inaccurate, incomplete, or unverifiable under the governing rules. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681g/)\n\n## 2. Free and paid disclosures\n\nFederal law provides:\n\n- At least one free annual disclosure through the centralized nationwide-CRA system.\n- Free disclosure after specified adverse-action notices.\n- Free disclosures in other circumstances such as certain unemployment, public-assistance, and fraud situations.\n- A paid-disclosure ceiling only when no free entitlement applies. [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t15/s1681j/)\n\nThe federal paid-disclosure ceiling is **$16 for calendar year 2026**. [Federal Register](https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures?utm_source=chatgpt.com)\n\nMontana’s qualified $8.50 rule may be more protective in a nonfree transaction, but its exact current enforceability and interaction with federal preemption have not been resolved in a controlling public case found here.\n\n## 3. Resellers\n\nA reseller ordinarily is exempt from the general CRA reinvestigation procedure, but after receiving a consumer dispute it must within five business days determine whether its own act or omission caused the error.\n\n- If yes, it must correct or delete within 20 days.\n- If no, it must forward the dispute and all relevant information to each source CRA.\n- The source CRA’s results go to the reseller, which must immediately reconvey them to the consumer. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/)\n\n# VII. Reporting clocks and status changes\n\n## 1. Federal ordinary collection-account clock\n\nFor an account placed for collection, charged off, or subjected to similar action, the federal seven-year period begins only after a 180-day period beginning on the delinquency that immediately preceded that action. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681c/)\n\nIn formula form:\n\nFederal ordinary reporting endpoint=DOFD+180 days+7 years\\text{Federal ordinary reporting endpoint}\n=\n\\text{DOFD}+180\\text{ days}+7\\text{ years}Federal ordinary reporting endpoint=DOFD+180 days+7 yearsThat is a maximum reporting-age rule, not a guarantee that the item will remain until the last day.\n\nFederal law also contains high-value-report exceptions for specified credit, insurance, and employment contexts. Bankruptcy, judgments, criminal records, medical debt, and other special categories are outside this focused ordinary-debt analysis.\n\n## 2. Montana’s separate seven-year language\n\nMontana’s §31-3-112 bars accounts placed for collection or charged to profit and loss when they antedate the report by more than seven years. It does not expressly define its start event as the federal DOFD or add the federal 180 days. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html)\n\nBecause the Montana provision predates September 30, 1996, the FCRA’s express preemption clause for report-content and obsolescence rules preserves the possibility of its continued operation. No controlling decision located in this pass determines whether the state clock runs from placement, charge-off, DOFD, or another event when those dates differ.\n\nTherefore:\n\n- The federal clock must be calculated.\n- The Montana statutory date must also be identified.\n- The account should not be assumed reportable merely because the federal period has not expired.\n- The account should not be assumed unreportable merely from a guessed Montana trigger.\n\n## 3. Sale, assignment, payment, and settlement\n\nThe federal clock does not restart when:\n\n- The creditor sells the account.\n- A debt buyer acquires it.\n- A new agency receives placement.\n- A servicer changes.\n- The consumer makes a later payment.\n- The account is settled. [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/)\n\nThose later events can require status and balance updates, but they do not create a new delinquency preceding the original charge-off or collection action.\n\n## 4. Paid and settled accounts\n\nNo general Montana or federal rule found here requires automatic deletion solely because the account is paid or settled.\n\nWhat must remain accurate includes:\n\n- Current balance.\n- Whether the account remains open or closed.\n- Whether the consumer still owes any contractual amount.\n- Whether the account was paid in full or settled for less.\n- Dates and payment status.\n- Disputed status where applicable.\n- The historical delinquency and reporting-age dates.\n\nIn *Shaw v. Experian*, the Ninth Circuit held on the particular short-sale facts that reporting the account as paid in settlement and legally paid in full for less than the full balance was not materially misleading. The decision does not authorize every “settled” code regardless of the underlying contract or report fields. [Ninth Circuit Court of Appeals+2](https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf)\n\n## 5. Transfers and duplicate reporting\n\nFederal law does not mandate a single universal tradeline code when an account is sold. The governing requirement is that the report be accurate and not materially misleading.\n\nDepending on the facts, accurate treatment may require:\n\n- The former furnisher to show no current balance if it transferred all rights and is no longer owed money.\n- The purchaser to report its actual current balance and ownership role accurately.\n- Both furnishers to preserve the original DOFD.\n- Prevention of duplicate current balances that make one obligation appear to be two.\n- Correction of transferred-account records where source data was incomplete. [Consumer Financial Protection Bureau+2](https://www.consumerfinance.gov/rules-policy/regulations/1022/41?utm_source=chatgpt.com)\n\nNo general statute located here requires the transferor to deliver every prior consumer dispute or internal note to the successor. But the successor’s own furnishing and investigation duties remain, and the transferor cannot knowingly preserve inaccurate data.\n\n# VIII. State/federal preemption map\n\n| Subject | Federal preemption text | Montana consequence |\n| --- | --- | --- |\n| CRA dispute timing and notifications | §1681t(b)(1)(B), with exception for state law in effect September 30, 1996 | Montana’s 1975 §31-3-124 has a textual grandfather basis; exact conflict/application remains claim-specific |\n| Information contained in reports and obsolescence | §1681t(b)(1)(E), same pre-1996 exception | Montana’s 1975 §31-3-112 may survive subject-matter preemption; exact starting-date interaction unresolved |\n| Furnisher responsibilities | §1681t(b)(1)(F), exceptions only for named Massachusetts and California laws | Montana furnisher duties and state claims are materially constrained; *Feller* applies broad preemption |\n| Security freezes | §1681t(b)(1)(J) and related conduct clauses | Federal nationwide-freeze rules control overlapping subjects; old Montana fee/timing provisions cannot be treated as current federal permission |\n| General state laws outside enumerated fields | §1681t(a) preserves noninconsistent state law | State law may still apply where it regulates a genuinely different subject and does not conflict |\n| Montana privacy act | State itself exempts FCRA-regulated and authorized reporting activity | No duplicate ordinary-debt privacy workflow for exempt activity |\n| Collection conduct distinct from furnishing | Depends on whether claim actually concerns §1681s-2 responsibilities | *Curtis* allows distinction where conduct is collection rather than furnishing a consumer report |\n| Servicing misrepresentation distinct from reporting | Claim-specific | *Morrow* preserved distinct servicing theories while preempting reporting-based damages |\n\nThe statutory preemption provisions are explicit. [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681t/)\n\nThe CFPB’s October 28, 2025 interpretive rule now states a broad federal-preemption view and replaced the withdrawn 2022 interpretation. It became applicable on October 28, 2025. The rule is interpretive and does not itself overrule contrary judicial precedent. [Federal Register](https://www.federalregister.gov/documents/2025/10/28/2025-19671/fair-credit-reporting-act-preemption-of-state-laws?utm_source=chatgpt.com)\n\n# IX. Controlling and materially relevant decisions\n\n| Decision | Posture and holding relevant here | Limits |\n| --- | --- | --- |\n| **Curtis v. Citibank**, 2011 MT 287 | Montana Supreme Court reversed a preemption disposition where the challenged collection agency activity was debt collection rather than furnishing consumer reports to report users | Does not establish that actual furnishing claims escape §1681t(b)(1)(F) |\n| **Feller v. First Interstate Banksystem**, 2013 MT 90 | Montana Supreme Court held claims based on a furnisher’s accuracy and dispute-response responsibilities preempted by §1681t(b)(1)(F) | Does not preempt every separate contract, servicing, or non-reporting theory |\n| **Morrow v. Bank of America**, 2014 MT 117 | Reporting-duty losses were preempted; materially distinct servicing-misrepresentation theories could proceed | Claim characterization and actual damages source matter |\n| **Nelson v. Chase Manhattan Mortgage**, 282 F.3d 1057 | Ninth Circuit recognized a private action under §1681s-2(b) after the furnisher receives CRA notice | Does not create a private action for subsection (a) |\n| **Gorman v. Wolpoff & Abramson**, 584 F.3d 1167 | CRA notice triggers subsection (b); furnisher investigation must be reasonable; dispute status can be material | Reasonableness depends on information supplied and circumstances |\n| **Gross v. CitiMortgage**, 33 F.4th 1246 | A furnisher cannot rubber-stamp information where an objectively verifiable legal event makes reported personal liability incorrect; investigation reasonableness could be a jury issue | Does not require furnishers to adjudicate every unsettled legal dispute |\n| **Shaw v. Experian**, 891 F.3d 749 | Accurate reporting that accounts were paid in settlement for less than full balance was not materially misleading on those facts | No blanket approval of every settlement code or balance |\n| **Carvalho v. Equifax**, 629 F.3d 876 | A plaintiff must identify inaccurate or misleading report information; CRA ordinarily need not resolve an underlying unresolved legal dispute | Must be read with *Gross* where the legal status is objectively verifiable |\n| **Aargon Agency v. O’Laughlin**, 70 F.4th 1224 | At preliminary-injunction stage, Ninth Circuit majority read §1681t(b)(1)(F) narrowly as to a Nevada pre-reporting notice/waiting law | Medical context, preliminary posture, and not a Montana-law case |\n| **TransUnion LLC v. Ramirez**, 594 U.S. 413 | Federal damages plaintiffs need concrete injury; misleading reports communicated to third parties created concrete reputational harm, while uncommunicated internal files did not necessarily do so | Standing boundary only; full remedies excluded |\n\nSupporting sources: [Justia Law+9](https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html)\n\n### Current-status qualification\n\nThe Ninth Circuit’s *Aargon* decision and the CFPB’s October 2025 broad-preemption interpretation point in different directions on the breadth of §1681t(b)(1)(F). Courts retain authority to decide preemption. The interpretive rule did not vacate or overrule *Aargon*. [Justia Law+1](https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html)\n\nNo controlling Montana appellate decision was located that directly reconciles current §§31-3-112 or 31-3-124 with the modern FCRA grandfather provisions.\n\n# X. Operational workflow matrix\n\n| Workflow | Trigger and channel | Required content/action | Deadline | Result and non-result |\n| --- | --- | --- | --- | --- |\n| Montana CRA file request | Consumer request plus proper identification | Nature/substance of file information, except medical; sources | Normal business hours and reasonable notice; no fixed day count in statute | File access; not automatic correction |\n| Montana CRA accuracy dispute | Consumer directly conveys dispute to CRA | Reinvestigate; record current status; delete if inaccurate/unverifiable; unresolved statement | “Reasonable period” | State deletion/user-notification process; exact federal preemption application held |\n| Federal CRA dispute | Consumer or reseller notifies CRA | Reasonable reinvestigation; notify furnisher; review relevant data | 30 days; possible 15-day extension | Correct/delete/modify if inaccurate, incomplete, or unverifiable |\n| CRA frivolous determination | CRA reasonably finds insufficient, frivolous, or irrelevant | Reason and information needed | Five business days after determination | No reinvestigation unless adequate dispute supplied |\n| CRA-routed furnisher investigation | Furnisher receives CRA notice | Investigate; review CRA data; report results; correct all nationwide CRAs if needed | Same federal reinvestigation period | Potential private §1681s-2(b) route; no automatic collection pause |\n| Direct furnisher dispute | Consumer sends compliant dispute to designated/proper address | Identify account, disputed information, basis, supporting documents | Same general 30/45-day period | Furnisher reports result to consumer and corrects CRAs if inaccurate |\n| Direct dispute excluded | Information concerns another furnisher, excluded public record, inquiry, identifying data, alert, or qualifying CRO submission | No Regulation V investigation duty | Frivolous/exclusion notice within five business days if determination made under rule | Other CRA dispute or legal route may remain |\n| Federal file disclosure | Consumer request and identification | All file information, sources, recipients, rights disclosures | No single universal completion period stated here | Annual and specified event-triggered disclosures free |\n| Negative information notice | Financial institution first furnishes negative information | Statutory notice or compliant model notice | Before or within 30 days after furnishing | Notice only; does not establish accuracy |\n| DOFD furnishing | Furnisher reports collection/charge-off information | Accurate date of delinquency preceding collection/charge-off | Within 90 days after furnishing | Fixes reporting-age reference; no re-aging |\n| Correction after payment or settlement | Furnisher determines information incomplete/inaccurate | Prompt correction/update; no repeated inaccurate furnishing | “Promptly,” no universal numbered day | Accurate status/balance; no automatic deletion |\n| Reinsertion | Furnisher certifies deleted information complete/accurate | CRA reinsert; consumer notice; furnisher contact; dispute-statement notice | Consumer notice within five business days after reinsertion | Reinsertion permitted only through statutory process |\n| Prior-recipient correction notice | Consumer requests after deletion/notation | CRA sends deletion/dispute information to designated prior users | No separate completion period in §1681i(d) | Employment lookback two years; other purposes six months |\n| Freeze request | Consumer requests nationwide freeze | Place free freeze under federal process | Generally one business day electronic/phone; three business days mail | Restricts new-account access, not existing-account collection access |\n| FDCPA validation dispute | Timely written dispute to covered debt collector | Collector validates or provides original-creditor information | Collection remains paused until response | Separate from CRA/furnisher investigation |\n\n# XI. Bounded examples\n\n## Example 1 — CRA dispute, direct furnisher dispute, and FDCPA validation are not substitutes\n\n### CRA route\n\n- **Day 0:** CRA receives a specific dispute.\n- **By five business days:** CRA must notify the furnisher.\n- **Ordinary completion:** 30 days after CRA receipt.\n- **Possible extension:** Up to 15 additional days if relevant consumer information arrives during the initial period and the statutory exception to extension does not apply.\n- **After completion:** Results and revised report are due within five business days.\n\n### Direct furnisher route\n\n- **Day 0:** Furnisher receives a complete dispute at a qualifying address.\n- **Completion period:** The same general federal period applicable to CRA reinvestigation.\n- **If inaccurate:** Furnisher must notify every CRA to which it furnished the inaccurate information.\n\n### FDCPA route\n\n- The collection pause arises only if the separate §1692g predicates are met.\n- Neither CRA filing nor direct furnishing dispute automatically stops calls, letters, suit, or contractual accrual.\n\nClaims: S_MT-P10-C015–C027 and C046 below.\n\n## Example 2 — Federal reporting-age clock\n\n**Assumptions**\n\n- Date of first delinquency immediately preceding charge-off: January 15, 2020.\n- No curing payment resets the account before charge-off.\n- Ordinary federal collection-account rule applies.\n- No high-value-report exception.\n\nStep 1:\n\nJanuary 15, 2020+180 days=July 13, 2020\\text{January 15, 2020}+180\\text{ days}=\\text{July 13, 2020}January 15, 2020+180 days=July 13, 2020Step 2:\n\nJuly 13, 2020+7 years=July 13, 2027\\text{July 13, 2020}+7\\text{ years}=\\text{July 13, 2027}July 13, 2020+7 years=July 13, 2027A sale on September 1, 2022 or settlement on March 1, 2024 does not restart that federal clock.\n\nThis is a federal maximum-age illustration, not a guaranteed exact bureau-deletion date. Montana’s separate seven-year statute may require an additional state-trigger analysis.\n\nClaims: S_MT-P10-C030–C033.\n\n## Example 3 — Paid settlement versus deletion\n\n**Hypothetical facts**\n\n- Contractual balance before settlement: $5,000.\n- Written settlement amount: $3,000.\n- Consumer pays $3,000.\n- Agreement releases the remaining $2,000.\n- No interest or additional charge remains due.\n\nArithmetic:\n\n$5,000−$3,000−$2,000 released=$0 current balance\\$5,000-\\$3,000-\\$2,000\\text{ released}=\\$0\\text{ current balance}$5,000−$3,000−$2,000 released=$0 current balanceA report continuing to show $2,000 currently due would conflict with the assumed release.\n\nBut an accurate notation such as:\n\n- Current balance: $0.\n- Account closed.\n- Settled or paid for less than full contractual balance.\n\nis not automatically subject to deletion merely because the settlement was completed.\n\nNo score increase or deletion date is guaranteed.\n\nClaims: S_MT-P10-C034–C036.\n\n## Example 4 — Sold account and duplicate-balance risk\n\n**Assumptions**\n\n- One obligation has a true current balance of $1,200.\n- Original creditor sells all rights.\n- Debt buyer becomes current owner.\n\n### Potentially misleading presentation\n\n- Original creditor reports current balance: $1,200.\n- Debt buyer reports current balance: $1,200.\n\nApparent aggregate current balance:\n\n$1,200+$1,200=$2,400\\$1,200+\\$1,200=\\$2,400$1,200+$1,200=$2,400### Potentially accurate transfer presentation\n\n- Original creditor reports transferred/sold and current balance $0.\n- Buyer reports current balance $1,200.\n\nAggregate current balance:\n\n$0+$1,200=$1,200\\$0+\\$1,200=\\$1,200$0+$1,200=$1,200The example does not prescribe a particular Metro 2 code. The governing issue is whether the report accurately and nonmisleadingly reflects one obligation, current ownership, status, and balance.\n\nClaims: S_MT-P10-C037–C038.\n\n## Example 5 — Reinsertion\n\n**Sequence**\n\n1. CRA deletes an item after it cannot be verified.\n2. Furnisher later certifies that the information is complete and accurate.\n3. CRA reinserts the item.\n4. CRA must notify the consumer within five business days after reinsertion.\n5. The notice must identify the furnisher and explain the right to place a dispute statement.\n\nThe five-business-day period begins after reinsertion, not after the original dispute or the furnisher’s certification.\n\nAn exact calendar date is held because no reinsertion date, time zone, holiday calendar, or delivery method is supplied.\n\nClaims: S_MT-P10-C018–C020.\n\n## Example 6 — Incomplete direct dispute\n\n**Facts**\n\nThe consumer sends: “My credit report is wrong. Fix it,” with no account number, no disputed field, and no supporting information.\n\nThe furnisher may reasonably determine that the dispute lacks sufficient information. If it does:\n\n- It need not conduct the full direct-dispute investigation.\n- It must notify the consumer within five business days after that determination.\n- The notice must identify why the dispute was insufficient and what information is needed.\n\nIf the consumer later supplies the account, field, explanation, and new documentation, the new dispute should not be dismissed merely as a duplicate of the incomplete one.\n\nClaims: S_MT-P10-C025–C027.\n\n## Example 7 — Montana and federal CRA dispute periods\n\nMontana says “within a reasonable period.” Federal law imposes the more concrete 30-day period, subject to the 15-day extension.\n\nFor a nationwide CRA subject to both:\n\n- The CRA cannot use Montana’s open-ended wording to ignore the federal 30-day deadline.\n- A response within 30 days can still violate Montana law if the investigation was not reasonable or the required state user notifications were omitted, assuming those state requirements apply and are not preempted in the particular case.\n\nClaims: S_MT-P10-C004–C007, C013, and C015–C020.\n\n## Example 8 — Security freeze does not halt existing-account collection\n\n**Facts**\n\n- Consumer places a nationwide freeze electronically.\n- CRA places the federal freeze by the applicable one-business-day deadline.\n- A collection agency acts for an existing account owner.\n\nThe freeze does not automatically prevent the creditor or its collection agency from accessing the report to review or collect the existing account under the statutory exception.\n\nIt also does not:\n\n- Delete the account.\n- Stop furnishing.\n- Stop collection.\n- Resolve a dispute.\n- Improve a score.\n\nClaims: S_MT-P10-C011–C012.\n\n# XII. PASS-10 source register\n\n| Source ID | Authority, issuer, literal URL, and exact scope | Status, access, and limits |\n| --- | --- | --- |\n| **S_MT-P10-S001** | **Montana Consumer Reporting Agencies Act**, Montana Legislature. Definitions, §31-3-102: https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html; obsolete information, §31-3-112: https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html; compliance, §31-3-114: https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0140/0310-0030-0010-0140.html; file disclosure, §§31-3-122–125: corresponding section URLs 0220–0250; users, §31-3-131: section 0310; actions, §31-3-141: section 0410; violation, §31-3-153: section 0530. | **Fresh direct official HTML read October 26, 2026 Pacific/UTC.** Published MCA 2025; most operative clauses originated in 1975. No comprehensive post-2025 special-session audit. Internet-code disclaimer applies. [Montana Code Annotated+9](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html) |\n| **S_MT-P10-S002** | **ARM 23.19.301—Disclosure Fees**, Montana Department of Justice/Secretary of State. Current rule route was searched; secondary full text: https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301. Clauses (1)(a)–(b), fee sentence, deletion-notice sentence; history through 2006 transfer. | **Fresh secondary full-text read; official direct body inaccessible.** Currentness qualified. The secondary text states free disclosure in specified 30-day situations and an $8.50 maximum otherwise. [Legal Information Institute](https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301) |\n| **S_MT-P10-S003** | **Montana security-freeze statutes**, Montana Legislature. Placement §30-14-1727: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html; CRA timing §1728: section 0280; lifting §1729: section 0290; removal §1730: section 0300; exceptions §1734: section 0340; fees §1735: section 0350. | **Fresh direct official HTML read October 26, 2026.** Enacted 2007 with selected later amendment. Federal preemption limits overlapping nationwide-freeze subjects. [Montana Code Annotated+4](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html) |\n| **S_MT-P10-S004** | **Montana Consumer Data Privacy Act exemption**, §30-14-2804(2)(k), Montana Legislature: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html. 2025 SB 297, Chapter 567: https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0567.pdf, relevant printed pp.10–11, zero-based PDF indices 9–10. | **Fresh direct official HTML and official enacted-law PDF read; relevant PDF pages visually inspected.** Exemption is limited to FCRA-regulated and authorized activity. [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html) |\n| **S_MT-P10-S005** | **FCRA CRA provisions**, U.S. House Office of Law Revision Counsel. Obsolescence §1681c: https://uscode.house.gov/us/usc/119-124/t15/s1681c/; file access §1681g: https://uscode.house.gov/us/usc/119-124/t15/s1681g/; disputes §1681i: https://uscode.house.gov/us/usc/119-124/t15/s1681i/; charges §1681j: https://uscode.house.gov/us/usc/119-124/t15/s1681j/. | **Fresh direct official HTML read October 26, 2026.** Text contains law through Public Law 119-124, October 15, 2026. Veteran medical and other special branches not developed here. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-S006** | **FCRA furnisher duties**, 15 U.S.C. §1681s-2: https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/. Relevant subsections (a)(1)–(5), (a)(7)–(8), (b), (c), and (d). | **Fresh direct official HTML read October 26, 2026.** Distinguishes public subsection (a) duties from CRA-notice-triggered subsection (b) investigation. [U.S. Code+4](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/) |\n| **S_MT-P10-S007** | **FCRA relation to state law and federal freeze**, 15 U.S.C. §§1681t and 1681c-1: https://uscode.house.gov/us/usc/119-124/t15/s1681t/; https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/. | **Fresh direct official HTML read October 26, 2026.** Relevant preemption clauses: §1681t(a), (b)(1)(B), (E), (F), and (J); freeze timing/exception clauses in §1681c-1. [U.S. Code+3](https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/) |\n| **S_MT-P10-S008** | **Regulation V furnisher provisions**, CFPB/eCFR. Definitions §1022.41: https://www.consumerfinance.gov/rules-policy/regulations/1022/41; policies §1022.42: https://www.consumerfinance.gov/rules-policy/regulations/1022/42; direct disputes §1022.43: https://www.consumerfinance.gov/rules-policy/regulations/1022/43; Appendix E: https://www.consumerfinance.gov/rules-policy/regulations/1022/E. | **Fresh direct official integrated-regulation read October 26, 2026.** Current Regulation V page identifies the version current as of January 1, 2026. [Consumer Financial Protection Bureau+4](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com) |\n| **S_MT-P10-S009** | **Federal disclosure-charge adjustment for 2026**, CFPB, 90 FR 57888: https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures, printed pp.57888–57890. | **Fresh official Federal Register HTML read October 26, 2026.** Effective for 2026; sets $16 ceiling where a disclosure is not free. [Federal Register](https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures?utm_source=chatgpt.com) |\n| **S_MT-P10-S010** | **FCRA Preemption of State Laws**, CFPB interpretive rule, 90 FR 48710: https://www.federalregister.gov/documents/2025/10/28/2025-19671/fair-credit-reporting-act-preemption-of-state-laws, printed pp.48710–48715. | **Fresh official Federal Register HTML read October 26, 2026.** Applicable October 28, 2025; interpretive and nonbinding on courts; replaces withdrawn 2022 interpretation. [Federal Register](https://www.federalregister.gov/documents/2025/10/28/2025-19671/fair-credit-reporting-act-preemption-of-state-laws?utm_source=chatgpt.com) |\n| **S_MT-P10-S011** | ***Curtis v. Citibank*, 2011 MT 287**, Montana Supreme Court full opinion reproduction: https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html. | **Fresh full public opinion read.** Secondary host of primary opinion; no paid subsequent-history citator. Used only for collection-versus-furnishing boundary. [Justia Law+1](https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html) |\n| **S_MT-P10-S012** | ***Feller v. First Interstate Banksystem, Inc.*, 2013 MT 90**: https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html. | **Fresh full public opinion read.** Montana Supreme Court furnisher-preemption decision. [Justia Law+1](https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html) |\n| **S_MT-P10-S013** | ***Morrow v. Bank of America, N.A.*, 2014 MT 117**: https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html. | **Fresh full public opinion read.** Distinguishes reporting-related damages from independent servicing theories. [Justia Law+1](https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html) |\n| **S_MT-P10-S014** | ***Gorman v. Wolpoff & Abramson*, No. 06-17226 (9th Cir. 2009)**: https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html. | **Fresh full public opinion reproduction read.** Secondary host of Ninth Circuit opinion. Relevant to CRA-trigger, reasonable investigation, and dispute notation. [Justia Law+1](https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html) |\n| **S_MT-P10-S015** | ***Nelson v. Chase Manhattan Mortgage Corp.*, 282 F.3d 1057 (9th Cir. 2002)**: https://law.justia.com/cases/federal/appellate-courts/F3/282/1057/581850/. | **Fresh full public opinion reproduction read.** Recognizes private §1681s-2(b) path. [Justia Law](https://law.justia.com/cases/federal/appellate-courts/F3/282/1057/581850/) |\n| **S_MT-P10-S016** | ***Gross v. CitiMortgage, Inc.*, 33 F.4th 1246 (9th Cir. 2022)**, official PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf; relevant printed pp.3 and 7–12, zero-based PDF indices 2 and 6–11. | **Fresh complete official 13-page PDF read; relevant pages visually inspected.** [Ninth Circuit Court of Appeals+1](https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf) |\n| **S_MT-P10-S017** | ***Shaw v. Experian Information Solutions, Inc.*, 891 F.3d 749 (9th Cir. 2018)**, official PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf; relevant printed pp.13–19, zero-based indices 12–18. | **Fresh complete official 23-page PDF read; relevant pages visually inspected.** [Ninth Circuit Court of Appeals+2](https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf) |\n| **S_MT-P10-S018** | ***Carvalho v. Equifax Information Services, LLC*, 629 F.3d 876 (9th Cir. 2010)**, official PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf; relevant printed pp.18–22, zero-based indices 17–21. | **Fresh complete official 26-page PDF read; relevant pages visually inspected.** [Ninth Circuit Court of Appeals+1](https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf) |\n| **S_MT-P10-S019** | ***Aargon Agency, Inc. v. O’Laughlin*, 70 F.4th 1224 (9th Cir. 2023)**: https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html. | **Fresh full public opinion reproduction read.** Preliminary-injunction posture and medical-debt context; no complete subsequent-history citator. [Justia Law+1](https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html) |\n| **S_MT-P10-S020** | ***TransUnion LLC v. Ramirez*, 594 U.S. 413 (2021)**, official Supreme Court PDF: https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf; syllabus printed pp.1–4/PDF indices 0–3; opinion standing analysis principally printed pp.5–27/indices 4–26. | **Fresh complete official 53-page PDF parsed and relevant pages visually inspected.** Used only for federal standing boundary. [Supreme Court](https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf) |\n| **S_MT-P10-S021** | **Current Regulation V and vacated 2025 medical rule status**, CFPB. Regulation V: https://www.consumerfinance.gov/rules-policy/regulations/1022/; medical-rule archive: https://www.consumerfinance.gov/archive/newsroom/cfpb-finalizes-rule-to-remove-medical-bills-from-credit-reports/; compliance page: https://www.consumerfinance.gov/compliance/compliance-resources/other-applicable-requirements/fair-credit-reporting-act/. | **Fresh official CFPB pages read October 26, 2026.** Medical rule vacated July 11, 2025; detailed medical reporting remains excluded. [Consumer Financial Protection Bureau+3](https://www.consumerfinance.gov/rules-policy/regulations/1022/?utm_source=chatgpt.com) |\n| **S_MT-P10-S022** | **FDCPA validation comparison**, 15 U.S.C. §1692g, U.S. House OLRC: https://uscode.house.gov/us/usc/119-124/t15/s1692g/. | **Fresh direct official HTML read October 26, 2026.** Used only to distinguish collection validation from reporting disputes. [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1692g/) |\n| **S_MT-P10-S023** | **Bounded Montana and federal search log** for ordinary-debt furnishing statutes, current Montana CRA rules, final orders, paid/settled deletion, duplicate reporting, transfer-of-dispute duties, and current amendments. | **Fresh bounded public-source searches October 26, 2026.** No Montana-specific current final administrative order or controlling Montana decision resolving §§31-3-112/124 preemption and clock interaction was located. This row is provenance, not proof of absence. |\n\n# XIII. PASS-10 claim register\n\n| Claim ID | Precise claim | Source and limits |\n| --- | --- | --- |\n| **S_MT-P10-C001** | Montana defines a CRA by regular assembly/evaluation of consumer information for third-party reports; transaction-and-experience-only reports are excluded. | S001, §31-3-102. **High.** [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html) |\n| **S_MT-P10-C002** | Montana CRAs must use reasonable procedures for maximum possible accuracy and retain user and source records. | S001, §31-3-114. **High.** [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0140/0310-0030-0010-0140.html) |\n| **S_MT-P10-C003** | Montana consumers may request the nature and substance of file information, except medical information, and its sources. | S001, §31-3-122. **High.** [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0220/0310-0030-0010-0220.html) |\n| **S_MT-P10-C004** | Montana file disclosure is statutorily structured around normal business hours, reasonable notice, in-person or qualified telephone delivery, trained staff, and a permitted companion. | S001, §31-3-123. **High; old-format statute.** [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0230/0310-0030-0010-0230.html) |\n| **S_MT-P10-C005** | A direct Montana CRA dispute requires reinvestigation within a reasonable period unless frivolous or irrelevant. | S001, §31-3-124(1). **High.** [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html) |\n| **S_MT-P10-C006** | Inaccurate or unverifiable information must be deleted and recorded users notified; users must also delete. | S001, §31-3-124(1). **High, subject to preemption/application analysis.** [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html) |\n| **S_MT-P10-C007** | An unresolved Montana dispute permits a brief statement and dispute notation in later reports. | S001, §31-3-124(2)–(3). **High.** [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html) |\n| **S_MT-P10-C008** | Montana’s on-books ordinary collection/charge-off obsolescence period is seven years, but its triggering language differs from federal DOFD-plus-180. | S001, §31-3-112(4). **High text; interaction unresolved.** [Montana Code Annotated+1](https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html) |\n| **S_MT-P10-C009** | ARM 23.19.301 presently appears to cap nonfree Montana file disclosure at $8.50 and requires specified free disclosures. | S002. **Qualified currentness; official body inaccessible.** [Legal Information Institute](https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301) |\n| **S_MT-P10-C010** | Montana’s privacy act exempts credit-reporting activity only to the extent regulated by and authorized under FCRA. | S004, §30-14-2804(2)(k). **High.** [Montana Code Annotated](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html) |\n| **S_MT-P10-C011** | Montana’s freeze statutes remain printed with older timing and fee provisions. | S003. **High for on-books text.** [Montana Code Annotated+3](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html) |\n| **S_MT-P10-C012** | Federal law preempts overlapping state freeze subjects and provides free nationwide freezes; existing-account collection access remains permitted. | S007, §§1681t(b)(1)(J), 1681c-1. **High.** [U.S. Code+1](https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/) |\n| **S_MT-P10-C013** | Montana’s pre-1996 CRA dispute and obsolescence provisions fall within textual grandfather exceptions to §1681t(b)(1)(B)/(E), to the extent unchanged. | S001, S007. **High textual conclusion; exact application unresolved.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681t/) |\n| **S_MT-P10-C014** | State furnisher requirements are broadly preempted by §1681t(b)(1)(F), which contains no Montana exception. | S007; S012–S013. **High.** [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681t/) |\n| **S_MT-P10-C015** | A CRA dispute generally requires a free reasonable reinvestigation within 30 days after receipt. | S005, §1681i(a)(1). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-C016** | The CRA may extend by up to 15 days upon receipt of relevant information, subject to statutory limitations. | S005, §1681i(a)(1)(B)–(C). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-C017** | CRA notice to the furnisher is due within five business days and must include relevant consumer information. | S005, §1681i(a)(2). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-C018** | Frivolous CRA dispute determinations require notice within five business days, reasons, and identification of needed information. | S005, §1681i(a)(3). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-C019** | Inaccurate, incomplete, or unverifiable items must be deleted or modified; reinsertion requires furnisher certification. | S005, §1681i(a)(5). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-C020** | Reinsertion notice and reinvestigation results are due within five business days under their respective triggers. | S005, §1681i(a)(5)–(6). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-C021** | Federal prior-recipient correction notice is consumer-requested, with two-year employment and six-month other-purpose lookbacks. | S005, §1681i(d). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-C022** | Resellers have a distinct five-business-day own-error review and 20-day correction or forwarding process. | S005, §1681i(f). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-C023** | Furnishers may not knowingly or unreasonably furnish inaccurate information and must promptly correct incomplete or inaccurate information. | S006, §1681s-2(a)(1)–(2). **High; public enforcement for subsection (a).** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/) |\n| **S_MT-P10-C024** | A furnisher receiving a direct consumer dispute may not continue furnishing without a dispute notation. | S006, §1681s-2(a)(3). **High; public enforcement boundary.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/) |\n| **S_MT-P10-C025** | The furnisher must report the operative DOFD within 90 days after furnishing collection/charge-off information. | S006, §1681s-2(a)(5). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/) |\n| **S_MT-P10-C026** | CRA notice triggers the furnisher’s investigation, review, results, cross-CRA correction, and modify/delete/block duties under subsection (b). | S006, §1681s-2(b). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/) |\n| **S_MT-P10-C027** | The FCRA does not create a private action for subsection (a), while subsection (b) may support one after CRA notice. | S006; S014–S015. **High.** [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/) |\n| **S_MT-P10-C028** | Regulation V requires reasonable written accuracy-and-integrity policies tailored to the furnisher and periodically updated. | S008, §1022.42. **High.** [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/42?utm_source=chatgpt.com) |\n| **S_MT-P10-C029** | Direct disputes cover liability, terms, balances, status, payment dates/amounts, and other account information bearing on creditworthiness. | S008, §1022.43(a). **High.** [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com) |\n| **S_MT-P10-C030** | Regulation V excludes specified identifying, inquiry, public-record, alert, other-furnisher, and CRO-generated disputes. | S008, §1022.43(b). **High; exact exception facts required.** [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com) |\n| **S_MT-P10-C031** | A direct dispute must use a qualifying address and contain account identification, the disputed item, basis, and supporting information. | S008, §1022.43(c)–(d). **High.** [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com) |\n| **S_MT-P10-C032** | A compliant direct dispute requires reasonable investigation, review, timely results, and CRA corrections if inaccurate. | S008, §1022.43(e). **High.** [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com) |\n| **S_MT-P10-C033** | Frivolous or insufficient direct disputes require a five-business-day notice identifying reasons and needed information. | S008, §1022.43(f). **High.** [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com) |\n| **S_MT-P10-C034** | The federal collection/charge-off reporting period runs seven years after a 180-day period beginning on the preceding DOFD. | S005, §1681c(c). **High.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681c/) |\n| **S_MT-P10-C035** | Sale, placement, payment, or settlement does not reset the federal DOFD clock. | S005–S006; S008 Appendix E. **High.** [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/) |\n| **S_MT-P10-C036** | Payment or settlement does not create an automatic deletion right; current balance and settlement status must nevertheless be accurate. | S005, S006, S017. **High.** [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681g/) |\n| **S_MT-P10-C037** | Furnisher policies should address duplicate reporting, transfers, sale, re-aging, and service-provider data quality. | S008 Appendix E. **High as regulatory-policy guidance, not a standalone coding mandate.** [Consumer Financial Protection Bureau+1](https://www.consumerfinance.gov/rules-policy/regulations/1022/E?utm_source=chatgpt.com) |\n| **S_MT-P10-C038** | No general law located requires automatic deletion of a transferor’s tradeline; the result must be accurate and nonmisleading. | S006, S008, S017–S018. **Qualified bounded conclusion.** [Consumer Financial Protection Bureau+2](https://www.consumerfinance.gov/rules-policy/regulations/1022/41?utm_source=chatgpt.com) |\n| **S_MT-P10-C039** | A credit-report dispute does not automatically halt collection or extinguish the debt. | S005–S008; S022. **High boundary.** [U.S. Code+2](https://uscode.house.gov/us/usc/119-124/t15/s1681i/) |\n| **S_MT-P10-C040** | Neither CRA nor direct-furnisher dispute law universally requires production of a signed original contract. | S005–S008; S014, S018. **High bounded conclusion.** [Justia Law+1](https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html) |\n| **S_MT-P10-C041** | *Curtis* distinguishes collection conduct from actual consumer-report furnishing for preemption purposes. | S011. **High for holding and posture.** [Justia Law](https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html) |\n| **S_MT-P10-C042** | *Feller* broadly preempts Montana claims based on furnisher reporting and dispute-response duties. | S012. **High.** [Justia Law](https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html) |\n| **S_MT-P10-C043** | *Morrow* preempts reporting-derived damages but preserves distinct servicing theories. | S013. **High.** [Justia Law](https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html) |\n| **S_MT-P10-C044** | *Gorman* and *Nelson* establish the CRA-notice-triggered private furnisher route and reasonableness requirement. | S014–S015. **High.** [Justia Law+1](https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html) |\n| **S_MT-P10-C045** | *Gross* allows liability where an objectively verifiable legal event makes reported liability patently incorrect and investigation may be unreasonable. | S016. **High, fact-specific.** [Ninth Circuit Court of Appeals](https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf) |\n| **S_MT-P10-C046** | *Shaw* confirms that accurate settled-for-less reporting is not automatically materially misleading. | S017. **High, fact-specific.** [Ninth Circuit Court of Appeals](https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf) |\n| **S_MT-P10-C047** | *Carvalho* requires inaccurate or misleading information and generally does not require CRAs to adjudicate unresolved legal disputes. | S018. **High, read with Gross.** [Ninth Circuit Court of Appeals](https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf) |\n| **S_MT-P10-C048** | *Aargon* gives §1681t(b)(1)(F) a narrower application in its state pre-reporting-notice context; the CFPB now advocates a broader interpretation. | S019, S010. **High for stated positions; conflict unresolved judicially.** [Justia Law+1](https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html) |\n| **S_MT-P10-C049** | Federal damages plaintiffs need concrete injury under *TransUnion*; an uncommunicated inaccurate file does not automatically establish federal standing. | S020. **High.** [Supreme Court](https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf) |\n| **S_MT-P10-C050** | The January 2025 CFPB medical-debt rule was vacated July 11, 2025 and is not operative. | S021. **High; medical dossier excluded.** [Consumer Financial Protection Bureau+1](https://www.consumerfinance.gov/archive/newsroom/cfpb-finalizes-rule-to-remove-medical-bills-from-credit-reports/) |\n| **S_MT-P10-C051** | The 2026 federal ceiling for a nonfree file disclosure is $16; free statutory disclosures remain free. | S009. **High.** [Federal Register](https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures?utm_source=chatgpt.com) |\n| **S_MT-P10-C052** | A financial institution generally must notify the customer before or within 30 days after furnishing negative information. | S006, §1681s-2(a)(7). **High; financial institutions only.** [U.S. Code](https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/) |\n| **S_MT-P10-C053** | No named account, contract, tradeline, furnisher, report, score, settlement, dispute, or provider status was established. | All sources. **High provenance limit.** |\n\n# XIV. Component coverage and gap table\n\n| Assigned issue | Status | Claim IDs | Exact remaining evidence or next action |\n| --- | --- | --- | --- |\n| Montana CRA definition | Answered | C001 | Apply actual business model and report purpose. |\n| Original-creditor transaction/experience exclusion | Answered textually | C001 | Determine whether communication remained solely internal/experience data or entered a CRA report. |\n| Montana CRA accuracy procedures | Answered | C002 | Actual CRA procedures and file held. |\n| Montana file access | Answered | C003–C004 | Actual identity, request channel, and file held. |\n| Montana CRA dispute | Answered textually | C005–C007 | Federal preemption and actual dispute sequence remain account-specific. |\n| Montana fixed dispute deadline | None in §31-3-124 | C005 | Federal 30-day deadline applies when FCRA covers the CRA. |\n| Montana deletion/user notice | Answered textually | C006 | Exact federal grandfather/conflict application unresolved. |\n| Montana dispute statement | Answered | C007 | Actual unresolved dispute and wording held. |\n| Montana obsolescence | Answered textually | C008 | State trigger and federal harmonization need controlling interpretation. |\n| Montana disclosure fee | Qualified answered | C009, C051 | Authenticate official current ARM body and resolve federal/state interaction. |\n| Montana adverse-action user notice | Answered as crossover | — | Full adverse-action/ECOA analysis excluded. |\n| Montana furnisher private action | Materially preempted/partial | C014, C042–C043 | Claim-specific pleading, actor, and subject matter required. |\n| Montana CRA private action | Partial | C013 | Full remedy, §1681h(e), standing, and limitation analysis later. |\n| Montana privacy act | Answered as exemption boundary | C010 | Determine whether activity was actually FCRA-authorized. |\n| Montana freeze provisions | Answered on books | C011 | Residual nonpreempted scope unresolved. |\n| Federal freeze timing/fees | Answered in core | C012 | Actual request method and identity proof held. |\n| Existing-account collection despite freeze | Answered | C012 | Actual account relationship required. |\n| CRA dispute timeline | Answered | C015–C020 | Actual receipt and additional-information dates needed. |\n| CRA frivolous dispute | Answered | C018 | Actual sufficiency and reasonableness held. |\n| CRA deletion/modification | Answered | C019 | Actual investigation record held. |\n| Reinsertion | Answered | C019–C020 | Actual certification and notice held. |\n| CRA result notice | Answered | C020 | Actual completion and delivery held. |\n| Prior-recipient notification | Answered | C021 | Consumer request and designated recipients needed. |\n| Federal consumer statement | Answered in core | — | Actual statement and CRA treatment held. |\n| Reseller dispute | Answered | C022 | Actual reseller/source CRA relationship held. |\n| Furnisher accuracy | Answered | C023 | Actual source records and furnished fields held. |\n| Furnisher dispute notation | Answered | C024 | Direct dispute receipt and continuing furnishing held. |\n| DOFD reporting | Answered | C025 | Actual delinquency and cure history held. |\n| CRA-routed furnisher investigation | Answered | C026–C027 | Actual CRA notice and transmitted information required. |\n| Direct furnisher dispute | Answered | C029–C033 | Correct address, content, and supporting evidence needed. |\n| CRO-generated direct dispute exclusion | Answered conditionally | C030 | Actual authorship, entity status, and form source held. |\n| Direct dispute private right | No FCRA subsection (a) private route | C027 | Other properly pleaded law remains claim-specific. |\n| Financial-institution negative notice | Answered | C052 | Institution status and first negative furnishing date held. |\n| Furnisher policies/Appendix E | Answered as regulatory requirement/guidance | C028, C037 | Actual written policies and examinations held. |\n| Federal file access | Answered | C003, C051 | Actual report and request route held. |\n| Free annual report | Answered | C051 | Voluntary extra free-report policies are not treated as law. |\n| Federal 2026 paid-disclosure ceiling | Answered | C051 | Applies only absent a free entitlement. |\n| Federal reporting clock | Answered | C034–C035 | Actual DOFD and exceptional-report context needed. |\n| Montana/federal clock interaction | Unresolved in part | C008, C013, C034 | Controlling Montana construction not located. |\n| Sale/assignment and clock | Answered federally | C035 | Actual DOFD still required. |\n| Payment/settlement and clock | Answered federally | C035 | Actual cure history and account terms held. |\n| Paid account status | Answered in principle | C036 | Actual payment application and remaining liability held. |\n| Settled account deletion | No automatic right established | C036, C046 | Contractual pay-for-delete promise, if any, unsupplied. |\n| Accurate settled-for-less notation | Answered as fact-dependent | C046 | Actual agreement and report fields required. |\n| Duplicate tradelines | Partial | C037–C038 | Actual furnishing codes, owner, and balances held. |\n| Transferred-account correction | Answered as accuracy/policy issue | C037–C038 | No universal mandated coding identified. |\n| Transfer of prior dispute file | Unresolved generally | C037 | Contract, knowledge, and later CRA notice required. |\n| Original-creditor identity in ordinary report | Partial | C003, C029 | No universal assignment-chain disclosure established. |\n| CRA dispute versus FDCPA validation | Answered as separate processes | C039–C040 | Full FDCPA pass remains separate. |\n| FCRA collection pause | No automatic pause | C039 | Independent FDCPA, contract, bankruptcy, or court order could differ. |\n| Mandatory original contract production | No universal requirement | C040 | Litigation proof and special-sector law later. |\n| Montana preemption | Answered structurally | C013–C014, C041–C048 | Claim-specific application and later precedent remain. |\n| Current CFPB preemption interpretation | Answered | C048 | Nonbinding; future withdrawal or judicial rejection possible. |\n| Federal standing | Answered as boundary | C049 | Full damages/remedies analysis excluded. |\n| Current medical-rule status | Answered only to prevent overbreadth | C050 | Medical reporting dossier remains excluded. |\n| Identity-theft blocking | Excluded | — | Separate §1681c-2 and Montana restoration pass. |\n| Fraud alerts | Excluded except freeze comparison | — | Separate identity-theft pass. |\n| Tenant/employment/insurance screening | Excluded | — | Separate specialty-reporting passes. |\n| Mortgage/repo/child-support/tax/student debt | Excluded | — | Sector-specific passes. |\n| Bankruptcy reporting | Excluded beyond ordinary-clock distinction | — | Separate bankruptcy/reporting pass. |\n| Litigation proof/admissibility | Excluded | — | Collection-litigation/evidence pass. |\n| Full private/public remedies | Excluded except threshold boundaries | C027, C049 | Separate remedies and limitations pass. |\n| Local/tribal law | Excluded | — | Separate jurisdictional investigation. |\n| Named account/provider compliance | Unresolved | C053 | Requires actual report, furnisher records, notices, and status. |\n| Comprehensive post-2025 Montana currentness | Partial | All state claims | Later special-session, rulemaking, and full citator check. |\n\n# XV. Researcher self-check\n\n## Freshly read on October 26, 2026\n\n- Complete materially relevant current published Montana CRA provisions:Definitions.Obsolete information.Accuracy and compliance procedures.File disclosure.Conditions of disclosure.State dispute procedure.Disclosure fees.User requirements.State action and consumer-protection crossreferences.\n- Montana security-freeze placement, timing, lifting, exceptions, and fee statutes.\n- Montana Consumer Data Privacy Act’s FCRA activity exemption and the relevant enacted 2025 bill pages.\n- Current federal FCRA:CRA file access.CRA disputes and resellers.Obsolescence.Furnisher accuracy, DOFD, negative-information notice, investigations, and enforcement boundary.Preemption.Nationwide freezes.\n- Current Regulation V definitions, furnisher policies, direct disputes, and Appendix E.\n- 2026 federal file-disclosure charge adjustment.\n- October 2025 CFPB preemption interpretive rule.\n- Full publicly available Montana and federal appellate opinions listed in the source register.\n- The current CFPB status pages confirming the July 11, 2025 medical-rule vacatur.\n\n## Access-limited or secondary\n\n- The official current ARM 23.19.301 body was not directly retrievable; a current secondary full-text compilation and rule history were used.\n- Montana Supreme Court opinions were read through full public opinion reproductions where an official court PDF was not located.\n- *Gorman*, *Nelson*, and *Aargon* were read through full public appellate opinion reproductions; official Ninth Circuit PDFs were used for *Gross*, *Shaw*, and *Carvalho*.\n- No paid citator or exhaustive Montana trial-court docket was used.\n\n## Bounded negative searches\n\nNo current public source located in this focused pass established:\n\n- A Montana law requiring automatic deletion of a paid or settled ordinary consumer debt.\n- A Montana law requiring every furnisher to provide a signed original contract during a credit-report dispute.\n- A general Montana requirement to delete the seller’s tradeline whenever a debt is sold.\n- A general Montana duty to transfer every historical dispute record to a successor owner.\n- A controlling Montana appellate decision reconciling §31-3-112’s seven-year language with the federal DOFD-plus-180-day clock.\n- A controlling Montana appellate decision comprehensively reconciling §31-3-124 with modern §1681t preemption.\n- A current Montana-specific public final order addressing ordinary debt-buyer furnishing.\n\nThose bounded results are not proof that no unpublished order, contract duty, local law, tribal law, special-sector provision, or later authority exists.\n\n## Not read or resolved\n\n- Any actual consumer report, tradeline, score, score factor, dispute, CRA response, furnisher response, settlement, payment ledger, assignment, transfer file, coding manual, Metro 2 record, or compliance policy.\n- Any named consumer, creditor, collector, debt buyer, servicer, CRA, or provider status.\n- Full medical-debt, medical-privacy, identity-theft, human-trafficking, specialty-screening, bankruptcy, mortgage, repossession, child-support, tax, education, litigation, ordinary-limitations, judgment, or remedies dossiers.\n- Complete post-2025 Montana legislative and special-session currentness.\n- Complete Montana administrative-rule amendment history.\n- Full damages, attorney-fee, punitive-damages, limitation, and standing analysis beyond the narrow boundaries stated.\n- The unreviewed P8 or P9 conclusions as accepted premises.\n\nExact individual source-fetch timestamps were not exposed and are not invented. No filing, dispute submission, provider lookup, complaint, regulator contact, records request, purchase, account change, private-data access, browser control, other-chat access, local-file write, account approval, provider approval, operational approval, independent review, component acceptance, Montana acceptance, parent-dossier acceptance, A066 acceptance, or publication-readiness determination occurred.\n\n**REPORT PARTIAL — the focused Montana ordinary consumer-debt credit-reporting, furnishing, and dispute-overlay component is completed to the stated source, preemption, actor, and currentness limits.**\n\nEND S_MT PASS-10\n\n","tables":[{"headers":["Actor","Montana-specific duties relevant here","Federal duties relevant here","Principal boundary"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Actor","Montana-specific duties relevant here","Federal duties relevant here","Principal boundary"],["Montana-defined CRA","Maximum-accuracy procedures; user/purpose controls; file/source disclosure; state reinvestigation; deletion; dispute notation; user notification; state obsolescence","FCRA accuracy, file access, 30-day reinvestigation, furnisher notice, deletion/modification, reinsertion controls, results, prior-recipient notice","Montana and federal CRA duties may coexist subject to specific preemption and conflict"],["Nationwide CRA","Same Montana CRA duties when state definition/nexus applies","Full FCRA and Regulation V duties; free annual report; federal freeze","Nationwide status does not displace surviving state provisions"],["Reseller","Potential Montana CRA status depending on activity","Special §1681i(f) process: own-error review within five business days; correction within 20 days or transmission to source CRA; reconvey results","Reseller does not simply use the ordinary CRA process for every dispute"],["Original creditor furnishing its own account","Montana furnisher-liability text is materially constrained by federal preemption","§1681s-2 accuracy, updates, dispute notation, DOFD, CRA-routed investigation; direct-dispute rule if covered","Original-creditor status does not exempt furnishing from FCRA"],["Collection agency furnishing","Same as any furnisher; collection license does not authorize reporting","Furnisher duties plus any independently applicable FDCPA duties","FCRA dispute does not automatically stop collection"],["Debt buyer furnishing purchased debt","State duties depend on reporting activity, not ownership label","Accuracy, integrity, DOFD, direct and CRA-routed dispute duties","Purchase date does not reset DOFD"],["Servicer furnishing","Same state/federal role analysis","Furnisher policies must account for transfers and source-data integrity","Actual servicing records and transfer fields remain essential"],["Consumer-report user","Montana adverse-action and report-use duties","Federal permissible-purpose, adverse-action, and other user duties","This pass does not cover full underwriting/adverse-action law"],["Successor furnisher","No general Montana rule located requiring transmission of every historical dispute to successor","Independently must furnish accurately and investigate disputes directed or transmitted to it","Transfer contract and actual data migration are unsupplied"],["Financial institution furnishing negative information","No separate Montana ordinary-debt notice identified","Federal notice before or within 30 days after first negative furnishing, subject to statutory details","Notice does not prove accuracy or eliminate dispute rights"],["CRA report recipient after correction","Montana CRA must notify recorded users of deletion; consumer gets user information for unresolved disputes","At consumer request, federal notice to designated employment recipients from prior two years and other recipients from prior six months","State and federal recipient mechanisms differ"]]},{"headers":["Feature","CRA dispute","Direct furnisher dispute","FDCPA validation dispute"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Feature","CRA dispute","Direct furnisher dispute","FDCPA validation dispute"],["Recipient","CRA","Furnisher","Covered debt collector"],["Primary subject","Accuracy/completeness of report information","Accuracy of furnished account information","Validation of a covered collection debt"],["Ordinary trigger","Consumer notifies CRA","Consumer sends compliant notice to correct furnisher address","Timely written notice within federal validation period"],["Furnisher receives CRA-coded notice?","Yes","No","Not necessarily"],["Investigation deadline","30 days, possible 15-day extension","Same general period by cross-reference","No fixed response deadline; collection pauses until response"],["Collection pause","No automatic FCRA pause","No automatic FCRA pause","Yes, for covered collector after timely written trigger"],["Requires original signed contract?","No universal rule","No universal rule","No universal rule"],["Debt extinguished if response inadequate?","No","No","No"],["Typical private federal furnisher path","Possible after CRA notice under §1681s-2(b)","No private subsection (a) action merely for direct-dispute breach","Separate FDCPA remedy if coverage and elements exist"]]},{"headers":["Subject","Federal preemption text","Montana consequence"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Subject","Federal preemption text","Montana consequence"],["CRA dispute timing and notifications","§1681t(b)(1)(B), with exception for state law in effect September 30, 1996","Montana’s 1975 §31-3-124 has a textual grandfather basis; exact conflict/application remains claim-specific"],["Information contained in reports and obsolescence","§1681t(b)(1)(E), same pre-1996 exception","Montana’s 1975 §31-3-112 may survive subject-matter preemption; exact starting-date interaction unresolved"],["Furnisher responsibilities","§1681t(b)(1)(F), exceptions only for named Massachusetts and California laws","Montana furnisher duties and state claims are materially constrained; Feller applies broad preemption"],["Security freezes","§1681t(b)(1)(J) and related conduct clauses","Federal nationwide-freeze rules control overlapping subjects; old Montana fee/timing provisions cannot be treated as current federal permission"],["General state laws outside enumerated fields","§1681t(a) preserves noninconsistent state law","State law may still apply where it regulates a genuinely different subject and does not conflict"],["Montana privacy act","State itself exempts FCRA-regulated and authorized reporting activity","No duplicate ordinary-debt privacy workflow for exempt activity"],["Collection conduct distinct from furnishing","Depends on whether claim actually concerns §1681s-2 responsibilities","Curtis allows distinction where conduct is collection rather than furnishing a consumer report"],["Servicing misrepresentation distinct from reporting","Claim-specific","Morrow preserved distinct servicing theories while preempting reporting-based damages"]]},{"headers":["Decision","Posture and holding relevant here","Limits"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Decision","Posture and holding relevant here","Limits"],["Curtis v. Citibank, 2011 MT 287","Montana Supreme Court reversed a preemption disposition where the challenged collection agency activity was debt collection rather than furnishing consumer reports to report users","Does not establish that actual furnishing claims escape §1681t(b)(1)(F)"],["Feller v. First Interstate Banksystem, 2013 MT 90","Montana Supreme Court held claims based on a furnisher’s accuracy and dispute-response responsibilities preempted by §1681t(b)(1)(F)","Does not preempt every separate contract, servicing, or non-reporting theory"],["Morrow v. Bank of America, 2014 MT 117","Reporting-duty losses were preempted; materially distinct servicing-misrepresentation theories could proceed","Claim characterization and actual damages source matter"],["Nelson v. Chase Manhattan Mortgage, 282 F.3d 1057","Ninth Circuit recognized a private action under §1681s-2(b) after the furnisher receives CRA notice","Does not create a private action for subsection (a)"],["Gorman v. Wolpoff & Abramson, 584 F.3d 1167","CRA notice triggers subsection (b); furnisher investigation must be reasonable; dispute status can be material","Reasonableness depends on information supplied and circumstances"],["Gross v. CitiMortgage, 33 F.4th 1246","A furnisher cannot rubber-stamp information where an objectively verifiable legal event makes reported personal liability incorrect; investigation reasonableness could be a jury issue","Does not require furnishers to adjudicate every unsettled legal dispute"],["Shaw v. Experian, 891 F.3d 749","Accurate reporting that accounts were paid in settlement for less than full balance was not materially misleading on those facts","No blanket approval of every settlement code or balance"],["Carvalho v. Equifax, 629 F.3d 876","A plaintiff must identify inaccurate or misleading report information; CRA ordinarily need not resolve an underlying unresolved legal dispute","Must be read with Gross where the legal status is objectively verifiable"],["Aargon Agency v. O’Laughlin, 70 F.4th 1224","At preliminary-injunction stage, Ninth Circuit majority read §1681t(b)(1)(F) narrowly as to a Nevada pre-reporting notice/waiting law","Medical context, preliminary posture, and not a Montana-law case"],["TransUnion LLC v. Ramirez, 594 U.S. 413","Federal damages plaintiffs need concrete injury; misleading reports communicated to third parties created concrete reputational harm, while uncommunicated internal files did not necessarily do so","Standing boundary only; full remedies excluded"]]},{"headers":["Workflow","Trigger and channel","Required content/action","Deadline","Result and non-result"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Workflow","Trigger and channel","Required content/action","Deadline","Result and non-result"],["Montana CRA file request","Consumer request plus proper identification","Nature/substance of file information, except medical; sources","Normal business hours and reasonable notice; no fixed day count in statute","File access; not automatic correction"],["Montana CRA accuracy dispute","Consumer directly conveys dispute to CRA","Reinvestigate; record current status; delete if inaccurate/unverifiable; unresolved statement","“Reasonable period”","State deletion/user-notification process; exact federal preemption application held"],["Federal CRA dispute","Consumer or reseller notifies CRA","Reasonable reinvestigation; notify furnisher; review relevant data","30 days; possible 15-day extension","Correct/delete/modify if inaccurate, incomplete, or unverifiable"],["CRA frivolous determination","CRA reasonably finds insufficient, frivolous, or irrelevant","Reason and information needed","Five business days after determination","No reinvestigation unless adequate dispute supplied"],["CRA-routed furnisher investigation","Furnisher receives CRA notice","Investigate; review CRA data; report results; correct all nationwide CRAs if needed","Same federal reinvestigation period","Potential private §1681s-2(b) route; no automatic collection pause"],["Direct furnisher dispute","Consumer sends compliant dispute to designated/proper address","Identify account, disputed information, basis, supporting documents","Same general 30/45-day period","Furnisher reports result to consumer and corrects CRAs if inaccurate"],["Direct dispute excluded","Information concerns another furnisher, excluded public record, inquiry, identifying data, alert, or qualifying CRO submission","No Regulation V investigation duty","Frivolous/exclusion notice within five business days if determination made under rule","Other CRA dispute or legal route may remain"],["Federal file disclosure","Consumer request and identification","All file information, sources, recipients, rights disclosures","No single universal completion period stated here","Annual and specified event-triggered disclosures free"],["Negative information notice","Financial institution first furnishes negative information","Statutory notice or compliant model notice","Before or within 30 days after furnishing","Notice only; does not establish accuracy"],["DOFD furnishing","Furnisher reports collection/charge-off information","Accurate date of delinquency preceding collection/charge-off","Within 90 days after furnishing","Fixes reporting-age reference; no re-aging"],["Correction after payment or settlement","Furnisher determines information incomplete/inaccurate","Prompt correction/update; no repeated inaccurate furnishing","“Promptly,” no universal numbered day","Accurate status/balance; no automatic deletion"],["Reinsertion","Furnisher certifies deleted information complete/accurate","CRA reinsert; consumer notice; furnisher contact; dispute-statement notice","Consumer notice within five business days after reinsertion","Reinsertion permitted only through statutory process"],["Prior-recipient correction notice","Consumer requests after deletion/notation","CRA sends deletion/dispute information to designated prior users","No separate completion period in §1681i(d)","Employment lookback two years; other purposes six months"],["Freeze request","Consumer requests nationwide freeze","Place free freeze under federal process","Generally one business day electronic/phone; three business days mail","Restricts new-account access, not existing-account collection access"],["FDCPA validation dispute","Timely written dispute to covered debt collector","Collector validates or provides original-creditor information","Collection remains paused until response","Separate from CRA/furnisher investigation"]]},{"headers":["Source ID","Authority, issuer, literal URL, and exact scope","Status, access, and limits"],"index":5,"links":[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html","text":"Montana Code Annotated\n+9"},{"href":"https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301","text":"Legal Information Institute"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html","text":"Montana Code Annotated\n+4"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html","text":"Montana Code Annotated"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code\n+3"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code\n+4"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/","text":"U.S. Code\n+3"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+4"},{"href":"https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures?utm_source=chatgpt.com","text":"Federal Register"},{"href":"https://www.federalregister.gov/documents/2025/10/28/2025-19671/fair-credit-reporting-act-preemption-of-state-laws?utm_source=chatgpt.com","text":"Federal Register"},{"href":"https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html","text":"Justia Law\n+1"},{"href":"https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html","text":"Justia Law\n+1"},{"href":"https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html","text":"Justia Law\n+1"},{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html","text":"Justia Law\n+1"},{"href":"https://law.justia.com/cases/federal/appellate-courts/F3/282/1057/581850/","text":"Justia Law"},{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf","text":"Ninth Circuit Court of Appeals\n+1"},{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf","text":"Ninth Circuit Court of Appeals\n+2"},{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf","text":"Ninth Circuit Court of Appeals\n+1"},{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html","text":"Justia Law\n+1"},{"href":"https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf","text":"Supreme Court"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+3"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1692g/","text":"U.S. Code"}],"row_links":[[],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html","text":"Montana Code Annotated\n+9"}],[{"href":"https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301","text":"Legal Information Institute"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html","text":"Montana Code Annotated\n+4"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html","text":"Montana Code Annotated"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code\n+3"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code\n+4"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/","text":"U.S. Code\n+3"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+4"}],[{"href":"https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures?utm_source=chatgpt.com","text":"Federal Register"}],[{"href":"https://www.federalregister.gov/documents/2025/10/28/2025-19671/fair-credit-reporting-act-preemption-of-state-laws?utm_source=chatgpt.com","text":"Federal Register"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/cases/federal/appellate-courts/F3/282/1057/581850/","text":"Justia Law"}],[{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf","text":"Ninth Circuit Court of Appeals\n+1"}],[{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf","text":"Ninth Circuit Court of Appeals\n+2"}],[{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf","text":"Ninth Circuit Court of Appeals\n+1"}],[{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html","text":"Justia Law\n+1"}],[{"href":"https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf","text":"Supreme Court"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+3"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1692g/","text":"U.S. Code"}],[]],"rows":[["Source ID","Authority, issuer, literal URL, and exact scope","Status, access, and limits"],["S_MT-P10-S001","Montana Consumer Reporting Agencies Act, Montana Legislature. Definitions, §31-3-102: https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html; obsolete information, §31-3-112: https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html; compliance, §31-3-114: https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0140/0310-0030-0010-0140.html; file disclosure, §§31-3-122–125: corresponding section URLs 0220–0250; users, §31-3-131: section 0310; actions, §31-3-141: section 0410; violation, §31-3-153: section 0530.","Fresh direct official HTML read October 26, 2026 Pacific/UTC. Published MCA 2025; most operative clauses originated in 1975. No comprehensive post-2025 special-session audit. Internet-code disclaimer applies. \nMontana Code Annotated\n+9"],["S_MT-P10-S002","ARM 23.19.301—Disclosure Fees, Montana Department of Justice/Secretary of State. Current rule route was searched; secondary full text: https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301. Clauses (1)(a)–(b), fee sentence, deletion-notice sentence; history through 2006 transfer.","Fresh secondary full-text read; official direct body inaccessible. Currentness qualified. The secondary text states free disclosure in specified 30-day situations and an $8.50 maximum otherwise. \nLegal Information Institute"],["S_MT-P10-S003","Montana security-freeze statutes, Montana Legislature. Placement §30-14-1727: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html; CRA timing §1728: section 0280; lifting §1729: section 0290; removal §1730: section 0300; exceptions §1734: section 0340; fees §1735: section 0350.","Fresh direct official HTML read October 26, 2026. Enacted 2007 with selected later amendment. Federal preemption limits overlapping nationwide-freeze subjects. \nMontana Code Annotated\n+4"],["S_MT-P10-S004","Montana Consumer Data Privacy Act exemption, §30-14-2804(2)(k), Montana Legislature: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html. 2025 SB 297, Chapter 567: https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0567.pdf, relevant printed pp.10–11, zero-based PDF indices 9–10.","Fresh direct official HTML and official enacted-law PDF read; relevant PDF pages visually inspected. Exemption is limited to FCRA-regulated and authorized activity. \nMontana Code Annotated"],["S_MT-P10-S005","FCRA CRA provisions, U.S. House Office of Law Revision Counsel. Obsolescence §1681c: https://uscode.house.gov/us/usc/119-124/t15/s1681c/; file access §1681g: https://uscode.house.gov/us/usc/119-124/t15/s1681g/; disputes §1681i: https://uscode.house.gov/us/usc/119-124/t15/s1681i/; charges §1681j: https://uscode.house.gov/us/usc/119-124/t15/s1681j/.","Fresh direct official HTML read October 26, 2026. Text contains law through Public Law 119-124, October 15, 2026. Veteran medical and other special branches not developed here. \nU.S. Code\n+3"],["S_MT-P10-S006","FCRA furnisher duties, 15 U.S.C. §1681s-2: https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/. Relevant subsections (a)(1)–(5), (a)(7)–(8), (b), (c), and (d).","Fresh direct official HTML read October 26, 2026. Distinguishes public subsection (a) duties from CRA-notice-triggered subsection (b) investigation. \nU.S. Code\n+4"],["S_MT-P10-S007","FCRA relation to state law and federal freeze, 15 U.S.C. §§1681t and 1681c-1: https://uscode.house.gov/us/usc/119-124/t15/s1681t/; https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/.","Fresh direct official HTML read October 26, 2026. Relevant preemption clauses: §1681t(a), (b)(1)(B), (E), (F), and (J); freeze timing/exception clauses in §1681c-1. \nU.S. Code\n+3"],["S_MT-P10-S008","Regulation V furnisher provisions, CFPB/eCFR. Definitions §1022.41: https://www.consumerfinance.gov/rules-policy/regulations/1022/41; policies §1022.42: https://www.consumerfinance.gov/rules-policy/regulations/1022/42; direct disputes §1022.43: https://www.consumerfinance.gov/rules-policy/regulations/1022/43; Appendix E: https://www.consumerfinance.gov/rules-policy/regulations/1022/E.","Fresh direct official integrated-regulation read October 26, 2026. Current Regulation V page identifies the version current as of January 1, 2026. \nConsumer Financial Protection Bureau\n+4"],["S_MT-P10-S009","Federal disclosure-charge adjustment for 2026, CFPB, 90 FR 57888: https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures, printed pp.57888–57890.","Fresh official Federal Register HTML read October 26, 2026. Effective for 2026; sets $16 ceiling where a disclosure is not free. \nFederal Register"],["S_MT-P10-S010","FCRA Preemption of State Laws, CFPB interpretive rule, 90 FR 48710: https://www.federalregister.gov/documents/2025/10/28/2025-19671/fair-credit-reporting-act-preemption-of-state-laws, printed pp.48710–48715.","Fresh official Federal Register HTML read October 26, 2026. Applicable October 28, 2025; interpretive and nonbinding on courts; replaces withdrawn 2022 interpretation. \nFederal Register"],["S_MT-P10-S011","Curtis v. Citibank, 2011 MT 287, Montana Supreme Court full opinion reproduction: https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html.","Fresh full public opinion read. Secondary host of primary opinion; no paid subsequent-history citator. Used only for collection-versus-furnishing boundary. \nJustia Law\n+1"],["S_MT-P10-S012","Feller v. First Interstate Banksystem, Inc., 2013 MT 90: https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html.","Fresh full public opinion read. Montana Supreme Court furnisher-preemption decision. \nJustia Law\n+1"],["S_MT-P10-S013","Morrow v. Bank of America, N.A., 2014 MT 117: https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html.","Fresh full public opinion read. Distinguishes reporting-related damages from independent servicing theories. \nJustia Law\n+1"],["S_MT-P10-S014","Gorman v. Wolpoff & Abramson, No. 06-17226 (9th Cir. 2009): https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html.","Fresh full public opinion reproduction read. Secondary host of Ninth Circuit opinion. Relevant to CRA-trigger, reasonable investigation, and dispute notation. \nJustia Law\n+1"],["S_MT-P10-S015","Nelson v. Chase Manhattan Mortgage Corp., 282 F.3d 1057 (9th Cir. 2002): https://law.justia.com/cases/federal/appellate-courts/F3/282/1057/581850/.","Fresh full public opinion reproduction read. Recognizes private §1681s-2(b) path. \nJustia Law"],["S_MT-P10-S016","Gross v. CitiMortgage, Inc., 33 F.4th 1246 (9th Cir. 2022), official PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf; relevant printed pp.3 and 7–12, zero-based PDF indices 2 and 6–11.","Fresh complete official 13-page PDF read; relevant pages visually inspected. \nNinth Circuit Court of Appeals\n+1"],["S_MT-P10-S017","Shaw v. Experian Information Solutions, Inc., 891 F.3d 749 (9th Cir. 2018), official PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf; relevant printed pp.13–19, zero-based indices 12–18.","Fresh complete official 23-page PDF read; relevant pages visually inspected. \nNinth Circuit Court of Appeals\n+2"],["S_MT-P10-S018","Carvalho v. Equifax Information Services, LLC, 629 F.3d 876 (9th Cir. 2010), official PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf; relevant printed pp.18–22, zero-based indices 17–21.","Fresh complete official 26-page PDF read; relevant pages visually inspected. \nNinth Circuit Court of Appeals\n+1"],["S_MT-P10-S019","Aargon Agency, Inc. v. O’Laughlin, 70 F.4th 1224 (9th Cir. 2023): https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html.","Fresh full public opinion reproduction read. Preliminary-injunction posture and medical-debt context; no complete subsequent-history citator. \nJustia Law\n+1"],["S_MT-P10-S020","TransUnion LLC v. Ramirez, 594 U.S. 413 (2021), official Supreme Court PDF: https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf; syllabus printed pp.1–4/PDF indices 0–3; opinion standing analysis principally printed pp.5–27/indices 4–26.","Fresh complete official 53-page PDF parsed and relevant pages visually inspected. Used only for federal standing boundary. \nSupreme Court"],["S_MT-P10-S021","Current Regulation V and vacated 2025 medical rule status, CFPB. Regulation V: https://www.consumerfinance.gov/rules-policy/regulations/1022/; medical-rule archive: https://www.consumerfinance.gov/archive/newsroom/cfpb-finalizes-rule-to-remove-medical-bills-from-credit-reports/; compliance page: https://www.consumerfinance.gov/compliance/compliance-resources/other-applicable-requirements/fair-credit-reporting-act/.","Fresh official CFPB pages read October 26, 2026. Medical rule vacated July 11, 2025; detailed medical reporting remains excluded. \nConsumer Financial Protection Bureau\n+3"],["S_MT-P10-S022","FDCPA validation comparison, 15 U.S.C. §1692g, U.S. House OLRC: https://uscode.house.gov/us/usc/119-124/t15/s1692g/.","Fresh direct official HTML read October 26, 2026. Used only to distinguish collection validation from reporting disputes. \nU.S. Code"],["S_MT-P10-S023","Bounded Montana and federal search log for ordinary-debt furnishing statutes, current Montana CRA rules, final orders, paid/settled deletion, duplicate reporting, transfer-of-dispute duties, and current amendments.","Fresh bounded public-source searches October 26, 2026. No Montana-specific current final administrative order or controlling Montana decision resolving §§31-3-112/124 preemption and clock interaction was located. This row is provenance, not proof of absence."]]},{"headers":["Claim ID","Precise claim","Source and limits"],"index":6,"links":[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html","text":"Montana Code Annotated"},{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0140/0310-0030-0010-0140.html","text":"Montana Code Annotated"},{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0220/0310-0030-0010-0220.html","text":"Montana Code Annotated"},{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0230/0310-0030-0010-0230.html","text":"Montana Code Annotated"},{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html","text":"Montana Code Annotated"},{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html","text":"Montana Code Annotated"},{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html","text":"Montana Code Annotated"},{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html","text":"Montana Code Annotated\n+1"},{"href":"https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301","text":"Legal Information Institute"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html","text":"Montana Code Annotated"},{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html","text":"Montana Code Annotated\n+3"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/","text":"U.S. Code\n+1"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681t/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681t/","text":"U.S. Code\n+2"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code\n+2"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/42?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681c/","text":"U.S. Code"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code\n+2"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681g/","text":"U.S. Code\n+2"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/E?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+1"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/41?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+2"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code\n+2"},{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html","text":"Justia Law\n+1"},{"href":"https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html","text":"Justia Law"},{"href":"https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html","text":"Justia Law"},{"href":"https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html","text":"Justia Law"},{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html","text":"Justia Law\n+1"},{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf","text":"Ninth Circuit Court of Appeals"},{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf","text":"Ninth Circuit Court of Appeals"},{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf","text":"Ninth Circuit Court of Appeals"},{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html","text":"Justia Law\n+1"},{"href":"https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf","text":"Supreme Court"},{"href":"https://www.consumerfinance.gov/archive/newsroom/cfpb-finalizes-rule-to-remove-medical-bills-from-credit-reports/","text":"Consumer Financial Protection Bureau\n+1"},{"href":"https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures?utm_source=chatgpt.com","text":"Federal Register"},{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"}],"row_links":[[],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html","text":"Montana Code Annotated"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0140/0310-0030-0010-0140.html","text":"Montana Code Annotated"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0220/0310-0030-0010-0220.html","text":"Montana Code Annotated"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0230/0310-0030-0010-0230.html","text":"Montana Code Annotated"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html","text":"Montana Code Annotated"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html","text":"Montana Code Annotated"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0240/0310-0030-0010-0240.html","text":"Montana Code Annotated"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html","text":"Montana Code Annotated\n+1"}],[{"href":"https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301","text":"Legal Information Institute"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html","text":"Montana Code Annotated"}],[{"href":"https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html","text":"Montana Code Annotated\n+3"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/","text":"U.S. Code\n+1"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681t/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681t/","text":"U.S. Code\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code\n+2"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/42?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681c/","text":"U.S. Code"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681g/","text":"U.S. Code\n+2"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/E?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+1"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1022/41?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681i/","text":"U.S. Code\n+2"}],[{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html","text":"Justia Law\n+1"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html","text":"Justia Law"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html","text":"Justia Law"}],[{"href":"https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html","text":"Justia Law"}],[{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html","text":"Justia Law\n+1"}],[{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf","text":"Ninth Circuit Court of Appeals"}],[{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf","text":"Ninth Circuit Court of Appeals"}],[{"href":"https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf","text":"Ninth Circuit Court of Appeals"}],[{"href":"https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html","text":"Justia Law\n+1"}],[{"href":"https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf","text":"Supreme Court"}],[{"href":"https://www.consumerfinance.gov/archive/newsroom/cfpb-finalizes-rule-to-remove-medical-bills-from-credit-reports/","text":"Consumer Financial Protection Bureau\n+1"}],[{"href":"https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures?utm_source=chatgpt.com","text":"Federal Register"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/","text":"U.S. Code"}],[]],"rows":[["Claim ID","Precise claim","Source and limits"],["S_MT-P10-C001","Montana defines a CRA by regular assembly/evaluation of consumer information for third-party reports; transaction-and-experience-only reports are excluded.","S001, §31-3-102. High. \nMontana Code Annotated"],["S_MT-P10-C002","Montana CRAs must use reasonable procedures for maximum possible accuracy and retain user and source records.","S001, §31-3-114. High. \nMontana Code Annotated"],["S_MT-P10-C003","Montana consumers may request the nature and substance of file information, except medical information, and its sources.","S001, §31-3-122. High. \nMontana Code Annotated"],["S_MT-P10-C004","Montana file disclosure is statutorily structured around normal business hours, reasonable notice, in-person or qualified telephone delivery, trained staff, and a permitted companion.","S001, §31-3-123. High; old-format statute. \nMontana Code Annotated"],["S_MT-P10-C005","A direct Montana CRA dispute requires reinvestigation within a reasonable period unless frivolous or irrelevant.","S001, §31-3-124(1). High. \nMontana Code Annotated"],["S_MT-P10-C006","Inaccurate or unverifiable information must be deleted and recorded users notified; users must also delete.","S001, §31-3-124(1). High, subject to preemption/application analysis. \nMontana Code Annotated"],["S_MT-P10-C007","An unresolved Montana dispute permits a brief statement and dispute notation in later reports.","S001, §31-3-124(2)–(3). High. \nMontana Code Annotated"],["S_MT-P10-C008","Montana’s on-books ordinary collection/charge-off obsolescence period is seven years, but its triggering language differs from federal DOFD-plus-180.","S001, §31-3-112(4). High text; interaction unresolved. \nMontana Code Annotated\n+1"],["S_MT-P10-C009","ARM 23.19.301 presently appears to cap nonfree Montana file disclosure at $8.50 and requires specified free disclosures.","S002. Qualified currentness; official body inaccessible. \nLegal Information Institute"],["S_MT-P10-C010","Montana’s privacy act exempts credit-reporting activity only to the extent regulated by and authorized under FCRA.","S004, §30-14-2804(2)(k). High. \nMontana Code Annotated"],["S_MT-P10-C011","Montana’s freeze statutes remain printed with older timing and fee provisions.","S003. High for on-books text. \nMontana Code Annotated\n+3"],["S_MT-P10-C012","Federal law preempts overlapping state freeze subjects and provides free nationwide freezes; existing-account collection access remains permitted.","S007, §§1681t(b)(1)(J), 1681c-1. High. \nU.S. Code\n+1"],["S_MT-P10-C013","Montana’s pre-1996 CRA dispute and obsolescence provisions fall within textual grandfather exceptions to §1681t(b)(1)(B)/(E), to the extent unchanged.","S001, S007. High textual conclusion; exact application unresolved. \nU.S. Code"],["S_MT-P10-C014","State furnisher requirements are broadly preempted by §1681t(b)(1)(F), which contains no Montana exception.","S007; S012–S013. High. \nU.S. Code\n+2"],["S_MT-P10-C015","A CRA dispute generally requires a free reasonable reinvestigation within 30 days after receipt.","S005, §1681i(a)(1). High. \nU.S. Code"],["S_MT-P10-C016","The CRA may extend by up to 15 days upon receipt of relevant information, subject to statutory limitations.","S005, §1681i(a)(1)(B)–(C). High. \nU.S. Code"],["S_MT-P10-C017","CRA notice to the furnisher is due within five business days and must include relevant consumer information.","S005, §1681i(a)(2). High. \nU.S. Code"],["S_MT-P10-C018","Frivolous CRA dispute determinations require notice within five business days, reasons, and identification of needed information.","S005, §1681i(a)(3). High. \nU.S. Code"],["S_MT-P10-C019","Inaccurate, incomplete, or unverifiable items must be deleted or modified; reinsertion requires furnisher certification.","S005, §1681i(a)(5). High. \nU.S. Code"],["S_MT-P10-C020","Reinsertion notice and reinvestigation results are due within five business days under their respective triggers.","S005, §1681i(a)(5)–(6). High. \nU.S. Code"],["S_MT-P10-C021","Federal prior-recipient correction notice is consumer-requested, with two-year employment and six-month other-purpose lookbacks.","S005, §1681i(d). High. \nU.S. Code"],["S_MT-P10-C022","Resellers have a distinct five-business-day own-error review and 20-day correction or forwarding process.","S005, §1681i(f). High. \nU.S. Code"],["S_MT-P10-C023","Furnishers may not knowingly or unreasonably furnish inaccurate information and must promptly correct incomplete or inaccurate information.","S006, §1681s-2(a)(1)–(2). High; public enforcement for subsection (a). \nU.S. Code"],["S_MT-P10-C024","A furnisher receiving a direct consumer dispute may not continue furnishing without a dispute notation.","S006, §1681s-2(a)(3). High; public enforcement boundary. \nU.S. Code"],["S_MT-P10-C025","The furnisher must report the operative DOFD within 90 days after furnishing collection/charge-off information.","S006, §1681s-2(a)(5). High. \nU.S. Code"],["S_MT-P10-C026","CRA notice triggers the furnisher’s investigation, review, results, cross-CRA correction, and modify/delete/block duties under subsection (b).","S006, §1681s-2(b). High. \nU.S. Code"],["S_MT-P10-C027","The FCRA does not create a private action for subsection (a), while subsection (b) may support one after CRA notice.","S006; S014–S015. High. \nU.S. Code\n+2"],["S_MT-P10-C028","Regulation V requires reasonable written accuracy-and-integrity policies tailored to the furnisher and periodically updated.","S008, §1022.42. High. \nConsumer Financial Protection Bureau"],["S_MT-P10-C029","Direct disputes cover liability, terms, balances, status, payment dates/amounts, and other account information bearing on creditworthiness.","S008, §1022.43(a). High. \nConsumer Financial Protection Bureau"],["S_MT-P10-C030","Regulation V excludes specified identifying, inquiry, public-record, alert, other-furnisher, and CRO-generated disputes.","S008, §1022.43(b). High; exact exception facts required. \nConsumer Financial Protection Bureau"],["S_MT-P10-C031","A direct dispute must use a qualifying address and contain account identification, the disputed item, basis, and supporting information.","S008, §1022.43(c)–(d). High. \nConsumer Financial Protection Bureau"],["S_MT-P10-C032","A compliant direct dispute requires reasonable investigation, review, timely results, and CRA corrections if inaccurate.","S008, §1022.43(e). High. \nConsumer Financial Protection Bureau"],["S_MT-P10-C033","Frivolous or insufficient direct disputes require a five-business-day notice identifying reasons and needed information.","S008, §1022.43(f). High. \nConsumer Financial Protection Bureau"],["S_MT-P10-C034","The federal collection/charge-off reporting period runs seven years after a 180-day period beginning on the preceding DOFD.","S005, §1681c(c). High. \nU.S. Code"],["S_MT-P10-C035","Sale, placement, payment, or settlement does not reset the federal DOFD clock.","S005–S006; S008 Appendix E. High. \nU.S. Code\n+2"],["S_MT-P10-C036","Payment or settlement does not create an automatic deletion right; current balance and settlement status must nevertheless be accurate.","S005, S006, S017. High. \nU.S. Code\n+2"],["S_MT-P10-C037","Furnisher policies should address duplicate reporting, transfers, sale, re-aging, and service-provider data quality.","S008 Appendix E. High as regulatory-policy guidance, not a standalone coding mandate. \nConsumer Financial Protection Bureau\n+1"],["S_MT-P10-C038","No general law located requires automatic deletion of a transferor’s tradeline; the result must be accurate and nonmisleading.","S006, S008, S017–S018. Qualified bounded conclusion. \nConsumer Financial Protection Bureau\n+2"],["S_MT-P10-C039","A credit-report dispute does not automatically halt collection or extinguish the debt.","S005–S008; S022. High boundary. \nU.S. Code\n+2"],["S_MT-P10-C040","Neither CRA nor direct-furnisher dispute law universally requires production of a signed original contract.","S005–S008; S014, S018. High bounded conclusion. \nJustia Law\n+1"],["S_MT-P10-C041","Curtis distinguishes collection conduct from actual consumer-report furnishing for preemption purposes.","S011. High for holding and posture. \nJustia Law"],["S_MT-P10-C042","Feller broadly preempts Montana claims based on furnisher reporting and dispute-response duties.","S012. High. \nJustia Law"],["S_MT-P10-C043","Morrow preempts reporting-derived damages but preserves distinct servicing theories.","S013. High. \nJustia Law"],["S_MT-P10-C044","Gorman and Nelson establish the CRA-notice-triggered private furnisher route and reasonableness requirement.","S014–S015. High. \nJustia Law\n+1"],["S_MT-P10-C045","Gross allows liability where an objectively verifiable legal event makes reported liability patently incorrect and investigation may be unreasonable.","S016. High, fact-specific. \nNinth Circuit Court of Appeals"],["S_MT-P10-C046","Shaw confirms that accurate settled-for-less reporting is not automatically materially misleading.","S017. High, fact-specific. \nNinth Circuit Court of Appeals"],["S_MT-P10-C047","Carvalho requires inaccurate or misleading information and generally does not require CRAs to adjudicate unresolved legal disputes.","S018. High, read with Gross. \nNinth Circuit Court of Appeals"],["S_MT-P10-C048","Aargon gives §1681t(b)(1)(F) a narrower application in its state pre-reporting-notice context; the CFPB now advocates a broader interpretation.","S019, S010. High for stated positions; conflict unresolved judicially. \nJustia Law\n+1"],["S_MT-P10-C049","Federal damages plaintiffs need concrete injury under TransUnion; an uncommunicated inaccurate file does not automatically establish federal standing.","S020. High. \nSupreme Court"],["S_MT-P10-C050","The January 2025 CFPB medical-debt rule was vacated July 11, 2025 and is not operative.","S021. High; medical dossier excluded. \nConsumer Financial Protection Bureau\n+1"],["S_MT-P10-C051","The 2026 federal ceiling for a nonfree file disclosure is $16; free statutory disclosures remain free.","S009. High. \nFederal Register"],["S_MT-P10-C052","A financial institution generally must notify the customer before or within 30 days after furnishing negative information.","S006, §1681s-2(a)(7). High; financial institutions only. \nU.S. Code"],["S_MT-P10-C053","No named account, contract, tradeline, furnisher, report, score, settlement, dispute, or provider status was established.","All sources. High provenance limit."]]},{"headers":["Assigned issue","Status","Claim IDs","Exact remaining evidence or next action"],"index":7,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Assigned issue","Status","Claim IDs","Exact remaining evidence or next action"],["Montana CRA definition","Answered","C001","Apply actual business model and report purpose."],["Original-creditor transaction/experience exclusion","Answered textually","C001","Determine whether communication remained solely internal/experience data or entered a CRA report."],["Montana CRA accuracy procedures","Answered","C002","Actual CRA procedures and file held."],["Montana file access","Answered","C003–C004","Actual identity, request channel, and file held."],["Montana CRA dispute","Answered textually","C005–C007","Federal preemption and actual dispute sequence remain account-specific."],["Montana fixed dispute deadline","None in §31-3-124","C005","Federal 30-day deadline applies when FCRA covers the CRA."],["Montana deletion/user notice","Answered textually","C006","Exact federal grandfather/conflict application unresolved."],["Montana dispute statement","Answered","C007","Actual unresolved dispute and wording held."],["Montana obsolescence","Answered textually","C008","State trigger and federal harmonization need controlling interpretation."],["Montana disclosure fee","Qualified answered","C009, C051","Authenticate official current ARM body and resolve federal/state interaction."],["Montana adverse-action user notice","Answered as crossover","—","Full adverse-action/ECOA analysis excluded."],["Montana furnisher private action","Materially preempted/partial","C014, C042–C043","Claim-specific pleading, actor, and subject matter required."],["Montana CRA private action","Partial","C013","Full remedy, §1681h(e), standing, and limitation analysis later."],["Montana privacy act","Answered as exemption boundary","C010","Determine whether activity was actually FCRA-authorized."],["Montana freeze provisions","Answered on books","C011","Residual nonpreempted scope unresolved."],["Federal freeze timing/fees","Answered in core","C012","Actual request method and identity proof held."],["Existing-account collection despite freeze","Answered","C012","Actual account relationship required."],["CRA dispute timeline","Answered","C015–C020","Actual receipt and additional-information dates needed."],["CRA frivolous dispute","Answered","C018","Actual sufficiency and reasonableness held."],["CRA deletion/modification","Answered","C019","Actual investigation record held."],["Reinsertion","Answered","C019–C020","Actual certification and notice held."],["CRA result notice","Answered","C020","Actual completion and delivery held."],["Prior-recipient notification","Answered","C021","Consumer request and designated recipients needed."],["Federal consumer statement","Answered in core","—","Actual statement and CRA treatment held."],["Reseller dispute","Answered","C022","Actual reseller/source CRA relationship held."],["Furnisher accuracy","Answered","C023","Actual source records and furnished fields held."],["Furnisher dispute notation","Answered","C024","Direct dispute receipt and continuing furnishing held."],["DOFD reporting","Answered","C025","Actual delinquency and cure history held."],["CRA-routed furnisher investigation","Answered","C026–C027","Actual CRA notice and transmitted information required."],["Direct furnisher dispute","Answered","C029–C033","Correct address, content, and supporting evidence needed."],["CRO-generated direct dispute exclusion","Answered conditionally","C030","Actual authorship, entity status, and form source held."],["Direct dispute private right","No FCRA subsection (a) private route","C027","Other properly pleaded law remains claim-specific."],["Financial-institution negative notice","Answered","C052","Institution status and first negative furnishing date held."],["Furnisher policies/Appendix E","Answered as regulatory requirement/guidance","C028, C037","Actual written policies and examinations held."],["Federal file access","Answered","C003, C051","Actual report and request route held."],["Free annual report","Answered","C051","Voluntary extra free-report policies are not treated as law."],["Federal 2026 paid-disclosure ceiling","Answered","C051","Applies only absent a free entitlement."],["Federal reporting clock","Answered","C034–C035","Actual DOFD and exceptional-report context needed."],["Montana/federal clock interaction","Unresolved in part","C008, C013, C034","Controlling Montana construction not located."],["Sale/assignment and clock","Answered federally","C035","Actual DOFD still required."],["Payment/settlement and clock","Answered federally","C035","Actual cure history and account terms held."],["Paid account status","Answered in principle","C036","Actual payment application and remaining liability held."],["Settled account deletion","No automatic right established","C036, C046","Contractual pay-for-delete promise, if any, unsupplied."],["Accurate settled-for-less notation","Answered as fact-dependent","C046","Actual agreement and report fields required."],["Duplicate tradelines","Partial","C037–C038","Actual furnishing codes, owner, and balances held."],["Transferred-account correction","Answered as accuracy/policy issue","C037–C038","No universal mandated coding identified."],["Transfer of prior dispute file","Unresolved generally","C037","Contract, knowledge, and later CRA notice required."],["Original-creditor identity in ordinary report","Partial","C003, C029","No universal assignment-chain disclosure established."],["CRA dispute versus FDCPA validation","Answered as separate processes","C039–C040","Full FDCPA pass remains separate."],["FCRA collection pause","No automatic pause","C039","Independent FDCPA, contract, bankruptcy, or court order could differ."],["Mandatory original contract production","No universal requirement","C040","Litigation proof and special-sector law later."],["Montana preemption","Answered structurally","C013–C014, C041–C048","Claim-specific application and later precedent remain."],["Current CFPB preemption interpretation","Answered","C048","Nonbinding; future withdrawal or judicial rejection possible."],["Federal standing","Answered as boundary","C049","Full damages/remedies analysis excluded."],["Current medical-rule status","Answered only to prevent overbreadth","C050","Medical reporting dossier remains excluded."],["Identity-theft blocking","Excluded","—","Separate §1681c-2 and Montana restoration pass."],["Fraud alerts","Excluded except freeze comparison","—","Separate identity-theft pass."],["Tenant/employment/insurance screening","Excluded","—","Separate specialty-reporting passes."],["Mortgage/repo/child-support/tax/student debt","Excluded","—","Sector-specific passes."],["Bankruptcy reporting","Excluded beyond ordinary-clock distinction","—","Separate bankruptcy/reporting pass."],["Litigation proof/admissibility","Excluded","—","Collection-litigation/evidence pass."],["Full private/public remedies","Excluded except threshold boundaries","C027, C049","Separate remedies and limitations pass."],["Local/tribal law","Excluded","—","Separate jurisdictional investigation."],["Named account/provider compliance","Unresolved","C053","Requires actual report, furnisher records, notices, and status."],["Comprehensive post-2025 Montana currentness","Partial","All state claims","Later special-session, rulemaking, and full citator check."]]}],"claims":[{"claim_id":"S_MT-P10-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C001","Precise claim":"Montana defines a CRA by regular assembly/evaluation of consumer information for third-party reports; transaction-and-experience-only reports are excluded.","Source and limits":"S001, §31-3-102. High. \nMontana Code Annotated"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C002","Precise claim":"Montana CRAs must use reasonable procedures for maximum possible accuracy and retain user and source records.","Source and limits":"S001, §31-3-114. High. \nMontana Code Annotated"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C003","Precise claim":"Montana consumers may request the nature and substance of file information, except medical information, and its sources.","Source and limits":"S001, §31-3-122. High. \nMontana Code Annotated"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C004","Precise claim":"Montana file disclosure is statutorily structured around normal business hours, reasonable notice, in-person or qualified telephone delivery, trained staff, and a permitted companion.","Source and limits":"S001, §31-3-123. High; old-format statute. \nMontana Code Annotated"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C005","Precise claim":"A direct Montana CRA dispute requires reinvestigation within a reasonable period unless frivolous or irrelevant.","Source and limits":"S001, §31-3-124(1). High. \nMontana Code Annotated"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C006","Precise claim":"Inaccurate or unverifiable information must be deleted and recorded users notified; users must also delete.","Source and limits":"S001, §31-3-124(1). High, subject to preemption/application analysis. \nMontana Code Annotated"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C007","Precise claim":"An unresolved Montana dispute permits a brief statement and dispute notation in later reports.","Source and limits":"S001, §31-3-124(2)–(3). High. \nMontana Code Annotated"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C008","Precise claim":"Montana’s on-books ordinary collection/charge-off obsolescence period is seven years, but its triggering language differs from federal DOFD-plus-180.","Source and limits":"S001, §31-3-112(4). High text; interaction unresolved. \nMontana Code Annotated\n+1"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C009","Precise claim":"ARM 23.19.301 presently appears to cap nonfree Montana file disclosure at $8.50 and requires specified free disclosures.","Source and limits":"S002. Qualified currentness; official body inaccessible. \nLegal Information Institute"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C010","Precise claim":"Montana’s privacy act exempts credit-reporting activity only to the extent regulated by and authorized under FCRA.","Source and limits":"S004, §30-14-2804(2)(k). High. \nMontana Code Annotated"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C011","Precise claim":"Montana’s freeze statutes remain printed with older timing and fee provisions.","Source and limits":"S003. High for on-books text. \nMontana Code Annotated\n+3"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C012","Precise claim":"Federal law preempts overlapping state freeze subjects and provides free nationwide freezes; existing-account collection access remains permitted.","Source and limits":"S007, §§1681t(b)(1)(J), 1681c-1. High. \nU.S. Code\n+1"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C013","Precise claim":"Montana’s pre-1996 CRA dispute and obsolescence provisions fall within textual grandfather exceptions to §1681t(b)(1)(B)/(E), to the extent unchanged.","Source and limits":"S001, S007. High textual conclusion; exact application unresolved. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C014","Precise claim":"State furnisher requirements are broadly preempted by §1681t(b)(1)(F), which contains no Montana exception.","Source and limits":"S007; S012–S013. High. \nU.S. Code\n+2"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C015","Precise claim":"A CRA dispute generally requires a free reasonable reinvestigation within 30 days after receipt.","Source and limits":"S005, §1681i(a)(1). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C016","Precise claim":"The CRA may extend by up to 15 days upon receipt of relevant information, subject to statutory limitations.","Source and limits":"S005, §1681i(a)(1)(B)–(C). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C017","Precise claim":"CRA notice to the furnisher is due within five business days and must include relevant consumer information.","Source and limits":"S005, §1681i(a)(2). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C018","Precise claim":"Frivolous CRA dispute determinations require notice within five business days, reasons, and identification of needed information.","Source and limits":"S005, §1681i(a)(3). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C019","Precise claim":"Inaccurate, incomplete, or unverifiable items must be deleted or modified; reinsertion requires furnisher certification.","Source and limits":"S005, §1681i(a)(5). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C020","Precise claim":"Reinsertion notice and reinvestigation results are due within five business days under their respective triggers.","Source and limits":"S005, §1681i(a)(5)–(6). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C021","Precise claim":"Federal prior-recipient correction notice is consumer-requested, with two-year employment and six-month other-purpose lookbacks.","Source and limits":"S005, §1681i(d). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C022","Precise claim":"Resellers have a distinct five-business-day own-error review and 20-day correction or forwarding process.","Source and limits":"S005, §1681i(f). High. \nU.S. Code"},"coordinator_verification_status":"bounded_material_predicate_correction_pending_UNSENT","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority.","coordinator_finding_ids":["S_MT-P10-Q003"]},{"claim_id":"S_MT-P10-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C023","Precise claim":"Furnishers may not knowingly or unreasonably furnish inaccurate information and must promptly correct incomplete or inaccurate information.","Source and limits":"S006, §1681s-2(a)(1)–(2). High; public enforcement for subsection (a). \nU.S. Code"},"coordinator_verification_status":"bounded_material_predicate_correction_pending_UNSENT","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority.","coordinator_finding_ids":["S_MT-P10-Q004"]},{"claim_id":"S_MT-P10-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C024","Precise claim":"A furnisher receiving a direct consumer dispute may not continue furnishing without a dispute notation.","Source and limits":"S006, §1681s-2(a)(3). High; public enforcement boundary. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C025","Precise claim":"The furnisher must report the operative DOFD within 90 days after furnishing collection/charge-off information.","Source and limits":"S006, §1681s-2(a)(5). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C026","Precise claim":"CRA notice triggers the furnisher’s investigation, review, results, cross-CRA correction, and modify/delete/block duties under subsection (b).","Source and limits":"S006, §1681s-2(b). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C027","Precise claim":"The FCRA does not create a private action for subsection (a), while subsection (b) may support one after CRA notice.","Source and limits":"S006; S014–S015. High. \nU.S. Code\n+2"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C028","Precise claim":"Regulation V requires reasonable written accuracy-and-integrity policies tailored to the furnisher and periodically updated.","Source and limits":"S008, §1022.42. High. \nConsumer Financial Protection Bureau"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C029","Precise claim":"Direct disputes cover liability, terms, balances, status, payment dates/amounts, and other account information bearing on creditworthiness.","Source and limits":"S008, §1022.43(a). High. \nConsumer Financial Protection Bureau"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C030","Precise claim":"Regulation V excludes specified identifying, inquiry, public-record, alert, other-furnisher, and CRO-generated disputes.","Source and limits":"S008, §1022.43(b). High; exact exception facts required. \nConsumer Financial Protection Bureau"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C031","Precise claim":"A direct dispute must use a qualifying address and contain account identification, the disputed item, basis, and supporting information.","Source and limits":"S008, §1022.43(c)–(d). High. \nConsumer Financial Protection Bureau"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C032","Precise claim":"A compliant direct dispute requires reasonable investigation, review, timely results, and CRA corrections if inaccurate.","Source and limits":"S008, §1022.43(e). High. \nConsumer Financial Protection Bureau"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C033","Precise claim":"Frivolous or insufficient direct disputes require a five-business-day notice identifying reasons and needed information.","Source and limits":"S008, §1022.43(f). High. \nConsumer Financial Protection Bureau"},"coordinator_verification_status":"bounded_material_predicate_correction_pending_UNSENT","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority.","coordinator_finding_ids":["S_MT-P10-Q005"]},{"claim_id":"S_MT-P10-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C034","Precise claim":"The federal collection/charge-off reporting period runs seven years after a 180-day period beginning on the preceding DOFD.","Source and limits":"S005, §1681c(c). High. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C035","Precise claim":"Sale, placement, payment, or settlement does not reset the federal DOFD clock.","Source and limits":"S005–S006; S008 Appendix E. High. \nU.S. Code\n+2"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C036","Precise claim":"Payment or settlement does not create an automatic deletion right; current balance and settlement status must nevertheless be accurate.","Source and limits":"S005, S006, S017. High. \nU.S. Code\n+2"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C037","Precise claim":"Furnisher policies should address duplicate reporting, transfers, sale, re-aging, and service-provider data quality.","Source and limits":"S008 Appendix E. High as regulatory-policy guidance, not a standalone coding mandate. \nConsumer Financial Protection Bureau\n+1"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C038","Precise claim":"No general law located requires automatic deletion of a transferor’s tradeline; the result must be accurate and nonmisleading.","Source and limits":"S006, S008, S017–S018. Qualified bounded conclusion. \nConsumer Financial Protection Bureau\n+2"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C039","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C039","Precise claim":"A credit-report dispute does not automatically halt collection or extinguish the debt.","Source and limits":"S005–S008; S022. High boundary. \nU.S. Code\n+2"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C040","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C040","Precise claim":"Neither CRA nor direct-furnisher dispute law universally requires production of a signed original contract.","Source and limits":"S005–S008; S014, S018. High bounded conclusion. \nJustia Law\n+1"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C041","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C041","Precise claim":"Curtis distinguishes collection conduct from actual consumer-report furnishing for preemption purposes.","Source and limits":"S011. High for holding and posture. \nJustia Law"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C042","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C042","Precise claim":"Feller broadly preempts Montana claims based on furnisher reporting and dispute-response duties.","Source and limits":"S012. High. \nJustia Law"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C043","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C043","Precise claim":"Morrow preempts reporting-derived damages but preserves distinct servicing theories.","Source and limits":"S013. High. \nJustia Law"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C044","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C044","Precise claim":"Gorman and Nelson establish the CRA-notice-triggered private furnisher route and reasonableness requirement.","Source and limits":"S014–S015. High. \nJustia Law\n+1"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C045","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C045","Precise claim":"Gross allows liability where an objectively verifiable legal event makes reported liability patently incorrect and investigation may be unreasonable.","Source and limits":"S016. High, fact-specific. \nNinth Circuit Court of Appeals"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C046","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C046","Precise claim":"Shaw confirms that accurate settled-for-less reporting is not automatically materially misleading.","Source and limits":"S017. High, fact-specific. \nNinth Circuit Court of Appeals"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C047","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C047","Precise claim":"Carvalho requires inaccurate or misleading information and generally does not require CRAs to adjudicate unresolved legal disputes.","Source and limits":"S018. High, read with Gross. \nNinth Circuit Court of Appeals"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C048","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C048","Precise claim":"Aargon gives §1681t(b)(1)(F) a narrower application in its state pre-reporting-notice context; the CFPB now advocates a broader interpretation.","Source and limits":"S019, S010. High for stated positions; conflict unresolved judicially. \nJustia Law\n+1"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C049","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C049","Precise claim":"Federal damages plaintiffs need concrete injury under TransUnion; an uncommunicated inaccurate file does not automatically establish federal standing.","Source and limits":"S020. High. \nSupreme Court"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C050","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C050","Precise claim":"The January 2025 CFPB medical-debt rule was vacated July 11, 2025 and is not operative.","Source and limits":"S021. High; medical dossier excluded. \nConsumer Financial Protection Bureau\n+1"},"coordinator_verification_status":"held_unreopened_authority_synthesis_currentness_or_application","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C051","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C051","Precise claim":"The 2026 federal ceiling for a nonfree file disclosure is $16; free statutory disclosures remain free.","Source and limits":"S009. High. \nFederal Register"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C052","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C052","Precise claim":"A financial institution generally must notify the customer before or within 30 days after furnishing negative information.","Source and limits":"S006, §1681s-2(a)(7). High; financial institutions only. \nU.S. Code"},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."},{"claim_id":"S_MT-P10-C053","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_MT-P10-C053","Precise claim":"No named account, contract, tradeline, furnisher, report, score, settlement, dispute, or provider status was established.","Source and limits":"All sources. High provenance limit."},"coordinator_verification_status":"selected_text_matches_conditions_and_scope_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Whole atomic claim read; literal assertion may require linked narrative qualification. Case/currentness/private-right/preemption/actual application not accepted from unreviewed authority."}],"sources":[{"source_id":"S_MT-P10-S001","urls":["https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html","https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html","https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0140/0310-0030-0010-0140.html"],"researcher_record":{"Source ID":"S_MT-P10-S001","Authority, issuer, literal URL, and exact scope":"Montana Consumer Reporting Agencies Act, Montana Legislature. Definitions, §31-3-102: https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0020/0310-0030-0010-0020.html; obsolete information, §31-3-112: https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0120/0310-0030-0010-0120.html; compliance, §31-3-114: https://mca.legmt.gov/bills/mca/title_0310/chapter_0030/part_0010/section_0140/0310-0030-0010-0140.html; file disclosure, §§31-3-122–125: corresponding section URLs 0220–0250; users, §31-3-131: section 0310; actions, §31-3-141: section 0410; violation, §31-3-153: section 0530.","Status, access, and limits":"Fresh direct official HTML read October 26, 2026 Pacific/UTC. Published MCA 2025; most operative clauses originated in 1975. No comprehensive post-2025 special-session audit. Internet-code disclaimer applies. \nMontana Code Annotated\n+9"},"coordinator_verification_status":"selected_primary_text_compared_scope_and_version_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S002","urls":["https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301"],"researcher_record":{"Source ID":"S_MT-P10-S002","Authority, issuer, literal URL, and exact scope":"ARM 23.19.301—Disclosure Fees, Montana Department of Justice/Secretary of State. Current rule route was searched; secondary full text: https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-23.19.301. Clauses (1)(a)–(b), fee sentence, deletion-notice sentence; history through 2006 transfer.","Status, access, and limits":"Fresh secondary full-text read; official direct body inaccessible. Currentness qualified. The secondary text states free disclosure in specified 30-day situations and an $8.50 maximum otherwise. \nLegal Information Institute"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S003","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html"],"researcher_record":{"Source ID":"S_MT-P10-S003","Authority, issuer, literal URL, and exact scope":"Montana security-freeze statutes, Montana Legislature. Placement §30-14-1727: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0270/0300-0140-0170-0270.html; CRA timing §1728: section 0280; lifting §1729: section 0290; removal §1730: section 0300; exceptions §1734: section 0340; fees §1735: section 0350.","Status, access, and limits":"Fresh direct official HTML read October 26, 2026. Enacted 2007 with selected later amendment. Federal preemption limits overlapping nationwide-freeze subjects. \nMontana Code Annotated\n+4"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S004","urls":["https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html","https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0567.pdf"],"researcher_record":{"Source ID":"S_MT-P10-S004","Authority, issuer, literal URL, and exact scope":"Montana Consumer Data Privacy Act exemption, §30-14-2804(2)(k), Montana Legislature: https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0280/section_0040/0300-0140-0280-0040.html. 2025 SB 297, Chapter 567: https://archive.legmt.gov/content/Sessions/69th/Contractor_index/CH0567.pdf, relevant printed pp.10–11, zero-based PDF indices 9–10.","Status, access, and limits":"Fresh direct official HTML and official enacted-law PDF read; relevant PDF pages visually inspected. Exemption is limited to FCRA-regulated and authorized activity. \nMontana Code Annotated"},"coordinator_verification_status":"selected_primary_text_compared_scope_and_version_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S005","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1681c/","https://uscode.house.gov/us/usc/119-124/t15/s1681g/","https://uscode.house.gov/us/usc/119-124/t15/s1681i/","https://uscode.house.gov/us/usc/119-124/t15/s1681j/"],"researcher_record":{"Source ID":"S_MT-P10-S005","Authority, issuer, literal URL, and exact scope":"FCRA CRA provisions, U.S. House Office of Law Revision Counsel. Obsolescence §1681c: https://uscode.house.gov/us/usc/119-124/t15/s1681c/; file access §1681g: https://uscode.house.gov/us/usc/119-124/t15/s1681g/; disputes §1681i: https://uscode.house.gov/us/usc/119-124/t15/s1681i/; charges §1681j: https://uscode.house.gov/us/usc/119-124/t15/s1681j/.","Status, access, and limits":"Fresh direct official HTML read October 26, 2026. Text contains law through Public Law 119-124, October 15, 2026. Veteran medical and other special branches not developed here. \nU.S. Code\n+3"},"coordinator_verification_status":"selected_primary_text_compared_scope_and_version_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S006","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/"],"researcher_record":{"Source ID":"S_MT-P10-S006","Authority, issuer, literal URL, and exact scope":"FCRA furnisher duties, 15 U.S.C. §1681s-2: https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/. Relevant subsections (a)(1)–(5), (a)(7)–(8), (b), (c), and (d).","Status, access, and limits":"Fresh direct official HTML read October 26, 2026. Distinguishes public subsection (a) duties from CRA-notice-triggered subsection (b) investigation. \nU.S. Code\n+4"},"coordinator_verification_status":"selected_primary_text_compared_scope_and_version_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S007","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1681t/","https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/"],"researcher_record":{"Source ID":"S_MT-P10-S007","Authority, issuer, literal URL, and exact scope":"FCRA relation to state law and federal freeze, 15 U.S.C. §§1681t and 1681c-1: https://uscode.house.gov/us/usc/119-124/t15/s1681t/; https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/.","Status, access, and limits":"Fresh direct official HTML read October 26, 2026. Relevant preemption clauses: §1681t(a), (b)(1)(B), (E), (F), and (J); freeze timing/exception clauses in §1681c-1. \nU.S. Code\n+3"},"coordinator_verification_status":"selected_primary_text_compared_scope_and_version_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S008","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1022/41","https://www.consumerfinance.gov/rules-policy/regulations/1022/42","https://www.consumerfinance.gov/rules-policy/regulations/1022/43","https://www.consumerfinance.gov/rules-policy/regulations/1022/E","https://www.consumerfinance.gov/rules-policy/regulations/1022/43?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P10-S008","Authority, issuer, literal URL, and exact scope":"Regulation V furnisher provisions, CFPB/eCFR. Definitions §1022.41: https://www.consumerfinance.gov/rules-policy/regulations/1022/41; policies §1022.42: https://www.consumerfinance.gov/rules-policy/regulations/1022/42; direct disputes §1022.43: https://www.consumerfinance.gov/rules-policy/regulations/1022/43; Appendix E: https://www.consumerfinance.gov/rules-policy/regulations/1022/E.","Status, access, and limits":"Fresh direct official integrated-regulation read October 26, 2026. Current Regulation V page identifies the version current as of January 1, 2026. \nConsumer Financial Protection Bureau\n+4"},"coordinator_verification_status":"selected_primary_text_compared_scope_and_version_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S009","urls":["https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures","https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P10-S009","Authority, issuer, literal URL, and exact scope":"Federal disclosure-charge adjustment for 2026, CFPB, 90 FR 57888: https://www.federalregister.gov/documents/2025/12/15/2025-22772/fair-credit-reporting-act-disclosures, printed pp.57888–57890.","Status, access, and limits":"Fresh official Federal Register HTML read October 26, 2026. Effective for 2026; sets $16 ceiling where a disclosure is not free. \nFederal Register"},"coordinator_verification_status":"selected_primary_text_compared_scope_and_version_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S010","urls":["https://www.federalregister.gov/documents/2025/10/28/2025-19671/fair-credit-reporting-act-preemption-of-state-laws","https://www.federalregister.gov/documents/2025/10/28/2025-19671/fair-credit-reporting-act-preemption-of-state-laws?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P10-S010","Authority, issuer, literal URL, and exact scope":"FCRA Preemption of State Laws, CFPB interpretive rule, 90 FR 48710: https://www.federalregister.gov/documents/2025/10/28/2025-19671/fair-credit-reporting-act-preemption-of-state-laws, printed pp.48710–48715.","Status, access, and limits":"Fresh official Federal Register HTML read October 26, 2026. Applicable October 28, 2025; interpretive and nonbinding on courts; replaces withdrawn 2022 interpretation. \nFederal Register"},"coordinator_verification_status":"selected_primary_text_compared_scope_and_version_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S011","urls":["https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html"],"researcher_record":{"Source ID":"S_MT-P10-S011","Authority, issuer, literal URL, and exact scope":"Curtis v. Citibank, 2011 MT 287, Montana Supreme Court full opinion reproduction: https://law.justia.com/cases/montana/supreme-court/2011/da-11-0188.html.","Status, access, and limits":"Fresh full public opinion read. Secondary host of primary opinion; no paid subsequent-history citator. Used only for collection-versus-furnishing boundary. \nJustia Law\n+1"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S012","urls":["https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html"],"researcher_record":{"Source ID":"S_MT-P10-S012","Authority, issuer, literal URL, and exact scope":"Feller v. First Interstate Banksystem, Inc., 2013 MT 90: https://law.justia.com/cases/montana/supreme-court/2013/da-12-0406.html.","Status, access, and limits":"Fresh full public opinion read. Montana Supreme Court furnisher-preemption decision. \nJustia Law\n+1"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S013","urls":["https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html"],"researcher_record":{"Source ID":"S_MT-P10-S013","Authority, issuer, literal URL, and exact scope":"Morrow v. Bank of America, N.A., 2014 MT 117: https://law.justia.com/cases/montana/supreme-court/2014/da-13-0241.html.","Status, access, and limits":"Fresh full public opinion read. Distinguishes reporting-related damages from independent servicing theories. \nJustia Law\n+1"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S014","urls":["https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html"],"researcher_record":{"Source ID":"S_MT-P10-S014","Authority, issuer, literal URL, and exact scope":"Gorman v. Wolpoff & Abramson, No. 06-17226 (9th Cir. 2009): https://law.justia.com/cases/federal/appellate-courts/ca9/06-17226/06-17226-2011-02-25.html.","Status, access, and limits":"Fresh full public opinion reproduction read. Secondary host of Ninth Circuit opinion. Relevant to CRA-trigger, reasonable investigation, and dispute notation. \nJustia Law\n+1"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S015","urls":["https://law.justia.com/cases/federal/appellate-courts/F3/282/1057/581850/"],"researcher_record":{"Source ID":"S_MT-P10-S015","Authority, issuer, literal URL, and exact scope":"Nelson v. Chase Manhattan Mortgage Corp., 282 F.3d 1057 (9th Cir. 2002): https://law.justia.com/cases/federal/appellate-courts/F3/282/1057/581850/.","Status, access, and limits":"Fresh full public opinion reproduction read. Recognizes private §1681s-2(b) path. \nJustia Law"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S016","urls":["https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf"],"researcher_record":{"Source ID":"S_MT-P10-S016","Authority, issuer, literal URL, and exact scope":"Gross v. CitiMortgage, Inc., 33 F.4th 1246 (9th Cir. 2022), official PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/16/20-17160.pdf; relevant printed pp.3 and 7–12, zero-based PDF indices 2 and 6–11.","Status, access, and limits":"Fresh complete official 13-page PDF read; relevant pages visually inspected. \nNinth Circuit Court of Appeals\n+1"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S017","urls":["https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf"],"researcher_record":{"Source ID":"S_MT-P10-S017","Authority, issuer, literal URL, and exact scope":"Shaw v. Experian Information Solutions, Inc., 891 F.3d 749 (9th Cir. 2018), official PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2018/05/29/16-56587.pdf; relevant printed pp.13–19, zero-based indices 12–18.","Status, access, and limits":"Fresh complete official 23-page PDF read; relevant pages visually inspected. \nNinth Circuit Court of Appeals\n+2"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S018","urls":["https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf"],"researcher_record":{"Source ID":"S_MT-P10-S018","Authority, issuer, literal URL, and exact scope":"Carvalho v. Equifax Information Services, LLC, 629 F.3d 876 (9th Cir. 2010), official PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2010/12/16/09-15030.pdf; relevant printed pp.18–22, zero-based indices 17–21.","Status, access, and limits":"Fresh complete official 26-page PDF read; relevant pages visually inspected. \nNinth Circuit Court of Appeals\n+1"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S019","urls":["https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html"],"researcher_record":{"Source ID":"S_MT-P10-S019","Authority, issuer, literal URL, and exact scope":"Aargon Agency, Inc. v. O’Laughlin, 70 F.4th 1224 (9th Cir. 2023): https://law.justia.com/cases/federal/appellate-courts/ca9/22-15352/22-15352-2023-06-15.html.","Status, access, and limits":"Fresh full public opinion reproduction read. Preliminary-injunction posture and medical-debt context; no complete subsequent-history citator. \nJustia Law\n+1"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S020","urls":["https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf"],"researcher_record":{"Source ID":"S_MT-P10-S020","Authority, issuer, literal URL, and exact scope":"TransUnion LLC v. Ramirez, 594 U.S. 413 (2021), official Supreme Court PDF: https://www.supremecourt.gov/opinions/20pdf/20-297_4g25.pdf; syllabus printed pp.1–4/PDF indices 0–3; opinion standing analysis principally printed pp.5–27/indices 4–26.","Status, access, and limits":"Fresh complete official 53-page PDF parsed and relevant pages visually inspected. Used only for federal standing boundary. \nSupreme Court"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S021","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1022/","https://www.consumerfinance.gov/archive/newsroom/cfpb-finalizes-rule-to-remove-medical-bills-from-credit-reports/","https://www.consumerfinance.gov/compliance/compliance-resources/other-applicable-requirements/fair-credit-reporting-act/","https://www.consumerfinance.gov/rules-policy/regulations/1022/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_MT-P10-S021","Authority, issuer, literal URL, and exact scope":"Current Regulation V and vacated 2025 medical rule status, CFPB. Regulation V: https://www.consumerfinance.gov/rules-policy/regulations/1022/; medical-rule archive: https://www.consumerfinance.gov/archive/newsroom/cfpb-finalizes-rule-to-remove-medical-bills-from-credit-reports/; compliance page: https://www.consumerfinance.gov/compliance/compliance-resources/other-applicable-requirements/fair-credit-reporting-act/.","Status, access, and limits":"Fresh official CFPB pages read October 26, 2026. Medical rule vacated July 11, 2025; detailed medical reporting remains excluded. \nConsumer Financial Protection Bureau\n+3"},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S022","urls":["https://uscode.house.gov/us/usc/119-124/t15/s1692g/"],"researcher_record":{"Source ID":"S_MT-P10-S022","Authority, issuer, literal URL, and exact scope":"FDCPA validation comparison, 15 U.S.C. §1692g, U.S. House OLRC: https://uscode.house.gov/us/usc/119-124/t15/s1692g/.","Status, access, and limits":"Fresh direct official HTML read October 26, 2026. Used only to distinguish collection validation from reporting disputes. \nU.S. Code"},"coordinator_verification_status":"dated_MT9_GPO_primary_reuse_OLRC_original_and_print_currency_held","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."},{"source_id":"S_MT-P10-S023","urls":[],"researcher_record":{"Source ID":"S_MT-P10-S023","Authority, issuer, literal URL, and exact scope":"Bounded Montana and federal search log for ordinary-debt furnishing statutes, current Montana CRA rules, final orders, paid/settled deletion, duplicate reporting, transfer-of-dispute duties, and current amendments.","Status, access, and limits":"Fresh bounded public-source searches October 26, 2026. No Montana-specific current final administrative order or controlling Montana decision resolving §§31-3-112/124 preemption and clock interaction was located. This row is provenance, not proof of absence."},"coordinator_verification_status":"held_not_freshly_reopened_this_scoped_review","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_check_evidence":"[internal evidence reference]","coordinator_scope_note":"Exact selected read map controls. Source selection is not full-source/whole-claim acceptance; original secondary, visual and all source/application holds retained."}],"coverage":[{"topic":"Montana CRA definition","researcher_record":{"Assigned issue":"Montana CRA definition","Status":"Answered","Claim IDs":"C001","Exact remaining evidence or next action":"Apply actual business model and report purpose."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Original-creditor transaction/experience exclusion","researcher_record":{"Assigned issue":"Original-creditor transaction/experience exclusion","Status":"Answered textually","Claim IDs":"C001","Exact remaining evidence or next action":"Determine whether communication remained solely internal/experience data or entered a CRA report."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana CRA accuracy procedures","researcher_record":{"Assigned issue":"Montana CRA accuracy procedures","Status":"Answered","Claim IDs":"C002","Exact remaining evidence or next action":"Actual CRA procedures and file held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana file access","researcher_record":{"Assigned issue":"Montana file access","Status":"Answered","Claim IDs":"C003–C004","Exact remaining evidence or next action":"Actual identity, request channel, and file held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana CRA dispute","researcher_record":{"Assigned issue":"Montana CRA dispute","Status":"Answered textually","Claim IDs":"C005–C007","Exact remaining evidence or next action":"Federal preemption and actual dispute sequence remain account-specific."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana fixed dispute deadline","researcher_record":{"Assigned issue":"Montana fixed dispute deadline","Status":"None in §31-3-124","Claim IDs":"C005","Exact remaining evidence or next action":"Federal 30-day deadline applies when FCRA covers the CRA."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana deletion/user notice","researcher_record":{"Assigned issue":"Montana deletion/user notice","Status":"Answered textually","Claim IDs":"C006","Exact remaining evidence or next action":"Exact federal grandfather/conflict application unresolved."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana dispute statement","researcher_record":{"Assigned issue":"Montana dispute statement","Status":"Answered","Claim IDs":"C007","Exact remaining evidence or next action":"Actual unresolved dispute and wording held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana obsolescence","researcher_record":{"Assigned issue":"Montana obsolescence","Status":"Answered textually","Claim IDs":"C008","Exact remaining evidence or next action":"State trigger and federal harmonization need controlling interpretation."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana disclosure fee","researcher_record":{"Assigned issue":"Montana disclosure fee","Status":"Qualified answered","Claim IDs":"C009, C051","Exact remaining evidence or next action":"Authenticate official current ARM body and resolve federal/state interaction."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana adverse-action user notice","researcher_record":{"Assigned issue":"Montana adverse-action user notice","Status":"Answered as crossover","Claim IDs":"—","Exact remaining evidence or next action":"Full adverse-action/ECOA analysis excluded."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana furnisher private action","researcher_record":{"Assigned issue":"Montana furnisher private action","Status":"Materially preempted/partial","Claim IDs":"C014, C042–C043","Exact remaining evidence or next action":"Claim-specific pleading, actor, and subject matter required."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana CRA private action","researcher_record":{"Assigned issue":"Montana CRA private action","Status":"Partial","Claim IDs":"C013","Exact remaining evidence or next action":"Full remedy, §1681h(e), standing, and limitation analysis later."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana privacy act","researcher_record":{"Assigned issue":"Montana privacy act","Status":"Answered as exemption boundary","Claim IDs":"C010","Exact remaining evidence or next action":"Determine whether activity was actually FCRA-authorized."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana freeze provisions","researcher_record":{"Assigned issue":"Montana freeze provisions","Status":"Answered on books","Claim IDs":"C011","Exact remaining evidence or next action":"Residual nonpreempted scope unresolved."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Federal freeze timing/fees","researcher_record":{"Assigned issue":"Federal freeze timing/fees","Status":"Answered in core","Claim IDs":"C012","Exact remaining evidence or next action":"Actual request method and identity proof held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Existing-account collection despite freeze","researcher_record":{"Assigned issue":"Existing-account collection despite freeze","Status":"Answered","Claim IDs":"C012","Exact remaining evidence or next action":"Actual account relationship required."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"CRA dispute timeline","researcher_record":{"Assigned issue":"CRA dispute timeline","Status":"Answered","Claim IDs":"C015–C020","Exact remaining evidence or next action":"Actual receipt and additional-information dates needed."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"CRA frivolous dispute","researcher_record":{"Assigned issue":"CRA frivolous dispute","Status":"Answered","Claim IDs":"C018","Exact remaining evidence or next action":"Actual sufficiency and reasonableness held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"CRA deletion/modification","researcher_record":{"Assigned issue":"CRA deletion/modification","Status":"Answered","Claim IDs":"C019","Exact remaining evidence or next action":"Actual investigation record held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Reinsertion","researcher_record":{"Assigned issue":"Reinsertion","Status":"Answered","Claim IDs":"C019–C020","Exact remaining evidence or next action":"Actual certification and notice held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"CRA result notice","researcher_record":{"Assigned issue":"CRA result notice","Status":"Answered","Claim IDs":"C020","Exact remaining evidence or next action":"Actual completion and delivery held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Prior-recipient notification","researcher_record":{"Assigned issue":"Prior-recipient notification","Status":"Answered","Claim IDs":"C021","Exact remaining evidence or next action":"Consumer request and designated recipients needed."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Federal consumer statement","researcher_record":{"Assigned issue":"Federal consumer statement","Status":"Answered in core","Claim IDs":"—","Exact remaining evidence or next action":"Actual statement and CRA treatment held."},"coordinator_acceptance":"bounded_material_predicate_correction_pending_UNSENT","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage.","coordinator_finding_ids":["S_MT-P10-Q002"]},{"topic":"Reseller dispute","researcher_record":{"Assigned issue":"Reseller dispute","Status":"Answered","Claim IDs":"C022","Exact remaining evidence or next action":"Actual reseller/source CRA relationship held."},"coordinator_acceptance":"bounded_material_predicate_correction_pending_UNSENT","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage.","coordinator_finding_ids":["S_MT-P10-Q003"]},{"topic":"Furnisher accuracy","researcher_record":{"Assigned issue":"Furnisher accuracy","Status":"Answered","Claim IDs":"C023","Exact remaining evidence or next action":"Actual source records and furnished fields held."},"coordinator_acceptance":"bounded_material_predicate_correction_pending_UNSENT","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage.","coordinator_finding_ids":["S_MT-P10-Q004"]},{"topic":"Furnisher dispute notation","researcher_record":{"Assigned issue":"Furnisher dispute notation","Status":"Answered","Claim IDs":"C024","Exact remaining evidence or next action":"Direct dispute receipt and continuing furnishing held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"DOFD reporting","researcher_record":{"Assigned issue":"DOFD reporting","Status":"Answered","Claim IDs":"C025","Exact remaining evidence or next action":"Actual delinquency and cure history held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"CRA-routed furnisher investigation","researcher_record":{"Assigned issue":"CRA-routed furnisher investigation","Status":"Answered","Claim IDs":"C026–C027","Exact remaining evidence or next action":"Actual CRA notice and transmitted information required."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Direct furnisher dispute","researcher_record":{"Assigned issue":"Direct furnisher dispute","Status":"Answered","Claim IDs":"C029–C033","Exact remaining evidence or next action":"Correct address, content, and supporting evidence needed."},"coordinator_acceptance":"bounded_material_predicate_correction_pending_UNSENT","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage.","coordinator_finding_ids":["S_MT-P10-Q005"]},{"topic":"CRO-generated direct dispute exclusion","researcher_record":{"Assigned issue":"CRO-generated direct dispute exclusion","Status":"Answered conditionally","Claim IDs":"C030","Exact remaining evidence or next action":"Actual authorship, entity status, and form source held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Direct dispute private right","researcher_record":{"Assigned issue":"Direct dispute private right","Status":"No FCRA subsection (a) private route","Claim IDs":"C027","Exact remaining evidence or next action":"Other properly pleaded law remains claim-specific."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Financial-institution negative notice","researcher_record":{"Assigned issue":"Financial-institution negative notice","Status":"Answered","Claim IDs":"C052","Exact remaining evidence or next action":"Institution status and first negative furnishing date held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Furnisher policies/Appendix E","researcher_record":{"Assigned issue":"Furnisher policies/Appendix E","Status":"Answered as regulatory requirement/guidance","Claim IDs":"C028, C037","Exact remaining evidence or next action":"Actual written policies and examinations held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Federal file access","researcher_record":{"Assigned issue":"Federal file access","Status":"Answered","Claim IDs":"C003, C051","Exact remaining evidence or next action":"Actual report and request route held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Free annual report","researcher_record":{"Assigned issue":"Free annual report","Status":"Answered","Claim IDs":"C051","Exact remaining evidence or next action":"Voluntary extra free-report policies are not treated as law."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Federal 2026 paid-disclosure ceiling","researcher_record":{"Assigned issue":"Federal 2026 paid-disclosure ceiling","Status":"Answered","Claim IDs":"C051","Exact remaining evidence or next action":"Applies only absent a free entitlement."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Federal reporting clock","researcher_record":{"Assigned issue":"Federal reporting clock","Status":"Answered","Claim IDs":"C034–C035","Exact remaining evidence or next action":"Actual DOFD and exceptional-report context needed."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana/federal clock interaction","researcher_record":{"Assigned issue":"Montana/federal clock interaction","Status":"Unresolved in part","Claim IDs":"C008, C013, C034","Exact remaining evidence or next action":"Controlling Montana construction not located."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Sale/assignment and clock","researcher_record":{"Assigned issue":"Sale/assignment and clock","Status":"Answered federally","Claim IDs":"C035","Exact remaining evidence or next action":"Actual DOFD still required."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Payment/settlement and clock","researcher_record":{"Assigned issue":"Payment/settlement and clock","Status":"Answered federally","Claim IDs":"C035","Exact remaining evidence or next action":"Actual cure history and account terms held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Paid account status","researcher_record":{"Assigned issue":"Paid account status","Status":"Answered in principle","Claim IDs":"C036","Exact remaining evidence or next action":"Actual payment application and remaining liability held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Settled account deletion","researcher_record":{"Assigned issue":"Settled account deletion","Status":"No automatic right established","Claim IDs":"C036, C046","Exact remaining evidence or next action":"Contractual pay-for-delete promise, if any, unsupplied."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Accurate settled-for-less notation","researcher_record":{"Assigned issue":"Accurate settled-for-less notation","Status":"Answered as fact-dependent","Claim IDs":"C046","Exact remaining evidence or next action":"Actual agreement and report fields required."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Duplicate tradelines","researcher_record":{"Assigned issue":"Duplicate tradelines","Status":"Partial","Claim IDs":"C037–C038","Exact remaining evidence or next action":"Actual furnishing codes, owner, and balances held."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Transferred-account correction","researcher_record":{"Assigned issue":"Transferred-account correction","Status":"Answered as accuracy/policy issue","Claim IDs":"C037–C038","Exact remaining evidence or next action":"No universal mandated coding identified."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Transfer of prior dispute file","researcher_record":{"Assigned issue":"Transfer of prior dispute file","Status":"Unresolved generally","Claim IDs":"C037","Exact remaining evidence or next action":"Contract, knowledge, and later CRA notice required."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Original-creditor identity in ordinary report","researcher_record":{"Assigned issue":"Original-creditor identity in ordinary report","Status":"Partial","Claim IDs":"C003, C029","Exact remaining evidence or next action":"No universal assignment-chain disclosure established."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"CRA dispute versus FDCPA validation","researcher_record":{"Assigned issue":"CRA dispute versus FDCPA validation","Status":"Answered as separate processes","Claim IDs":"C039–C040","Exact remaining evidence or next action":"Full FDCPA pass remains separate."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"FCRA collection pause","researcher_record":{"Assigned issue":"FCRA collection pause","Status":"No automatic pause","Claim IDs":"C039","Exact remaining evidence or next action":"Independent FDCPA, contract, bankruptcy, or court order could differ."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Mandatory original contract production","researcher_record":{"Assigned issue":"Mandatory original contract production","Status":"No universal requirement","Claim IDs":"C040","Exact remaining evidence or next action":"Litigation proof and special-sector law later."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Montana preemption","researcher_record":{"Assigned issue":"Montana preemption","Status":"Answered structurally","Claim IDs":"C013–C014, C041–C048","Exact remaining evidence or next action":"Claim-specific application and later precedent remain."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Current CFPB preemption interpretation","researcher_record":{"Assigned issue":"Current CFPB preemption interpretation","Status":"Answered","Claim IDs":"C048","Exact remaining evidence or next action":"Nonbinding; future withdrawal or judicial rejection possible."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Federal standing","researcher_record":{"Assigned issue":"Federal standing","Status":"Answered as boundary","Claim IDs":"C049","Exact remaining evidence or next action":"Full damages/remedies analysis excluded."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Current medical-rule status","researcher_record":{"Assigned issue":"Current medical-rule status","Status":"Answered only to prevent overbreadth","Claim IDs":"C050","Exact remaining evidence or next action":"Medical reporting dossier remains excluded."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Identity-theft blocking","researcher_record":{"Assigned issue":"Identity-theft blocking","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Separate §1681c-2 and Montana restoration pass."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Fraud alerts","researcher_record":{"Assigned issue":"Fraud alerts","Status":"Excluded except freeze comparison","Claim IDs":"—","Exact remaining evidence or next action":"Separate identity-theft pass."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Tenant/employment/insurance screening","researcher_record":{"Assigned issue":"Tenant/employment/insurance screening","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Separate specialty-reporting passes."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Mortgage/repo/child-support/tax/student debt","researcher_record":{"Assigned issue":"Mortgage/repo/child-support/tax/student debt","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Sector-specific passes."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Bankruptcy reporting","researcher_record":{"Assigned issue":"Bankruptcy reporting","Status":"Excluded beyond ordinary-clock distinction","Claim IDs":"—","Exact remaining evidence or next action":"Separate bankruptcy/reporting pass."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Litigation proof/admissibility","researcher_record":{"Assigned issue":"Litigation proof/admissibility","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Collection-litigation/evidence pass."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Full private/public remedies","researcher_record":{"Assigned issue":"Full private/public remedies","Status":"Excluded except threshold boundaries","Claim IDs":"C027, C049","Exact remaining evidence or next action":"Separate remedies and limitations pass."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Local/tribal law","researcher_record":{"Assigned issue":"Local/tribal law","Status":"Excluded","Claim IDs":"—","Exact remaining evidence or next action":"Separate jurisdictional investigation."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Named account/provider compliance","researcher_record":{"Assigned issue":"Named account/provider compliance","Status":"Unresolved","Claim IDs":"C053","Exact remaining evidence or next action":"Requires actual report, furnisher records, notices, and status."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."},{"topic":"Comprehensive post-2025 Montana currentness","researcher_record":{"Assigned issue":"Comprehensive post-2025 Montana currentness","Status":"Partial","Claim IDs":"All state claims","Exact remaining evidence or next action":"Later special-session, rulemaking, and full citator check."},"coordinator_acceptance":"scoped_reviewed_original_missing_evidence_and_parent_holds_retained","coordinator_review":"[internal evidence reference]","coordinator_checked_at":"2026-10-29T03:01:52.963550+00:00","coordinator_review_note":"All 65 rows read; original answered status remains researcher provenance. No unreviewed/failed source or excluded component is converted into accepted coverage."}],"annotations":{},"corrections":[{"issue_id":"S_MT-P10-Q001","finding":"Example-to-claim traceability Example 2 reporting-age illustration cites C030-C033 direct-dispute rules, and Example 6 incomplete direct dispute cites C025-C027 DOFD/CRA-notice/private-path rules. Example 1 includes unrelated settlement C046 and omits direct-dispute C029-C033.","affected_claim_ids":[],"related_claim_ids":[],"validated_exact_raw_rows":[],"exact_original_cell_matches":[],"source_urls":[],"localization":"report_level_pending_localization_required","public_status":"Recorded correction pending; working-paper assertion requires the stated repair or qualification."},{"issue_id":"S_MT-P10-Q002","finding":"100-word dispute statement cap requires writing assistance The narrative says the consumer may add a statement of up to 100 words under federal law, without the statutory condition on the CRA-imposed cap.","affected_claim_ids":[],"related_claim_ids":[],"validated_exact_raw_rows":[],"exact_original_cell_matches":[],"source_urls":["https://uscode.house.gov/us/usc/119-124/t15/s1681i/"],"localization":"report_level_pending_localization_required","public_status":"Recorded correction pending; working-paper assertion requires the stated repair or qualification."},{"issue_id":"S_MT-P10-Q003","finding":"Reseller forwarding has the five-business-day framework C022 and the actor matrix group correction or forwarding with a 20-day process. This can improperly give 20 days for forwarding when the five-business-day opening governs the not-own-error conveyance branch.","affected_claim_ids":["S_MT-P10-C022"],"related_claim_ids":[],"validated_exact_raw_rows":[],"exact_original_cell_matches":[],"source_urls":["https://uscode.house.gov/us/usc/119-124/t15/s1681i/"],"localization":"claim_row_matches_available_no_complete_narrative_localization","public_status":"Recorded correction pending; working-paper assertion requires the stated repair or qualification."},{"issue_id":"S_MT-P10-Q004","finding":"Knowledge prohibition omits specified-address exception The categorical knowledge/reasonable-cause prohibition in V.1/C023 omits the express (C) exception and collapses (A)/(B).","affected_claim_ids":["S_MT-P10-C023"],"related_claim_ids":[],"validated_exact_raw_rows":[],"exact_original_cell_matches":[],"source_urls":["https://uscode.house.gov/us/usc/119-124/t15/s1681s-2/"],"localization":"claim_row_matches_available_no_complete_narrative_localization","public_status":"Recorded correction pending; working-paper assertion requires the stated repair or qualification."},{"issue_id":"S_MT-P10-Q005","finding":"Direct-dispute repeat rule does not require new material information The narrative says a resolved dispute can be repeated without new material information. The actual repeat exception does not impose a materiality requirement on the new paragraph-(d) information. This risks importing the distinct FDCPA/Reg F duplicative-dispute standard.","affected_claim_ids":["S_MT-P10-C033"],"related_claim_ids":[],"validated_exact_raw_rows":[],"exact_original_cell_matches":[],"source_urls":["https://www.consumerfinance.gov/rules-policy/regulations/1022/43"],"localization":"claim_row_matches_available_no_complete_narrative_localization","public_status":"Recorded correction pending; working-paper assertion requires the stated repair or qualification."}],"resolved_corrections":[],"review_history":[{"id":"S_MT-P10-scoped-review-20261029-parallel","status":"five_bounded_corrections_pending_UNSENT_all_other_holds_retained","at":null}]}