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

S_MT PASS-10 — Montana ordinary consumer-debt credit reporting, furnishing, and dispute overlays

Fresh research session: October 26, 2026, Pacific / October 26, 2026, UTC Actual model/mode: GPT-5.6 Sol Pro, regular Chat 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.

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.

I. Bottom-line findings

1. 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
2. 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
3. **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
4. 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
5. 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
6. **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

II. Montana-specific layer

1. State actors and scope

Montana 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

A 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

Consequences of that classification:

• An original creditor does not become a Montana CRA merely by maintaining or communicating only its own transaction-and-experience information.
• A nationwide CRA, specialty CRA, or qualifying reseller can fall within the state definition when it assembles or evaluates information for third-party reports.
• 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.
• A business can occupy more than one role for different functions, but the definitions cannot be collapsed into a single “credit-reporting company” label.

Regulation 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

2. Montana CRA accuracy and compliance duties

Montana requires a CRA to:

• Maintain reasonable procedures to avoid obsolete information and impermissible-purpose reporting.
• Verify prospective users and their certified purposes.
• Decline to furnish reports when it has reasonable grounds to believe no permissible purpose exists.
• Follow reasonable procedures to assure maximum possible accuracy.
• Maintain a record of all persons using the information.
• Maintain the source of each item of information.
• Notify information suppliers that false information, or information furnished with malice or willful intent to injure, can expose them to suit. Montana Code Annotated

These are affirmative state CRA duties. They are not a state-law substitute for the more detailed federal furnisher investigation requirements.

3. Montana file access

Upon request and proper identification, a Montana CRA must clearly and accurately disclose:

• The nature and substance of all information in the consumer’s file, except medical information.
• The sources of that information. Montana Code Annotated

Montana’s stated delivery conditions are old-fashioned but still printed in the current code:

• Disclosure during normal business hours and on reasonable notice.
• In-person disclosure with identification.
• Telephone disclosure after a written request with proper identification and prepaid or directly charged toll.
• Trained personnel to explain the information.
• A right to be accompanied by one identified person, subject to written permission if required. Montana Code Annotated

Those Montana provisions do not eliminate broader federal file-access rights or modern federal delivery systems.

4. Montana dispute and correction process

When 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

If the information is inaccurate or can no longer be verified, the CRA must:

• Promptly delete it.
• Notify all users of whom the CRA has records that the information was deleted.
• Those users must also delete it. Montana Code Annotated

If the reinvestigation does not resolve the dispute:

• The consumer may file a brief statement explaining the dispute.
• Subsequent reports containing the item must clearly note that it is disputed and include the statement or a clear and accurate summary.
• The CRA must tell the consumer which recorded users have the disputed information. Montana Code Annotated

This 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.

5. Montana disclosure fees

Section 31-3-125 delegates disclosure fees to administrative rule. The currently available secondary compilation of ARM 23.19.301 states:

• No charge if the consumer requests disclosure within 30 days after specified adverse-credit notification.
• Otherwise, no more than $8.50.
• No charge for notifying users of deletion following verification.
• The rule history lists amendments through August 23, 1996 and a later agency transfer. Montana Code Annotated+1

The 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

6. Montana obsolete-information rule

Montana’s on-books CRA statute bars reports containing:

• Bankruptcies older than 14 years from adjudication.
• Suits and judgments older than seven years or the governing limitations period, whichever is longer.
• Paid tax liens older than seven years.
• Accounts placed for collection or charged to profit and loss that antedate the report by more than seven years.
• Arrest, indictment, or conviction records older than seven years from the listed event.
• Other adverse information older than seven years. Montana Code Annotated

For 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

7. Montana user and adverse-action information

When 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

This is an adverse-action crossover, not a full credit-underwriting or ECOA analysis.

8. Montana private-law provisions and federal furnisher preemption

Montana’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

Those provisions remain printed law, but they do not establish a currently viable claim against every furnisher:

• §1681t(b)(1)(F) broadly preempts state requirements and prohibitions concerning furnisher responsibilities under §1681s-2.
• The express exceptions name specified Massachusetts and California provisions—not Montana.
• Feller held that Montana claims based on a bank’s duties to report accurately and respond to credit-report disputes were preempted.
• Morrow likewise treated damages directly tied to credit-reporting duties as preempted while allowing distinct servicing-misrepresentation theories to proceed. U.S. Code+4

Full state and federal remedies, pleading standards, damages, and limitation periods remain outside this pass.

9. Montana Consumer Data Privacy Act

The 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

This 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.

10. Security freezes

Montana’s 2007 freeze provisions remain in the code. They provide, among other things:

• Written or secure-electronic placement requests.
• A five-business-day ordinary placement period.
• A 24-hour identity-theft placement branch.
• Written confirmation.
• Temporary lifting procedures.
• An existing-account and collection exception.
• 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

Federal 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

Therefore, 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.

III. State/federal actor-duty matrix

The 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

IV. The three distinct reporting-dispute channels

1. CRA dispute under 15 U.S.C. §1681i

When 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

Within 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

If 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

If 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:

• The furnisher must certify that it is complete and accurate.
• The CRA must notify the consumer within five business days after reinsertion.
• The notice must identify the furnisher and explain the consumer’s dispute-statement right.
• The CRA must maintain procedures designed to prevent improper reappearance. U.S. Code

The 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

If 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

2. Furnisher investigation after CRA notice

A 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:

• Conduct an investigation.
• Review all relevant information supplied by the CRA.
• Report results to the CRA.
• If the information is incomplete or inaccurate, report that result to every other nationwide CRA to which it furnished the information.
• Modify, delete, or permanently block the information as appropriate.
• Finish within the CRA reinvestigation period. U.S. Code+2

Under 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

A 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

3. Direct dispute to furnisher under Regulation V

A direct dispute may concern:

• Liability for the account.
• Account terms.
• Principal balance.
• Scheduled payment amount or credit limit.
• Payment status, high balance, payment dates or amounts, opening or closing dates.
• Other account information bearing on creditworthiness. Consumer Financial Protection Bureau

The rule does not apply to every direct complaint. Important exclusions include:

• Most identifying-information disputes.
• Employment identity.
• Inquiries.
• Public-record information, unless furnished by an account-related furnisher.
• Fraud alerts and active-duty alerts.
• Information furnished by another furnisher.
• 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

The 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

The furnisher must:

• Conduct a reasonable investigation.
• Review all relevant information.
• Report results to the consumer within the period that would apply under §1681i.
• If the information is inaccurate, promptly notify every CRA to which it furnished that information and provide the correction. Consumer Financial Protection Bureau

A 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

4. FDCPA validation is separate

For 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

These processes are not interchangeable:

V. Federal furnishing duties

1. Accuracy, correction, and disputed status

A 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

These duties apply based on the furnishing activity. They are not limited to collection agencies and are not created by a Montana collection license.

2. Date of first delinquency

When 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

A furnisher cannot lawfully “re-age” an account by substituting:

• The date of purchase.
• The date of placement with a new collector.
• The date of a later payment.
• The date of a settlement.
• The date the account was entered into a new servicing system.

3. Financial-institution negative-information notice

A 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

This notice requirement is not universal to every nonbank creditor or collector.

4. Policies and integrity

Every 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

The guidelines address, among other things:

• Correct consumer matching.
• Substantiation by records.
• Correct balances, status, dates, and liability.
• Prevention of duplicative reporting.
• Transfers and sales of accounts.
• Prevention of re-aging.
• Reasonable dispute investigation.
• Oversight of service providers.
• Prompt updating and correction. Consumer Financial Protection Bureau+1

Appendix 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.

VI. File access, corrections, and prior recipients

1. Federal file disclosure

Upon request and proper identification, the CRA must disclose:

• All information in the consumer’s file at the time of the request.
• Sources of the information, subject to statutory limits.
• Identified report recipients, generally covering employment recipients for two years and other recipients for one year.
• Other specified file and score information. U.S. Code+1

The 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

2. Free and paid disclosures

Federal law provides:

• At least one free annual disclosure through the centralized nationwide-CRA system.
• Free disclosure after specified adverse-action notices.
• Free disclosures in other circumstances such as certain unemployment, public-assistance, and fraud situations.
• A paid-disclosure ceiling only when no free entitlement applies. U.S. Code+1

The federal paid-disclosure ceiling is $16 for calendar year 2026. Federal Register

Montana’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.

3. Resellers

A 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.

• If yes, it must correct or delete within 20 days.
• If no, it must forward the dispute and all relevant information to each source CRA.
• The source CRA’s results go to the reseller, which must immediately reconvey them to the consumer. U.S. Code

VII. Reporting clocks and status changes

1. Federal ordinary collection-account clock

For 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

In formula form:

Federal ordinary reporting endpoint=DOFD+180 days+7 years\text{Federal ordinary reporting endpoint}

\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.

Federal 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.

2. Montana’s separate seven-year language

Montana’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

Because 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.

Therefore:

• The federal clock must be calculated.
• The Montana statutory date must also be identified.
• The account should not be assumed reportable merely because the federal period has not expired.
• The account should not be assumed unreportable merely from a guessed Montana trigger.

3. Sale, assignment, payment, and settlement

The federal clock does not restart when:

• The creditor sells the account.
• A debt buyer acquires it.
• A new agency receives placement.
• A servicer changes.
• The consumer makes a later payment.
• The account is settled. U.S. Code+2

Those later events can require status and balance updates, but they do not create a new delinquency preceding the original charge-off or collection action.

4. Paid and settled accounts

No general Montana or federal rule found here requires automatic deletion solely because the account is paid or settled.

What must remain accurate includes:

• Current balance.
• Whether the account remains open or closed.
• Whether the consumer still owes any contractual amount.
• Whether the account was paid in full or settled for less.
• Dates and payment status.
• Disputed status where applicable.
• The historical delinquency and reporting-age dates.

In 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

5. Transfers and duplicate reporting

Federal 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.

Depending on the facts, accurate treatment may require:

• The former furnisher to show no current balance if it transferred all rights and is no longer owed money.
• The purchaser to report its actual current balance and ownership role accurately.
• Both furnishers to preserve the original DOFD.
• Prevention of duplicate current balances that make one obligation appear to be two.
• Correction of transferred-account records where source data was incomplete. Consumer Financial Protection Bureau+2

No 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.

VIII. State/federal preemption map

The statutory preemption provisions are explicit. U.S. Code+2

The 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

IX. Controlling and materially relevant decisions

Supporting sources: Justia Law+9

Current-status qualification

The 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

No controlling Montana appellate decision was located that directly reconciles current §§31-3-112 or 31-3-124 with the modern FCRA grandfather provisions.

X. Operational workflow matrix

XI. Bounded examples

Example 1 — CRA dispute, direct furnisher dispute, and FDCPA validation are not substitutes

CRA route

• Day 0: CRA receives a specific dispute.
• By five business days: CRA must notify the furnisher.
• Ordinary completion: 30 days after CRA receipt.
• 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.
• After completion: Results and revised report are due within five business days.

Direct furnisher route

• Day 0: Furnisher receives a complete dispute at a qualifying address.
• Completion period: The same general federal period applicable to CRA reinvestigation.
• If inaccurate: Furnisher must notify every CRA to which it furnished the inaccurate information.

FDCPA route

• The collection pause arises only if the separate §1692g predicates are met.
• Neither CRA filing nor direct furnishing dispute automatically stops calls, letters, suit, or contractual accrual.

Claims: S_MT-P10-C015–C027 and C046 below.

Example 2 — Federal reporting-age clock

Assumptions

• Date of first delinquency immediately preceding charge-off: January 15, 2020.
• No curing payment resets the account before charge-off.
• Ordinary federal collection-account rule applies.
• No high-value-report exception.

Step 1:

January 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:

July 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.

This 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.

Claims: S_MT-P10-C030–C033.

Example 3 — Paid settlement versus deletion

Hypothetical facts

• Contractual balance before settlement: $5,000.
• Written settlement amount: $3,000.
• Consumer pays $3,000.
• Agreement releases the remaining $2,000.
• No interest or additional charge remains due.

Arithmetic:

$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.

But an accurate notation such as:

• Current balance: $0.
• Account closed.
• Settled or paid for less than full contractual balance.

is not automatically subject to deletion merely because the settlement was completed.

No score increase or deletion date is guaranteed.

Claims: S_MT-P10-C034–C036.

Example 4 — Sold account and duplicate-balance risk

Assumptions

• One obligation has a true current balance of $1,200.
• Original creditor sells all rights.
• Debt buyer becomes current owner.

Potentially misleading presentation

• Original creditor reports current balance: $1,200.
• Debt buyer reports current balance: $1,200.

Apparent aggregate current balance:

$1,200+$1,200=$2,400$1,200+$1,200=$2,400$1,200+$1,200=$2,400### Potentially accurate transfer presentation

• Original creditor reports transferred/sold and current balance $0.
• Buyer reports current balance $1,200.

Aggregate current balance:

$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.

Claims: S_MT-P10-C037–C038.

Example 5 — Reinsertion

Sequence

1. CRA deletes an item after it cannot be verified.
2. Furnisher later certifies that the information is complete and accurate.
3. CRA reinserts the item.
4. CRA must notify the consumer within five business days after reinsertion.
5. The notice must identify the furnisher and explain the right to place a dispute statement.

The five-business-day period begins after reinsertion, not after the original dispute or the furnisher’s certification.

An exact calendar date is held because no reinsertion date, time zone, holiday calendar, or delivery method is supplied.

Claims: S_MT-P10-C018–C020.

Example 6 — Incomplete direct dispute

Facts

The consumer sends: “My credit report is wrong. Fix it,” with no account number, no disputed field, and no supporting information.

The furnisher may reasonably determine that the dispute lacks sufficient information. If it does:

• It need not conduct the full direct-dispute investigation.
• It must notify the consumer within five business days after that determination.
• The notice must identify why the dispute was insufficient and what information is needed.

If 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.

Claims: S_MT-P10-C025–C027.

Example 7 — Montana and federal CRA dispute periods

Montana says “within a reasonable period.” Federal law imposes the more concrete 30-day period, subject to the 15-day extension.

For a nationwide CRA subject to both:

• The CRA cannot use Montana’s open-ended wording to ignore the federal 30-day deadline.
• 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.

Claims: S_MT-P10-C004–C007, C013, and C015–C020.

Example 8 — Security freeze does not halt existing-account collection

Facts

• Consumer places a nationwide freeze electronically.
• CRA places the federal freeze by the applicable one-business-day deadline.
• A collection agency acts for an existing account owner.

The 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.

It also does not:

• Delete the account.
• Stop furnishing.
• Stop collection.
• Resolve a dispute.
• Improve a score.

Claims: S_MT-P10-C011–C012.

XII. PASS-10 source register

XIII. PASS-10 claim register

XIV. Component coverage and gap table

XV. Researcher self-check

Freshly read on October 26, 2026

• 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.
• Montana security-freeze placement, timing, lifting, exceptions, and fee statutes.
• Montana Consumer Data Privacy Act’s FCRA activity exemption and the relevant enacted 2025 bill pages.
• Current federal FCRA:CRA file access.CRA disputes and resellers.Obsolescence.Furnisher accuracy, DOFD, negative-information notice, investigations, and enforcement boundary.Preemption.Nationwide freezes.
• Current Regulation V definitions, furnisher policies, direct disputes, and Appendix E.
• 2026 federal file-disclosure charge adjustment.
• October 2025 CFPB preemption interpretive rule.
• Full publicly available Montana and federal appellate opinions listed in the source register.
• The current CFPB status pages confirming the July 11, 2025 medical-rule vacatur.

Access-limited or secondary

• The official current ARM 23.19.301 body was not directly retrievable; a current secondary full-text compilation and rule history were used.
• Montana Supreme Court opinions were read through full public opinion reproductions where an official court PDF was not located.
• Gorman, Nelson, and Aargon were read through full public appellate opinion reproductions; official Ninth Circuit PDFs were used for Gross, Shaw, and Carvalho.
• No paid citator or exhaustive Montana trial-court docket was used.

Bounded negative searches

No current public source located in this focused pass established:

• A Montana law requiring automatic deletion of a paid or settled ordinary consumer debt.
• A Montana law requiring every furnisher to provide a signed original contract during a credit-report dispute.
• A general Montana requirement to delete the seller’s tradeline whenever a debt is sold.
• A general Montana duty to transfer every historical dispute record to a successor owner.
• A controlling Montana appellate decision reconciling §31-3-112’s seven-year language with the federal DOFD-plus-180-day clock.
• A controlling Montana appellate decision comprehensively reconciling §31-3-124 with modern §1681t preemption.
• A current Montana-specific public final order addressing ordinary debt-buyer furnishing.

Those bounded results are not proof that no unpublished order, contract duty, local law, tribal law, special-sector provision, or later authority exists.

Not read or resolved

• 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.
• Any named consumer, creditor, collector, debt buyer, servicer, CRA, or provider status.
• 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.
• Complete post-2025 Montana legislative and special-session currentness.
• Complete Montana administrative-rule amendment history.
• Full damages, attorney-fee, punitive-damages, limitation, and standing analysis beyond the narrow boundaries stated.
• The unreviewed P8 or P9 conclusions as accepted premises.

Exact 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.

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.

END S_MT PASS-10