Which place’s debt rules apply—and who can help?

S_MT PASS-09 — Montana prelitigation debt validation, disputes, and consumer access to account documentation

Fresh research session: October 26, 2026, Pacific / October 26, 2026, UTC Mode: GPT-5.6 Sol Pro, regular Chat Relationship to prior work: Distinct validation/documentation component. This does not adopt PASS-08’s unreviewed licensing conclusions or regenerate any provider, fee, funds, bond, agreement, remedies, collection-conduct, litigation, or credit-reporting report.

Component status: PARTIAL. Montana has several account-specific disclosure and documentation rights, but no generally applicable Montana prelitigation validation-notice-and-collection-pause regime equivalent to 15 U.S.C. §1692g was verified. The federal FDCPA/Regulation F process supplies that broader validation framework only when the collector, debt, and communication satisfy federal coverage requirements.

A. Substantive answers

1. Montana does not present one universal debt-validation regime

Fresh review identified four materially different Montana documentation systems:

1. Consumer Loan Act records and receipts for a covered Montana consumer-loan licensee.
2. Retail installment contract copies, payment statements, and periodic retail-account statements.
3. UCC Article 9 accounting and assignment-proof rights, whose scope depends on the transaction and statutory role.
4. General Montana unfair-or-deceptive-practice law, which can reach materially false debt, ownership, or account representations but does not itself prescribe one universal validation form, 30-day dispute window, or automatic collection pause.

No current Montana statute or authenticated current rule was verified that requires every original creditor, collection agency, debt buyer, servicer, or attorney collecting a Montana debt to send a general initial validation notice containing the federal §1692g disclosures. No general Montana rule was verified that pauses every collector after every consumer dispute. That is a bounded conclusion from the Montana Titles 30, 31, and 32 provisions and official rule routes examined—not proof that no specialized sector, local, tribal, contract, or future-enacted duty exists. Montana Code Annotated+4

The practical result is that the following questions must be kept separate:

• Is the account governed by a Montana loan, retail-installment, retail-merchandise, or secured-transactions statute?
• Is the person seeking payment a federally covered “debt collector”?
• Is the consumer making a state account-statement request, a UCC assignment-proof request, a UCC accounting request, a federal oral dispute, a timely federal written dispute, or a federal original-creditor request?
• Does the request create only a document duty, a payment-direction consequence, or an actual collection pause?

A voluntary account statement, industry validation packet, or creditor policy is not converted into Montana law merely because it is customary.

2. Montana Consumer Loan Act records and consumer-facing information

A. Payment receipts

A covered Montana Consumer Loan Act licensee must give a borrower a plain, dated, complete receipt for every cash payment at the time of payment. The licensee must also maintain a reliable ledger or electronic record showing the amount and date of each payment. After full repayment, it must memorialize satisfaction, release covered collateral, and cancel and return the note or equivalent instrument within ten days. Montana Code Annotated

The current official Montana rule search rendering and the matching current secondary compilation go further than the statute’s cash-payment minimum. ARM 2.59.305 requires the licensee to give or mail a plain and complete receipt for each payment, with at least:

• Borrower name.
• Account number.
• Payment amount and date.
• Past-due amount collected, if any.
• Remaining loan balance.
• Refund amount.

The rule also requires each installment payment, refund, or collection to be recorded separately, with electronic records capable of hard-copy reproduction. The current official rule text route returned HTTP 405, but the official search rendering supplies the current text, and the official 2014 adoption notice confirms that ARM 2.59.305 was amended as proposed. Montana Administrative Rules+2

This is a payment-receipt and account-record duty, not a general precollection validation notice. It does not itself require production of the original signed note, an assignment chain, or every historical statement after a consumer disputes the account.

B. Retention

A Consumer Loan Act licensee must preserve the books, accounts, and records required by the Department and necessary to determine compliance for at least two years after the final entry on the loan. ARM 2.59.306 additionally requires a continuously current total of Montana consumer-loan notes receivable originated at each licensed location and requires the supporting source documents to remain available for Department examination or submission. Montana Code Annotated+2

Those records must exist for regulatory purposes, but the provisions do not create an express consumer right to demand the licensee’s entire regulatory file, underwriting file, examination materials, or source-document archive.

C. Closure and transfer information

ARM 2.59.319 creates a special disclosure regime when a Consumer Loan Act business closes. At least 60 days before the intended closure, the licensee must notify consumers with active loans and disclose:

• Current balance itemized by unpaid principal, accrued interest, and allowable fees.
• Closure date, no sooner than 60 days after mailing.
• Succession plan, including sale or assignment.
• Successor’s contact information and assumption letter.
• Available alternatives.
• Lien-release contact information.
• Department complaint information.

The licensee also must identify the post-closure custodian of inactive files and furnish the Department a detailed active-loan report. This is a closure-specific rule; it is not proof that every ordinary sale or servicing transfer must use the same notice. The official current page identifies the rule as effective, but direct body access failed; the matching current secondary text was read. Montana Administrative Rules+2

D. No general MCLA dispute pause found

The read Consumer Loan Act provisions and rules do not establish a general process under which:

• Every consumer dispute must be written.
• The licensee must respond within a fixed number of days.
• Collection automatically stops upon dispute.
• A signed original note must be produced before collection resumes.
• The debt disappears if requested documents are not supplied.

False balance, ownership, or payment-history representations may implicate other law, including Montana’s general ban on unfair or deceptive practices, but those are distinct issues. Montana Code Annotated+1

3. Montana retail-credit documentation rights

A. Retail installment contract copy at formation

A Montana retail installment contract must generally be written, signed by buyer and seller, completed as to essential provisions before the buyer signs, and contain the prescribed information. The buyer must be told that the buyer is entitled to an exact copy bearing the buyer’s signature. The contract must identify the parties, goods or services, collateral, cash price, down payment, principal balance, finance charge, total time balance, installment count and amount, and due dates or periods. Montana Code Annotated

This is an execution-stage copy right. It does not say that every later collector must produce the original ink-signed contract in response to every prelitigation dispute. A collector’s later proof obligations may arise from federal validation law, UCC assignment law, contract law, or litigation evidentiary rules, but §31-1-231 itself is not a universal later validation process.

B. Written request for account statement

Upon the buyer’s written request, the holder of a Montana retail installment contract must give or forward a written statement showing:

• Dates of payments.
• Amounts of payments.
• Total amount unpaid under the contract.

The holder must also give a receipt for cash payments and, after full payment, acknowledge satisfaction and release security. The statute does not prescribe a response deadline, assumed-receipt rule, specific delivery method, dispute form, or collection pause. Montana Code Annotated

“Holder” is important. It includes the seller or an assignee entitled to the seller’s rights under the retail installment contract. Thus, this duty can follow the contract to a qualifying assignee; it is not limited to the original seller. The exact contract and assignment facts remain necessary.

C. Retail-merchandise periodic statements

A separate Montana statute applies when a retail seller sells merchandise on an account that was not intended to extend credit beyond 30 days and imposes the authorized late-payment charge. During every agreed regular period with an unpaid balance, the seller must promptly provide a statement disclosing:

• Late-charge percentage.
• Opening or ending unpaid balance.
• Amounts debited during the period.
• Buyer payments during the period.
• Late charge and annual simple-interest equivalent.
• A statement that the buyer may pay the total unpaid balance at any time.

This branch excludes intangible services, regulated utilities, real estate, health-care services, and transactions governed by Montana’s retail-installment provisions. Montana Code Annotated+1

It is a periodic-statement condition on charging the Montana retail late fee—not a universal debt-buyer validation rule.

4. Montana UCC assignment proof, accounting, and release rights

These UCC rights can apply to consumer or commercial transactions depending on the statutory role and collateral. They should not be reduced to a generic “debt validation” label.

A. Reasonable proof of assignment under §30-9A-406

An account debtor on an account, chattel paper, or payment intangible may continue discharging the obligation by paying the assignor until receiving a signed assignment notice that reasonably identifies the assigned rights and directs payment to the assignee. After an effective notification, payment generally must go to the assignee. Montana Code Annotated

If the account debtor requests proof, the assignee must seasonably furnish reasonable proof that the assignment occurred. Until the assignee complies, the account debtor may discharge the obligation by paying the assignor even after receiving the assignment notice. Montana Code Annotated

This has several limits:

• “Seasonably” is not converted in this section into a fixed number of days.
• The consequence is a rule about whom the account debtor may safely pay.
• The section does not say that failure to furnish proof extinguishes the underlying debt.
• It does not require a complete purchase agreement, every intermediate assignment, a wet-ink note, or every ledger entry in every case.
• It does not itself pause every communication or lawsuit.
• It is subject to other law providing different rules for individuals who incurred personal, family, or household obligations.
• Its payment-notification provisions do not apply to controllable accounts or controllable payment intangibles, and the section contains other transaction-specific exclusions. Montana Code Annotated

Montana’s older First Fidelity Bank v. Matthews decision applied the predecessor assignment-notice rule and held that notice to a limited-purpose escrow agent was not necessarily notice to the account debtor. The court treated effective notice of the assignment and payment direction as material to whether the debtor could discharge the obligation by paying the assignor. It did not hold that every assignment requires production of a complete chain of title or that an unnoticed assignment destroys the debt. Justia Law

B. Accounting and statement-of-account requests under §30-9A-210

A debtor may send a signed record that reasonably identifies the transaction and requests:

• An accounting of unpaid secured obligations.
• Approval or correction of a collateral list.
• Approval or correction of the debtor’s proposed statement of the aggregate unpaid obligation.

A covered secured party must respond within 14 days after receipt. An accounting must be signed, state the aggregate unpaid secured obligations as of a date within 35 days before or after the record date, and identify the obligation’s components in reasonable detail. Montana Code Annotated+1

A former secured party that no longer claims an interest must respond within the same 14-day period by disclaiming its interest and, if known, naming and giving the mailing address of its assignee or successor. Montana Code Annotated

The debtor receives one response without charge during any six-month period. A secured party may charge no more than $25 for each additional response. Montana Code Annotated

The scope limitation is major: §30-9A-210 expressly excludes from this response duty a buyer of accounts, chattel paper, payment intangibles, or promissory notes, as well as a consignor. A consumer cannot assume that every debt buyer or purchased-account owner must answer a §30-9A-210 accounting request merely because it owns the debt. Montana Code Annotated

In Hutzenbiler v. RJC Investment, the Montana Supreme Court reversed summary judgment and held that a release did not terminate applicable Article 9 accounting and surplus protections after resale of a mobile home. The court cited §30-9A-210’s 14-day accounting duty and emphasized that protected accounting rights could not simply be waived away. The court remanded and did not decide every merits issue, including the disputed default question. Justia Law+1

C. Release after the secured obligation ends

Where there is no outstanding secured obligation and no commitment to provide further value, a secured party must, within 10 days after receiving a signed demand, send a signed release to an account debtor previously notified of the assignment. This section does not apply when the assignment itself constituted a sale of an account, chattel paper, or payment intangible. Montana Code Annotated

This is not a generic paid-debt validation rule for every purchased account. It is a narrower release mechanism tied to a secured-party assignment structure.

5. Necessary federal validation branch

A. Coverage gateway

The federal validation regime applies only to a person who satisfies the FDCPA “debt collector” definition and to an obligation arising primarily from a personal, family, or household transaction. An original creditor collecting in its own name is generally not within the ordinary “owed another” prong, although the statute contains the other-name rule and other fact-specific routes. Employees, affiliates, pre-default acquirers, fiduciaries, government actors, and other categories have conditional exclusions. U.S. Code

This means:

• A Montana original creditor can have Montana account-statement duties without having a federal §1692g validation duty.
• A third-party collector can have a federal validation duty even where Montana has no parallel general notice statute.
• A debt buyer’s federal status requires the principal-purpose and other statutory analysis; title ownership alone does not answer the validation question.
• Commercial debt is outside §1692g even if a Montana UCC accounting or assignment provision applies.

B. Initial federal validation notice

Unless the consumer already paid or the required information appeared in the initial communication, a covered debt collector must send the validation notice within five days after its initial communication. The statute requires:

1. Amount of the debt.
2. Name of the current creditor.
3. Statement that the collector will assume validity unless the consumer disputes within 30 days after receipt.
4. Statement that a timely written dispute requires verification or a judgment copy.
5. Statement that a timely written request requires the original creditor’s name and address, if different. U.S. Code

A formal pleading in a civil action is not an initial communication for this purpose. Failure to dispute is not a legal admission of liability. U.S. Code

Regulation F permits the validation information to be:

• Sent in writing or electronically with the initial communication.
• Sent within five days after the initial communication.
• Provided orally in the initial communication.

The regulation defines the initial communication collector by collector, subject to the formal-pleading and other listed exclusions. eCFR

C. Regulation F’s expanded itemization

Regulation F requires materially more structured information than the short statutory list. Subject to the residential-mortgage special rule, the validation information includes:

• Debt collector name and mailing address for disputes and original-creditor requests.
• Consumer’s name and mailing address.
• Creditor at the itemization date for covered consumer financial products or services.
• Account number or recognizable truncation.
• Current creditor.
• Chosen itemization date.
• Amount on the itemization date.
• Interest, fees, payments, and credits since that date.
• Current amount.
• Consumer-protection statements and response prompts.

The five permitted itemization dates are the last statement date, charge-off date, last-payment date, transaction date, or judgment date. Once one collector uses a reference date for that debt and consumer, it must use it consistently within its validation disclosures. A successor collector may choose a different permitted itemization date. eCFR+2

Each itemization field must appear. A zero-value field may say “0” or “none,” but it may not simply be omitted or left blank. A substantially similar itemization required by another law may be used where Regulation F permits. Consumer Financial Protection Bureau+1

Arithmetic consistency does not establish that an interest or fee is legally authorized, that the owner has valid title, or that the consumer is liable.

D. Validation period and receipt

Regulation F defines the validation period as beginning when the information is provided and ending 30 days after the consumer actually receives or is assumed to receive it. For calculating the disclosed end date, the collector may assume receipt on a date at least five days after provision, excluding Saturdays, Sundays, and federal legal public holidays. eCFR+1

If a notice is returned undeliverable and a later notice is sent to a corrected address, the later notice must carry a newly calculated validation-period end date based on receipt or assumed receipt of that later notice. Consumer Financial Protection Bureau

The older Ninth Circuit decision in Mahon held that §1692g(a) required the collector to send the notice and did not require proof of actual receipt. Regulation F now adds the separate “reasonably expected to provide actual notice” delivery rule and a receipt/assumed-receipt framework for calculating the validation period. Mahon remains relevant to the statutory “send” issue, but it should not be quoted as eliminating the current regulatory delivery and recalculation rules. Justia Law+3

E. Oral versus written disputes

Under controlling Ninth Circuit authority, a consumer may dispute validity orally for §1692g(a)(3)’s “assumed valid” provision. A notice that says the consumer can dispute validity only in writing misstates that right. Camacho affirmed denial of the collector’s dismissal motion on that basis. Justia Law+2

But a timely written dispute is required to invoke §1692g(b)’s cease-collection-and-verify requirement. A timely written request is likewise required to compel original-creditor information and a collection pause. U.S. Code+2

Regulation F treats a request as written when, for example, the consumer:

• Mails it.
• Returns the response form.
• Uses an email address or portal through which the collector accepts consumer communications.
• Delivers it in person or by courier.

A telephone call alone is not the Regulation F written trigger for the pause. Consumer Financial Protection Bureau

F. Collection pause and restart

A timely written dispute requires the collector to cease collection of the debt or disputed portion until it sends:

• Verification of the debt; or
• A copy of the judgment.

A timely written original-creditor request requires the collector to stop collection until it sends the original creditor’s name and address. When current and original creditor are the same, the collector may reasonably determine that fact, notify the consumer, and refer back to the previously supplied validation information. eCFR+2

The pause is not the same as:

• Cancellation of the debt.
• Waiver of interest otherwise accruing under lawful terms.
• Closure of an account.
• Revocation of every payment authorization.
• A credit-reporting block.
• A litigation ruling on admissibility or ownership.

Collection may continue during the validation period if no timely written dispute or qualifying original-creditor request has been received, but the communications may not overshadow or contradict the validation rights. U.S. Code+1

A dispute submitted after the validation period does not create §1692g(b)’s automatic pause. It also is not an admission of liability and may have significance under other provisions, a creditor policy, credit-reporting law, contract law, or litigation rules.

G. Verification standard

The Ninth Circuit’s baseline in Clark is limited. At minimum, verification involves written confirmation that the amount demanded is the amount the creditor claims is owed. In the case before it, an itemized statement and creditor confirmation were sufficient, and the court declined to impose a universal duty of independent investigation. Justia Law+2

That does not mean:

• Any number supplied by a creditor is always legally correct.
• A collector may knowingly transmit false account information.
• Verification adjudicates ownership or contract enforceability.
• Verification always requires the original signed contract.
• Verification can omit the current creditor or amount.
• A collector is immunized from separate false-amount or false-identity prohibitions.

The correct bounded conclusion is that §1692g verification is not a universal discovery procedure or prelitigation trial on the debt. Account-level proof needed to sue remains a later litigation/evidence question.

H. Successor collectors

The Ninth Circuit held in Hernandez that each successive covered debt collector must provide its own validation notice following its own initial communication. A prior collector’s notice does not eliminate the successor’s duty. The court reversed summary judgment and remanded. Ninth Circuit Court of Appeals+3

The court also observed that a collector that receives a validation request can verify and continue or cease collection and transfer the account. The successor collector must independently satisfy its own validation obligations. Ninth Circuit Court of Appeals

This does not establish that:

• The first collector’s internal dispute flags automatically transfer under every contract.
• A prior collector’s verification automatically satisfies the next collector’s response.
• State UCC successor information replaces federal validation.
• A successor may ignore known false account data.

Those questions require the transfer records, applicable federal provisions, and later furnishing/reporting analysis.

I. Duplicative disputes

A timely written dispute is “duplicative” only when it is substantially the same as a prior timely written dispute that the collector already answered and contains no new and material information. The collector may either reverify or send a notice explaining why the dispute is duplicative and identify the date of the prior response. New and material support—such as a canceled check not previously supplied—prevents the dispute from being treated as duplicative. eCFR+2

J. Electronic notices and responses

A required federal disclosure sent in writing or electronically must be transmitted in a manner reasonably expected to provide actual notice and in a form the consumer can retain and access later. Electronic five-day validation notices and electronic verification or original-creditor responses must comply with E-SIGN’s consumer-consent rules. eCFR+1

E-SIGN generally requires affirmative consent following clear disclosures about paper records, withdrawal of consent, scope, contact updates, paper copies, and hardware and software requirements. The consumer must consent electronically in a way reasonably demonstrating access to the format that will be used. U.S. Code

Montana UETA likewise does not make email automatically valid for every state-law request. It applies only when both parties have agreed to transact electronically. Where a Montana law requires writing, the electronic record must be retainable, and the sender cannot disable the recipient’s ability to print or store it. A specified statutory method or format remains controlling unless the governing law permits variation. Montana Code Annotated+1

K. Federal record retention

Regulation F requires a covered debt collector to retain evidence of compliance or noncompliance from the beginning of collection activity until three years after the collector’s last collection activity on the debt. If it records collection calls, it must retain each recording for three years after the call. eCFR+1

A sale or transfer can start the transferor’s three-year clock if it is the transferor’s last collection activity. Consumer Financial Protection Bureau

This retention duty does not itself grant the consumer automatic access to every retained record. It is not a universal document-production statute.

L. Model Form B-1

CFPB Model Form B-1 provides a safe harbor for the validation notice’s required information and form when properly used, and its proper use also receives the rule’s specified overshadowing safe harbor. A substantially similar form can qualify. Consumer Financial Protection Bureau+1

The form is not:

• The only permissible notice format.
• Evidence that the debt is valid.
• Proof of ownership.
• Proof that all charges are authorized.
• A complete response to every specific dispute.
• A substitute for the applicable electronic-delivery requirements.
• A litigation affidavit or authenticated business record.

The CFPB’s current public English packet is dated October 2021; the actual model notice appears on printed page 3, zero-based PDF index 2. Consumer Financial Protection Bureau+1

B. Actor/model/document matrix

C. Event, form, timing, and pause matrix

D. Records and evidence matrix

E. Controlling and materially relevant decisions

1. First Fidelity Bank v. Matthews — assignment notice

The Montana Supreme Court considered an assignment of payments held through an escrow arrangement. It upheld the finding that the account debtor lacked effective notice where the limited-purpose escrow agent’s knowledge was not imputed beyond the scope of its agency. The decision illustrates the predecessor rule that assignment notice and payment direction matter to discharge by payment; it is not a holding that an unproved assignment automatically extinguishes the debt. Justia Law

2. Hutzenbiler v. RJC Investment — accounting and nonwaiver

The Montana Supreme Court reversed summary judgment in a mobile-home secured transaction. It held that a release did not simply eliminate applicable Article 9 accounting and surplus protections, cited the 14-day §30-9A-210 accounting requirement, and remanded without deciding all disputed default and merits questions. Justia Law+1

3. Camacho v. Bridgeport Financial — oral dispute

The Ninth Circuit held that §1692g(a)(3) does not require an initial validity dispute to be in writing. A notice stating that the consumer could dispute only in writing plausibly misstated the consumer’s rights. The decision does not eliminate the separate written predicate for §1692g(b)’s pause and verification rights. Justia Law+2

4. Clark v. Capital Credit & Collection Services — verification baseline

The Ninth Circuit adopted a minimum verification standard under which the collector confirms in writing that the amount demanded is what the creditor claims. In that record, an itemized statement and creditor confirmation were sufficient, and the collector had no universal duty to independently investigate the creditor’s underlying claim. The court separately preserved false-amount and misleading-representation analysis. Justia Law+2

5. Mahon v. Credit Bureau of Placer County — sending

The Ninth Circuit held that the statutory §1692g(a) notice requirement required sending and did not require proof of actual receipt. Current Regulation F adds the actual-notice-expectation and receipt/assumed-receipt rules described above, so Mahon must be applied with the current regulation rather than as a complete modern delivery rule. Justia Law+3

6. Hernandez v. Williams, Zinman & Parham — successor collectors

The Ninth Circuit held that §1692g’s validation requirement applies to each debt collector attempting collection, not only the first collector ever assigned the account. The case reversed summary judgment and remanded. Ninth Circuit Court of Appeals+3

7. Mashiri v. Epsten Grinnell & Howell — overshadowing

The Ninth Circuit reversed a Rule 12(b)(6) dismissal. A notice demanding payment within 35 days of the letter date could leave fewer than 30 days after receipt and plausibly overshadow the dispute right. A statement that a lien “will” be recorded also plausibly conveyed that a timely dispute would not pause collection. The court resolved pleading sufficiency, not final merits or damages. Ninth Circuit Court of Appeals+3

F. Bounded worked examples

All monetary amounts are U.S. dollars. These examples demonstrate document and workflow mechanics only. They do not establish debt validity, charge authorization, ownership, federal coverage, or an actual deadline for an identified consumer.

Example 1 — Montana Consumer Loan Act payment receipt

Assumptions

• Covered Consumer Loan Act licensee.
• Borrower pays $125.
• $25 is applied to a past-due amount.
• Remaining balance after the payment is $875.
• No refund is due.

Required receipt fields under the current rule include:

• Borrower name.
• Account number.
• Payment amount: $125.00.
• Payment date.
• Past-due amount collected: $25.00.
• Balance remaining: $875.00.
• Refund: $0.00.

This receipt does not establish that every historical charge is lawful or that the licensee owns the account. It also does not trigger or substitute for a federal validation notice.

Claims: S_MT-P09-C003–C005.

Example 2 — Retail installment statement request

Facts

A buyer sends the holder a written request. The holder’s records show:

• Payment 1: $100.
• Payment 2: $150.
• Payment 3: $200.
• Total unpaid: $750.

Total payments reflected:

$100+$150+$200=$450$100+$150+$200=$450$100+$150+$200=$450The Montana statement must show the dates and amounts of those payments and the $750 total unpaid. The statute does not prescribe a fixed response deadline or automatic collection pause.

Claims: S_MT-P09-C008–C010.

Example 3 — Assignment-proof request

Facts

• Consumer receives a signed notice instructing payment to Assignee B.
• Consumer requests reasonable proof of assignment.
• Assignee B has not yet furnished it.

Montana UCC consequence

Until B seasonably furnishes reasonable proof, the account debtor may discharge the obligation by paying Assignor A.

This does not mean:

• The debt is canceled.
• B permanently loses the claim.
• The consumer may safely pay no one.
• B must necessarily produce every purchase agreement and intermediate transfer.

Claims: S_MT-P09-C013–C016.

Example 4 — UCC accounting request

Assumptions

• Requesting person is a statutory “debtor.”
• Recipient is a covered secured party, not an excluded buyer of accounts, chattel paper, payment intangibles, or notes.
• Signed request reasonably identifies the transaction.
• No request has been made in the preceding six months.

Sequence

• Day 0: secured party receives request.
• Response deadline: 14 days after receipt.
• Charge: $0 for the first response in the six-month period.

A second request during the same six-month period may carry a charge no greater than $25.

The request does not itself pause collection, and the 14-day deadline is not imported into federal §1692g verification.

Claims: S_MT-P09-C017–C020.

Example 5 — Regulation F itemization

Hypothetical itemization

Amount on itemization date:

$1,000.00$1,000.00$1,000.00Post-itemization changes:

• Interest: +$25.00
• Fees: +$10.00
• Payments: −$100.00
• Credits: −$15.00

Current amount:

$1,000+$25+$10−$100−$15=$920$1,000+$25+$10-$100-$15=$920$1,000+$25+$10−$100−$15=$920The notice should display each category, including zero-value categories when applicable, and the current amount of $920.

The calculation proves only arithmetic consistency. It does not prove:

• Interest authorization.
• Fee authorization.
• Ownership.
• Contract execution.
• Consumer liability.
• Correct application of payments.

Claims: S_MT-P09-C026–C029.

Example 6 — Relative federal validation timeline

Use relative days because no actual mailing date, holiday calendar, or delivery evidence is supplied.

• Provision Day P: collector provides validation information.
• Assumed receipt: a date at least five days after P, excluding Saturdays, Sundays, and federal legal holidays.
• Validation end: 30 days after actual or assumed receipt, using the date the collector properly placed in the notice.

If the notice is returned undeliverable and a replacement notice is sent, the replacement must use a recalculated end date.

This does not determine an individual deadline without the actual notice, provision method, dates, address history, and returned-mail facts.

Claims: S_MT-P09-C030–C032.

Example 7 — Oral versus written dispute

Branch A: oral dispute within validation period

The consumer calls and says, “I dispute this debt.”

• Collector may not correctly say that validity could be disputed only in writing.
• The dispute rebuts the notice’s assumption-of-validity branch.
• The call alone does not invoke §1692g(b)’s mandatory collection pause.

Branch B: timely written dispute

The consumer mails, hand-delivers, couriers, or uses an accepted electronic channel for the written dispute.

• Collection of the debt or disputed portion must stop.
• Collection may resume after compliant verification or judgment copy is sent.

Claims: S_MT-P09-C033–C036.

Example 8 — Original-creditor request

Facts

The consumer timely writes: “Please provide the original creditor’s name and address.”

Different original and current creditors

Collection pauses until the collector sends the original creditor’s name and address.

Same original and current creditor

The collector may reasonably determine they are the same, send that fact to the consumer, and refer to the prior validation information.

The request is not a demand for the entire assignment chain or original contract.

Claims: S_MT-P09-C037–C038.

Example 9 — Successor collector

Sequence

1. Collector A sends a validation notice.
2. Consumer timely disputes in writing.
3. A stops collection rather than verifying and returns or transfers the account.
4. Collector B later sends its first collection communication.

Under Hernandez, B must provide its own validation information. B may select a different permitted Regulation F itemization date, but its own itemization must be internally consistent.

No conclusion is made that A’s private dispute file automatically transferred or that B may knowingly disregard it.

Claims: S_MT-P09-C039–C041.

Example 10 — Electronic validation notice

Supported branch

• Consumer previously gave compliant E-SIGN consent.
• Collector uses the agreed electronic channel.
• Subject line and content are reasonably expected to provide actual notice.
• Record can be downloaded, printed, or stored.
• Notice explains an accepted electronic dispute channel.

Unsupported branch

• No compliant consumer consent.
• Collector sends only a disappearing link.
• The portal prevents saving or printing.
• Email bounces or is sent to a known invalid address.

The unsupported branch does not establish compliant electronic delivery merely because the collector’s database shows “sent.”

Claims: S_MT-P09-C042–C044.

Example 11 — Late request

Facts

The validation period has ended. Consumer then requests validation.

Result

• Failure to dispute earlier is not an admission of liability.
• The late request does not trigger §1692g(b)’s automatic cease-collection rule.
• Collector may respond voluntarily.
• State account-statement, UCC, contract, or later litigation rights may still exist independently.

Claims: S_MT-P09-C035, C045.

G. PASS-09 source register

H. PASS-09 claim register

I. Component coverage and gap table

J. Researcher self-check

Freshly and directly read on October 26, 2026

• Official current published 2025 Montana Code provisions for:Consumer-loan receipts and records.Retail installment contract form and statement rights.Retail-merchandise periodic statements.UCC Article 9 definitions, accounting, assignment proof, and release.Montana UETA.Montana’s general unfair/deceptive-practices prohibition.
• Official Montana administrative-rule search renderings for ARM 2.59.305, 2.59.306, and 2.59.319.
• Matching current secondary full rule texts.
• Official 2014 Montana Administrative Register adoption notice for ARM 2.59.305 and 2.59.306, including screenshot of printed p.498/PDF index 68.
• Current official U.S. Code §1692a and §1692g.
• Current eCFR §§1006.34, 1006.38, 1006.42, 1006.100, and 1006.104.
• CFPB’s integrated official interpretations and Model Form B-1.
• E-SIGN §7001 and the Montana electronic-record provisions.
• Full publicly accessible opinions or opinion reproductions for:First Fidelity.Hutzenbiler.Camacho.Clark.Mahon.Hernandez.Mashiri.
• Relevant pages of the PDF opinions and forms were visually inspected through screenshots where required.

Fresh but access-limited

• Direct official ARM body URLs for 2.59.305, 2.59.306, and 2.59.319 returned HTTP 405. Official search rendering and adoption/status evidence were used with matching secondary text.
• The direct U.S. Code §1692n route failed; the same state-law-preservation rule was verified in current Regulation F §1006.104.
• Older Ninth Circuit opinions in Camacho, Clark, and Mahon were read from full public opinion reproductions rather than an official Ninth Circuit PDF archive.
• First Fidelity and Hutzenbiler were read from full public Montana opinion reproductions; no paid subsequent-history citator was used.

Bounded negative searches

Targeted official and judicial searches did not locate:

• A universal Montana debt-validation notice statute.
• A universal Montana dispute-and-pause law.
• A Montana rule requiring every collector to produce an original signed contract.
• A Montana rule requiring every debt buyer to furnish an entire assignment chain prelitigation.
• A general Montana collector response deadline for every account dispute.
• A controlling Montana appellate decision construing a universal collector-validation process.

These are bounded search results, not proof that no specialized, unpublished, district-court, local, tribal, contract, or later authority exists.

Not read or resolved

• Any actual debt, contract, assignment, account ledger, payment receipt, validation notice, dispute, collector response, email-consent record, returned mail, or delivery log.
• Any named creditor, collector, debt buyer, servicer, attorney, or provider record.
• Complete post-2025 Montana session-law and future-effective-law review.
• Complete current Montana ARM body and all amendment histories beyond the specific rules examined.
• Full credit-reporting, furnishing, identity-theft, litigation-proof, evidentiary, limitations, revival, service, default, judgment, garnishment, bankruptcy, probate, local, tribal, or sector-specific analyses.
• A complete federal FDCPA communications, liability, damages, or limitations dossier.
• The unreviewed conclusions of PASS-07 or PASS-08 as accepted premises.

Exact individual fetch timestamps were not exposed and are not invented. No application, complaint, provider search, filing, contact, records request, purchase, account change, private-data access, browser control, local-file write, provider approval, operational approval, independent review, component acceptance, Montana acceptance, parent-dossier acceptance, A066 acceptance, or publication-readiness determination occurred.

REPORT PARTIAL — the focused Montana prelitigation validation, dispute, and consumer account-documentation component is completed to the stated source, actor, transaction, and currentness limits.

END S_MT PASS-09