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

SettleADebt — Wisconsin S_WI PASS-04

Credit reporting, disputed information, settlements, and reporting consequences

Research baseline: October 22, 2026 Actual fresh source-access date: October 26, 2026, Pacific / October 26, 2026, UTC Method: Regular Chat, public-source research. PASS-01, PASS-02, and PASS-03 remain saved but unreviewed; none is treated as an accepted legal foundation.

Scope: Ordinary unsecured consumer debts, with separate treatment of original creditors, collection agencies, debt purchasers, furnishers, consumer reporting agencies, and report users. Medical, bankruptcy, judgment, and other sector-specific issues are addressed only at necessary reporting boundaries.

1. Critical current-law findings

The 2025 federal medical-debt reporting ban is not operative

The Consumer Financial Protection Bureau issued a broad medical-debt credit-reporting rule in January 2025. On July 11, 2025, the U.S. District Court for the Eastern District of Texas vacated it in Cornerstone Credit Union League v. CFPB, No. 4:25-cv-00016, Document 52.

The CFPB's current FCRA compliance page expressly acknowledges the vacatur and identifies its former medical-debt rule materials as reference-only. Consequently, the 2025 rule cannot be presented as an operative nationwide prohibition on medical-debt credit reporting. Existing FCRA provisions, including special medical-information restrictions, veteran-medical-debt protections, and any applicable CRA policies remain separate questions. Consumer Financial Protection Bureau+2

Wisconsin's disputed-debt rule differs from federal FCRA investigation duties

Wis. Stat. §427.104(1)(c) prohibits a qualifying debt collector from communicating adverse creditworthiness information with knowledge or reason to know that it is false. Paragraph (f) separately prohibits communicating the existence of a debt known to be reasonably disputed without disclosing the dispute.

In Turner v. Gene Dencker Buick-Pontiac, Inc., the Wisconsin Court of Appeals held that a bank's initial oral request to flag a debt as disputed did not excuse subsequent monthly reports omitting that status. Every relevant disclosure required accurate disputed-status treatment. The case demonstrates that even a genuine underlying debt can produce a separate reporting-conduct violation. law.justia.com+1

These Wisconsin provisions do not automatically cover every reporting relationship. Chapter 427 has its own consumer-transaction, deferred-payment, actor, and territorial predicates. Federal FCRA furnisher obligations, by contrast, attach according to the federal consumer-reporting relationship.

A consumer dispute can trigger different legal processes

A dispute sent directly to a furnisher may trigger Regulation V's direct-dispute investigation process, subject to its address, information, subject-matter, and other exceptions. A dispute sent to a consumer reporting agency triggers FCRA §611 reinvestigation duties and, following the CRA's statutory referral, can activate the furnisher's separate §623(b) obligations.

The CRA generally has 30 days, potentially extended by up to 15 additional days when the statutory conditions are satisfied. This is not a rule that every disputed item must be deleted after 30 days. uscode.house.gov+2

The remainder of the report tests these rules against actual actor coverage, deadlines, remedies, settlement status, obsolescence, preemption, and controlling cases.

2. Federal preemption substantially limits Wisconsin reporting claims

This is a material qualification to the Wisconsin reporting duties.

15 U.S.C. §1681t(a) generally preserves nonconflicting state law, but §1681t(b)(1)(E) and (F) expressly preempt important subject matters involving the contents of consumer reports and furnisher responsibilities. Section 1681h(e) separately addresses defamation, invasion-of-privacy, and negligence claims involving specified credit-report disclosures.

In Purcell v. Bank of America, 659 F.3d 622 (7th Cir. 2011), the Seventh Circuit rejected a reading that would preserve otherwise-preempted state common-law claims simply because malicious furnishing was alleged. It held that §1681t(b)(1)(F) reaches state common-law claims as well as statutes within its subject matter. uscode.house.gov+2

There is also a current administrative-interpretation change: the CFPB withdrew its 2022 narrow-preemption interpretation in May 2025 and published a replacement broad-preemption interpretation applicable October 28, 2025, at 90 Fed. Reg. 48710. That interpretation is agency guidance, not an amendment to the FCRA or a binding judicial ruling on every Wisconsin statute. federalregister.gov+1

Practical research consequence: The merits of a Wisconsin §427.104 credit-reporting violation and whether a particular state-law cause of action survives federal preemption are distinct questions. Turner establishes the Wisconsin-law merits ruling on its facts; it does not itself resolve every later federal preemption issue.

3. Actor, debt, and jurisdiction coverage

The starting question is not simply whether the item is a collection account. It is which actor communicated which information, to whom, about what underlying transaction.

Wisconsin ch. 427 applies to an attempt to collect an alleged debt from a qualifying consumer-credit or other consumer transaction with deferred payment, expressly including primarily agricultural transactions. The Wisconsin Consumer Act’s general definitions, exclusions, and territorial rules remain relevant; a purely business-purpose debt is not automatically within this chapter, while an original creditor can be covered. Wisconsin's licensed-collection-agency rule, DFI-Bkg 74.16, uses its own licensee trigger and need not be consumer-purpose limited. law.justia.com+3

Claim notation: In the remaining tables, C001 means S_WI-P04-C001, and S001 means S_WI-P04-S001. These are new PASS-04 identifiers, not aliases claiming review or acceptance of an earlier pass.

C001, C004, C007–C008, C049.

The FCRA defines a consumer as an individual, a consumer report by the statutory communication-and-purpose test, and a CRA by its business of assembling or evaluating consumer information for third parties. A report user must have a permissible purpose. Section 1681b(a)(3)(A) includes credit decisions and review or collection of an account; this does not authorize indiscriminate report access. uscode.house.gov+1

4. Before a collector reports: Wisconsin, FDCPA, and Regulation F

4.1 Wisconsin false-credit and disputed-status duties

For a covered state actor:

• §427.104(1)(c): Adverse creditworthiness disclosures cannot be made with knowledge or reason to know the information is false.
• §427.104(1)(e): Reputation-affecting disclosures to persons without legitimate business need are restricted, subject to statutory authorization.
• §427.104(1)(f): If the debt is known to be reasonably disputed, disclosing or threatening to disclose its existence without the dispute is prohibited.
• DFI-Bkg 74.16(3), (6), and (7): Parallel prohibitions apply to Wisconsin collection-agency licensees.

The word known matters. These provisions do not automatically compel a collector to accept every allegation as established fact. But a legitimate underlying obligation is not a license to transmit a wrong amount or omit a known disputed status. law.justia.com+1

4.2 Regulation F debt parking

Under 12 C.F.R. §1006.30(a), a covered federal debt collector must not furnish information about a debt to a CRA until it either:

1. speaks with the consumer about the debt in person or by telephone; or
2. mails a letter or sends an electronic message about the debt, then waits a reasonable period while accepting and monitoring delivery-failure notifications.

The official interpretation supplies 14 consecutive days after sending as a reasonable period, not 14 business days. If nondelivery is reported during that period, the collector must qualify again before furnishing. The rule expressly exempts furnishing to a specified nationwide specialty CRA maintaining check-writing-history information.

This is not a blanket ban on all original creditors or a requirement that the collector wait until the federal 30-day validation period has ended. Valid electronic communication must independently meet its applicable delivery requirements. C009. Consumer Financial Protection Bureau

Regulation F §1006.30(b) also prohibits certain transfers, sales for consideration, or placements for collection of debts known or reasonably known to have been paid, settled, or discharged in bankruptcy. The regulation has exceptions, including specified transfers to the debt's owner, exchanges required by law, and certain securitizations. This is a rule about covered debt collectors transferring covered debts, not a universal prohibition on retaining historically accurate credit-report data. Consumer Financial Protection Bureau

4.3 FDCPA disputed-status furnishing

Under 15 U.S.C. §1692e(8), a federally covered collector cannot communicate or threaten credit information it knows or should know is false, including failing to communicate that a debt is disputed.

The disputed-status duty is not confined to a timely written §1692g validation dispute. Oral or late disputes can supply knowledge for §1692e(8), although the legal consequence of a particular communication still requires the actual facts. The Wisconsin provision, federal disputed-status provision, and §1692g verification pause must be separately labeled. C010–C011. uscode.house.gov+1

5. FCRA investigation architecture

5.1 Initial furnisher duties: §623(a)

15 U.S.C. §1681s-2(a) imposes these material responsibilities:

• Do not furnish information known, or reasonably supported by specific knowledge, to be inaccurate; the statute defines reasonable cause carefully and does not equate a bare consumer allegation with proof.
• Correct and update information subsequently determined incomplete or inaccurate.
• When the consumer disputes completeness or accuracy directly, do not continue furnishing the item without indicating that it is disputed.
• Report the applicable commencement-of-delinquency month and year for charged-off or collection accounts under §623(a)(5).
• Where §623(a)(7) applies, a financial institution extending credit and regularly furnishing negative information must provide the specified written notice before or within 30 days after initially furnishing that negative information. A notice can cover subsequent furnishing for the same account; it is not a universal prior-consumer-contact rule.

The §623(a) duties are primarily enforced by designated government authorities. There is no general individual damages action directly under §623(a); §1681s-2(c) and (d) expressly restrict private enforcement. C019, C025, C027. uscode.house.gov

5.2 CRA-mediated dispute: §§611 and 623(b)

The consumer disputes information with the CRA. The CRA then:

1. conducts a reasonable reinvestigation, free of charge, unless a statutory exception applies;
2. forwards the dispute and all relevant information to the furnisher;
3. assesses whether the item is accurate, incomplete, unverifiable, or requires modification; and
4. notifies the consumer of the results.

The furnisher's §623(b) duty arises after notice from the CRA under §1681i(a)(2), not simply after receiving an ordinary consumer letter. It must investigate, review relevant information, report the result, notify other applicable nationwide CRAs of inaccuracies, and modify, delete, or permanently block the disputed item where the statute requires.

The furnisher's deadline is coordinated with the CRA reinvestigation period, not a fresh automatic 30 days beginning whenever the furnisher opens its mail. C012–C020. uscode.house.gov+1

5.3 Direct-to-furnisher dispute: Regulation V §1022.43

A direct dispute requires a reasonable investigation where it concerns the consumer's liability, account terms, payment performance, or other creditworthiness information furnished about an account or relationship. But the rule excludes several categories when raised directly with that furnisher, including:

• identifying information unrelated to liability;
• past or current employer identity;
• credit inquiries;
• public-record information not supplied by that account furnisher;
• fraud/active-duty alerts;
• information supplied by another furnisher; and
• disputes reasonably believed to originate from certain credit-repair organizations or their forms.

The consumer must send the dispute to a qualifying address and provide sufficient account identification, the disputed information, the reason, and reasonably required supporting information. If the furnisher has supplied an eligible dispute address, sending to an arbitrary other office does not automatically invoke §1022.43. Consumer Financial Protection Bureau

The furnisher must review relevant material, investigate reasonably, and send results to the consumer within the period that §611 would allow a CRA. If inaccurate data was furnished, the furnisher must promptly correct the information with each CRA to which it furnished that inaccurate information. A qualifying frivolous, irrelevant, or insufficient dispute can be rejected with reasons and missing-information guidance, provided within five business days after the determination.

A direct furnisher dispute does not, by itself, start the separate §623(b) private-liability pathway. Nor does it automatically stay debt collection. C021–C025. Consumer Financial Protection Bureau

5.4 Reporting/investigation outcome matrix

C013–C024, C043–C045, C050.

6. Relative clocks, notices, and decision-makers

A reporting-dispute clock, a validation period, a reporting-age limit, and a lawsuit limitation period are four different legal clocks.

The CRA's forwarding deadline is measured from CRA receipt, while the furnisher's §623(b) process is activated by CRA notice. Subsection 611 also provides a limited right to a dispute statement: when reinvestigation does not resolve the dispute, the consumer can submit a brief statement; a CRA providing assistance may limit it to 100 words and must generally flag it in subsequent reports containing the item. On consumer request, the CRA must give specified prior recipients notice—generally recipients within six months, or two years for employment-related reports. C013–C018, C024, C027–C028. uscode.house.gov

There is no basis here for promising a real-world calendar deadline without the actual delivery/receipt records, applicable jurisdiction, method, holiday calendar, and whether an extension was lawfully triggered.

7. Reporting status, obsolescence, and settlement consequences

7.1 First delinquency and re-aging

For an account placed for collection or charged off, 15 U.S.C. §1681c(c) ties the seven-year reporting period to the expiration of a 180-day period beginning with the commencement of the delinquency immediately preceding collection/charge-off.

The operative reference point is commonly called the date of first delinquency (DOFD).

Statutory exclusion boundary=DOFD+180 days+7 years\text{Statutory exclusion boundary} = \text{DOFD} + 180\text{ days} + 7\text{ years}Statutory exclusion boundary=DOFD+180 days+7 yearsThat is a ceiling on reporting under the covered provision, not a promise that a CRA will always report until the final day. Section 1681s-2(a)(5) separately requires covered furnishers to provide the month and year of the qualifying delinquency.

A new sale, new collector, updated date reported, partial payment, settlement, or charge-off does not by itself create a new original delinquency that permits restarting the FCRA exclusion period. Debt-enforcement limitations and potential revival are distinct and deliberately not decided here. C027–C029. uscode.house.gov

7.2 Reporting status matrix

C026–C032, C043–C048.

A historically accurate charge-off is not the same as a current unpaid balance. A settlement that satisfies the obligation can correctly coexist with older negative payment history. In Frazier v. Dovenmuehle Mortgage, Inc. (7th Cir. 2023), the court rejected a materially-misleading-reporting theory after examining a settled, closed, zero-balance account and its historical delinquency coding in context. This was a mortgage-servicing case, so the holding is used only for its FCRA reporting analysis, not as Wisconsin mortgage-sector research. media.ca7.uscourts.gov

7.3 Public records and bankruptcy

Section 1681c(a) distinguishes different categories:

• Bankruptcy cases: generally ten years from entry of the order for relief/adjudication.
• Civil suits, civil judgments and arrest records: generally seven years from entry or until the governing statute of limitations expires, whichever is longer.
• Paid tax liens: generally seven years after payment.
• Collection/charge-off accounts: the DOFD-plus-180-days reporting rule.
• Other adverse information: generally seven years, subject to statutory exceptions.

Subsection (b) contains exceptions to some age exclusions for particular high-value credit, life-insurance, and employment purposes, including a credit transaction involving or reasonably expected to involve principal of $150,000 or more. This report does not investigate those secondary use cases.

A bankruptcy's appearance on a credit report, discharge of personal liability, accuracy of a trade balance, lien enforceability, and collection legality are separate issues. C028–C029, C048. uscode.house.gov

8. Medical debt: current authority and voluntary practice

Controlling status

The July 11, 2025 Cornerstone judgment vacated the January 2025 CFPB medical-debt amendments, including the proposed additions to Regulation V §§1022.30 and 1022.38. The signed district-court order and judgment were read, including the remedy language. The current CFPB compliance page acknowledges the vacatur.

Consequently, there is no operative nationwide CFPB rule from that 2025 action categorically removing medical collections from consumer reports. storage.courtlistener.com+2

Separate, surviving categories

The current TransUnion and Experian publications describe the three nationwide CRAs' voluntary removal of paid medical collection debt, an exclusion for qualifying small medical collection balances, and a one-year waiting practice for unpaid medical collections. Publisher wording around a $500 boundary and original versus remaining balance must be checked for each product and policy; the precise equality case is held rather than silently generalized. These practices do not bind every specialty CRA. TransUnion+2

No complete current Wisconsin medical-debt sector statute, provider-charity-care program, or regulation was established in this focused pass.

9. State–federal claims, remedies, and preemption

C005–C006, C033–C035, C039–C041, C050–C051.

Wisconsin statutory damages are not automatically the federal award

Wis. Stat. §427.105(1) provides that an injured person may recover actual damages and the penalty provided by §425.304, expressly including qualifying emotional-distress damages. Section 425.304's own penalty calculation is the greater of:

min⁡(max⁡(2×finance charge,$100),$1,000)\min(\max(2\times\text{finance charge},$100),$1{,}000)min(max(2×finance charge,$100),$1,000)or the actual damages under that section. The Wisconsin annotation to Kirk v. Credit Acceptance Corp. cautions against adding both statutory and actual damages under §425.304 itself. The exact interaction with §427.105’s separate actual-plus-penalty language requires claim-specific analysis. It cannot simply be described as an automatic $1,000 or an automatic stack with federal awards.

Section 425.307 contains alternative one- and two-year customer-action triggers and a six-year outer restriction, together with a defensive-use provision. Its actual triggering structure—and its applicability to a particular injured plaintiff—must be determined separately from the FCRA's limitations period. Justia Law+2

Federal limitations, causation, and concrete injury

Under §1681p, FCRA actions generally must be brought by the earlier of two years after discovery of the violation forming the basis for liability or five years after the violation occurs, subject to statutory particulars. Sections 1681n and 1681o distinguish willful from negligent noncompliance.

In TransUnion LLC v. Ramirez (2021), the Supreme Court distinguished misleading information actually disseminated to third parties from certain misleading information remaining only in internal CRA files. Statutory noncompliance does not automatically establish Article III concrete injury for a federal damages case. USCode+3

Potential overlapping FDCPA, FCRA, and Wisconsin injuries must be separately attributed. No double recovery, punitive award, statutory minimum, class treatment, or litigation outcome is assumed here.

10. Controlling case grid and important limitations

The following decisions were reviewed for the narrow reporting, dispute, accuracy, preemption, and standing issues. A published majority holding is separated from a dissent, a remand, and a district-court order. No complete commercial citator was available, so the currentness assessment is bounded to public sources checked October 26, 2026.

Primary opinion URLs appear in the source register below. These are separate holdings, not nine votes for one general rule. Especially:

• In Ewing/Webster, a reported dispute could constitute concrete reputational harm, but Ewing's collector retained its bona-fide-error defense, while Webster's collector could not rely on an unmonitored fax system as reasonable preventive procedures. Seventh Circuit Court of Appeals
• In Chuluunbat, treating every ownership challenge as requiring a CRA to resolve contract law would overstate the CRA's role. Treating all assignment errors as legally uninvestigable would also overstate the holding. Seventh Circuit Court of Appeals
• In the 2024 Frazier appeal, the rejection of the consumer's claim was a majority result. The contrary discussion in the separate Hamilton dissent is not controlling law. Seventh Circuit Court of Appeals
• Purcell is especially relevant to Wisconsin because its preemption holding directly limits state-law reporting theories that might otherwise appear actionable under §427.104. Seventh Circuit Court of Appeals

Later-treatment and version limitations

The opinions were checked through current public official-host reproductions, and the current federal provisions were separately read. No later public decision identified during this investigation was found to expressly overrule these narrow controlling holdings. That is not a complete subsequent-history or citator certification. In particular, older state reporting merits cases must be tested against later federal preemption precedent and current statutory versions before using them to assert a viable cause of action.

11. Hypothetical evidence and decision workflows

All examples are invented, with no individual or company data. Dates are relative unless a provision supplies a precise day-counting rule. The fact that a person can make a dispute is not a representation that its truth has been adjudicated.

Example 1 — Original creditor reports a balance the consumer disputes

Known: An original Wisconsin credit-card creditor reports $3,400. Its records show $3,100 in principal and $300 in assessed charges. The consumer asserts that $200 of the charges is unauthorized.

Missing: Contract and fee authorization, complete payments/credits, whether the creditor received a sufficiently specific dispute, Wisconsin transaction coverage, and whether the data was furnished after dispute receipt.

Decision flow: Wisconsin §427.104 can govern qualifying collection communication; federal §623(a) accuracy and disputed-status duties can govern furnishing. If a proper Regulation V direct dispute reaches the furnisher, its investigation clock applies. If the CRA refers the dispute, the independent §623(b) duties apply.

Numerical branches: 3,100 + 300 = $3,400. If investigation establishes $200 unauthorized, a corrected balance would be $3,400 − $200 = $3,200, assuming no further activity. If all charges are authorized and no payments are missing, the $3,400 balance might be accurate while the pending dispute status still needs appropriate treatment.

Failure case: Neither an unsupported consumer assertion nor the existence of a valid $3,100 principal proves the full amount or reporting conduct lawful. C002–C003, C019–C024.

Example 2 — Third-party collector wants to report before contact

Known: A federally covered collection agency sends a qualifying letter about a debt on relative Day D.

No undeliverability: It monitors a reasonable period. The official Regulation F example recognizes 14 consecutive days after D. If no delivery-failure notice arrives during that period, the collector may satisfy §1006.30(a)'s pre-furnishing condition.

Delivery failure on day 8: The collector cannot rely on that first mailing to furnish. It must complete another qualifying contact method and meet its conditions. A new letter creates a new monitoring window.

Alternative: Actually speaking to the consumer in person or by telephone about the debt can satisfy the separate route.

Missing: Collector federal status, actual delivery/log evidence, communication content and recipient, any statutory specialty-CRA exception, and other accuracy/dispute conditions.

Failure case: Furnishing on Day D merely because a letter was generated is not enough. Waiting 14 days does not prove the balance accurate. C007, C009.

Example 3 — Late oral dispute outside the validation period

Known: The original federal validation period has expired. The consumer calls the covered collector and says an outstanding balance is wrong.

Result: A late oral dispute ordinarily does not trigger the §1692g(b) written-dispute verification pause. But it can give the collector knowledge that the account is disputed, relevant to §1692e(8) if the collector later supplies credit information. Qualifying Wisconsin §427.104(1)(f) can independently matter.

Missing: Exactly what the consumer said, whether the debt is reasonably disputed, actual reporting event, and actor coverage.

Failure case: “The 30 days expired, so the collector can report it as undisputed forever” is not a valid general conclusion. Equally, “one oral late call forces deletion” is unsupported. C003, C010–C011.

Example 4 — CRA-mediated versus direct furnisher dispute

Known: A consumer believes a payment was omitted and sends the same ledger to either a CRA or a furnisher.

Missing: CRA receipt, whether CRA actually referred, exact documents, direct-dispute address, and applicable exception.

Failure case: An ordinary consumer letter is not evidence that a CRA gave §623(b) notice. C012–C025.

Example 5 — Thirty versus forty-five days, with new evidence

Let D be the CRA's actual date of receipt of a qualifying dispute.

Branch A: No relevant additional information

• Base investigation period: 30 calendar days beginning on D.
• Maximum §611 period on this branch: 30 days.
• After completion, results generally due within five business days.

Branch B: New material information during initial 30-day period

• Base: 30 days.
• Potential extension: up to 15 days.
• Arithmetic ceiling: 30 + 15 = 45 calendar days.
• Extension unavailable if the CRA has already found the item inaccurate/incomplete or unverifiable within the initial period.

Branch C: Additional material supplied after initial 30-day period

The late submission does not retroactively activate the §611(a)(1)(B) extension for an otherwise completed 30-day period.

Missing: Receipt date, what information is genuinely relevant, when received, investigation finding, holidays for the separate business-day notices.

Failure case: A purported 45-day automatic period for every dispute is incorrect. C013–C018.

Example 6 — Fully settled account still displays original unpaid balance

Known: A $4,800 account was settled under a hypothetical binding agreement for $2,100, paid in full, and the agreement discharged the remaining balance.

Arithmetic:

• Earlier claimed debt: $4,800.
• Settlement consideration actually paid: $2,100.
• Reduction: $4,800 − $2,100 = $2,700.
• Current outstanding amount after completed discharge: $0, assuming no other enforceable claim.

An account reported with a current $4,800 unpaid balance could be inaccurate. A historical original-balance field of $4,800, paired with a $0 current balance and an accurate settled/paid-for-less status, can tell a different and potentially accurate story.

Missing: Actual settlement release, conditional installments, final posting, account ownership, field definitions, historic status, and creditor's reporting policies.

Failure case: Correcting current balance to zero does not automatically remove accurately reported prior delinquency or charge-off. C026, C044, C046.

Example 7 — Paid medical collection

Known: A hypothetical $350 hospital-billing collection account has been fully paid.

Current law: The vacated 2025 CFPB medical-debt rule supplies no operative universal deletion right. A nationwide CRA's currently published paid-medical-collection exclusion policy may exclude it, provided the item is actually classified within that program.

Missing: Which CRA, whether it is a medical collection or a general credit-card debt, original reported balance, date and manner of payment, whether it is veteran medical debt, and applicable voluntary-policy version.

Failure case: “It was a medical expense, therefore the current federal statute bans its reporting” is incorrect. A policy about three major nationwide CRAs is not automatically a statutory duty of all specialty CRAs. C030–C032.

Example 8 — New collector and an old charged-off account

Known: Hypothetical original delinquency D never cured; account later charged off, then sold twice, and a new collector starts furnishing.

Statutory arithmetic:

Potential exclusion age=180 days+7 years after D\text{Potential exclusion age} = 180\text{ days} + 7\text{ years after D}Potential exclusion age=180 days+7 years after DThe buyer's acquisition date and the new collector's first-report date do not replace D in that formula.

Missing: Actual start of uninterrupted delinquency, any cure/redefault, original records, furnishing DOFD, statutory exception under §1681c(b), and whether CRA policy removes the item earlier.

Failure case: A new collector reporting a new account cannot lawfully manufacture a new underlying delinquency date to extend the reporting life. The ordinary collection-lawsuit limitations period is not calculated from this FCRA reporting formula. C027–C029, C047.

Example 9 — Duplicate accounts and disputed ownership

Known: A consumer report shows the original creditor and a debt buyer, both apparently showing a collectible $2,000 balance for the same account. The consumer challenges ownership.

Factual path: Verify account numbers, assignment dates, source ledgers, actual balance, whether the original creditor sold the receivable or retained collection rights, and whether both reports misleadingly imply two independent debts.

Legal path: A complex contract or chain-of-assignment dispute that requires an adjudication may exceed what a CRA is required to determine from objective file data under Chuluunbat. But objectively wrong owner identity or duplicate unpaid balances cannot be dismissed as inherently uninvestigable merely by labeling them a legal issue.

Failure case: Two tradelines are not automatically prohibited; two simultaneous inaccurate collectible balances may still be problematic. C043, C047, C050.

Example 10 — Claim of credit denial and damages

Known: A consumer alleges an inaccurate negative item caused denial of credit. A CRA reinvestigated; the denial letter cites both delinquency information and debt-to-income ratio.

Questions: Was there a concrete inaccuracy? Did the defendant receive the statutory notice triggering the alleged duty? Was the investigation unreasonable? Did a third party actually receive the information? Which factor caused the denial or other injury? Was the conduct negligent or willful?

Federal amount branches:

• Willful FCRA violation: potential statutory range $100–$1,000 or proven actual damages under §1681n, with possible punitive damages and fees when legal conditions are satisfied.
• Negligent FCRA violation: proven actual damages and applicable fees under §1681o.
• §623(a)-only allegation: generally no ordinary private §1681n/o cause from that duty alone.
• FDCPA individual case: up to $1,000 additional statutory damages per action, not per letter; actual harm and defenses separate.

Frazier v. Equifax illustrates why a denial alone does not establish CRA causation. TransUnion illustrates why a statutory violation alone does not establish Article III concrete harm.

Failure case: No guaranteed award, automatic credit-score correction, or duplicate statutory payment. C033–C035, C044–C045.

Example 11 — Wisconsin statutory penalty arithmetic without assuming a claim survives

Known only for illustration: A qualifying transaction has a $160 finance charge.

• Twice the finance charge: 2 × $160 = $320.
• Apply §425.304 minimum $100 and maximum $1,000: $320.
• The separate actual-damages comparator under §425.304 might produce a different amount if established.

But §427.105 contains separate actual-damages language; the exact interaction must be resolved for the claim. More importantly, federal furnishing preemption, injury, limitations, and defendant status could bar a particular reporting claim before damages are reached.

Failure case: The $320 calculation does not establish entitlement to $320. C005–C006, C033.

Example 12 — Credit freeze versus collection/reporting

Known: An individual places a qualifying federally mandated free freeze with a nationwide CRA.

What a freeze principally does: Restricts prospective access to the consumer report as specified, including exceptions.

What it does not automatically do: Delete existing accurate accounts, prevent all furnisher updates, cancel debt, stop collection calls, or bar every existing-account review.

Missing: CRA type, federal/state exceptions, existing-account collection purposes, and which report user seeks access.

Failure case: The older Wisconsin statutory $10 language cannot override federally mandated free nationwide security freezes. C036–C038.

12. Source register — S_WI-P04-S001 onward

Access-date notation: Every row was accessed or attempted October 26, 2026, Pacific and UTC. No individual fetch time is asserted. F = freshly read on the identified public source; O = official original document read; R = reproduction/read-aid read but preferred official Wisconsin integrated text unavailable; H = historical or superseded; V = currently published voluntary policy, not law; P = PDF actual text and pertinent page images inspected; L = located only, or access incomplete. Repeated citations to one document do not create independent authorities.

Wisconsin and federal statutes/rules

Public policies, forms, enforcement routes, and decisions

Status reconciliation: Federal OLRC pages have two explicitly different compilation dates in this register; the FCRA remedies and furnishing pages above were accessed at their /119-120/ versions while most others showed /119-124/. This does not establish that every page is contemporaneously consolidated to the same public law. No relevant intervening enacted change was located in the targeted checks, but that unresolved version discrepancy must be retested in a subsequent currentness pass.

The original Wisconsin Legislature's integrated statute/code fetching limitation likewise remains real. Wisconsin reproductions are text read-aids, not falsely labeled successful official integrated downloads.

13. Consumer access, official instructions, and evidentiary records

Access to reports

Under FCRA §§1681g and 1681j, a consumer can obtain disclosure of information in a CRA's file, subject to the statute's identification and disclosure provisions. The baseline right includes a free disclosure from each nationwide CRA once in a 12-month period, with additional free rights under specified circumstances.

The three nationwide CRAs currently make free reports available weekly through AnnualCreditReport.com. The weekly schedule is a publisher-supported availability policy, broader than the basic annual statutory frequency; it should not be described as an amendment making all specialty CRA files freely available weekly. USCode+2

Section 1681g also addresses sources of information and specified report recipients. A consumer's right to access a CRA file does not automatically compel the CRA to produce a creditor's entire accounting ledger, every internal scoring calculation, or all evidence potentially required in a later lawsuit.

Security freezes

Federal §1681c-1(i) requires nationwide CRAs to provide qualifying security freezes and removals without charge. Wisconsin §100.54 also regulates freezes, with specified access exceptions. The older state provision's facial fee language cannot be treated as authorizing a charge that the applicable federal rule prohibits.

A freeze does not delete accurate negative history, alter a DOFD, terminate a credit obligation, or itself prevent every existing-account collection-related permissible use. Fraud-alert and identity-theft-block procedures remain separate future investigations. C036–C038.

Official forms and instructions

The DFI form expressly warns that information may be shared with agencies or the complained-of business and may be subject to public-records requirements. It was not completed or submitted. Department of Financial Institutions

Evidence to retain versus legally mandatory records

Bounded evidence principle: Documents that are helpful to investigate a report, documents a furnisher must retain to follow reasonable accuracy procedures, documents a CRA must disclose, and evidence needed for a court case are not interchangeable categories.

14. Claim register — S_WI-P04-C001 onward

Every row is a distinct claim, with a supporting source document, an exact operative clause or judicial passage, and conditions. A confidence rating concerns the stated proposition, not a specific consumer's chance of recovering money or obtaining deletion.

This claim register covers material permission, timing, reporting, remedies and preemption conclusions. Citations are to the same document IDs used in the source register, rather than assigning invented new authorities to each subsection.

15. Complete PASS-04 coverage and gap matrix

Status meanings: Answered means the cited authority supports a bounded conclusion; Partial means only specific branches are established; Unresolved means a material legal or factual answer was not verified; Excluded means deliberately reserved for a separate pass.

16. Exact follow-on research holds

The major unresolved points for coordinator review are:

1. Wisconsin preemption reconciliation: Analyze a specifically pleaded Wisconsin §427.104(1)(c) or (f) claim against the current §1681t(b)(1)(F) text, Purcell, Turner, and later Seventh Circuit treatment. Do not label all independent communication harassment or privacy conduct preempted merely because the same account was also furnished.
2. Wisconsin remedies: Independently investigate §427.105, §425.304, §425.307 and any cure, procedural, standing, fee or limitation provisions as applied to distinct injuries, plus federal overlapping recovery.
3. Medical classification and policy: Verify original-versus-current reported balance thresholds, the precise $500 boundary, publisher exclusions, specialty CRA treatment, Wisconsin medical assistance/billing law, and any post-vacatur rulemaking or appeal.
4. Assignment/duplicate data: Obtain controlling authority defining materially inaccurate simultaneous tradelines, original-creditor balance after a bona fide sale, and the boundary between objectively verifiable owner identity and complex contractual legal validity.
5. Currentness: Re-fetch the official integrated Wisconsin statutory/administrative provisions when accessible, compare relevant 2025–26 amendments, reconcile OLRC's different public-law compilation cutoffs, and use an actual subsequent-history/citator pass for decisions.
6. Remaining registry modules: Preserve all PASS-01 to PASS-03 work as unreviewed; keep collection validation, limitation/revival, courts/judgments, garnishment, secured/sector, local/tribal, actual contract/account, and parent-state work explicitly separate.

17. Researcher self-check

Actually read or inspected in this pass: Relevant Wisconsin 2025 statutory reproductions for the narrow WCA reporting, remedy, and freeze gateways; DFI-Bkg 74.16 reproduction; federal FCRA and FDCPA OLRC sections; current CFPB Regulation V and F operative regulations/commentary; FTC, DFI, CFPB, TransUnion and Experian public materials; Wisconsin Turner and the listed Seventh Circuit/Supreme Court opinions; Cornerstone's signed vacatur opinion and judgment; 2025 Federal Register preemption interpretation; and the DFI BCA500 complaint PDF. Material PDF passages were inspected through public page-image views where relevant.

Not successfully verified in preferred original form: Several official Wisconsin Legislature integrated pages; a complete commercial citator or subsequent-history service; a comprehensive Wisconsin DFI adjudication archive; every medical-debt publisher policy at every possible specialty CRA; an actual borrower's original contract, account ledger, credit report or credit-scoring model; and actual mailing, receipt, reporting, or investigation records. The document-source table explicitly distinguishes successful original reads, statutory reproductions, voluntary policies, court-docket mirrors, historical interpretations, and failed/incomplete routes.

Math and deadline check: The 30-plus-15-day CRA extension is conditional, the five-business-day notices have distinct triggering events, the 14-day Regulation F window uses consecutive days, the DOFD-plus-180-days-plus-seven-years formula is not a debt-suit limitation period, and the $100–$1,000 remedies are not automatic or per-letter entitlements. No individualized calendar, actual damages, score change, reporting removal, collection stay, or legal entitlement was calculated.

Procedural limits: No private credit file or person was accessed; no dispute, complaint, application, record request, lawsuit or contact was sent; no account, browser permissions, system, or website was changed. No local write or publication is claimed. This is the author's self-check, not independent review, publication approval, operational approval, or acceptance of Wisconsin PASS-04, the parent state dossier, or A066.

Disposition: PASS-04 research completed as a focused source-supported component, with identified unresolved questions remaining held for coordinator review and later passes.

END S_WI PASS-04.