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

S_WI PASS-05 — Wisconsin PASS-04 correction dossier

Scope: Four authorized correction groups only. This supplements PASS-04; it does not replace the full saved report.

Actual fresh access: October 26, 2026, Pacific (America/Los_Angeles) and UTC. Historical baseline: October 22, 2026. Research: Regular Chat, public primary-source browsing. No Deep Research, Work, external API, Chrome control, filing, contact, or private account access.

Disposition: The federal corrections and Turner pinpoint correction have been substantiated by fresh primary-source reads. Some Wisconsin current-law assertions remain provisional because the operative official text could not be retrieved. One additional material finding emerged: the current text of 15 U.S.C. §1681j was successfully retrieved, revealing a separate statutory 45-day CRA reinvestigation provision that PASS-04's clock discussion must accommodate.

Throughout this correction, P05-C001 means S_WI-P05-C001, and P05-S001 means S_WI-P05-S001. The new IDs do not certify earlier PASS-04 findings.

G1. Corrected federal predicates and exceptions

1. Regulation F §1006.30(b): paid, settled, and discharged debts

Replacement for PASS-04 §4.2; new claims P05-C001–C007

Under 12 C.F.R. §1006.30(b)(1), a covered debt collector may not sell, transfer for consideration, or place for collection a debt that it knows or should know has been paid, settled, or discharged in bankruptcy, except under §1006.30(b)(2).

This is not a prohibition on every transaction involving discharged debt, every transfer by an original creditor, or a historical and accurate report to a CRA.

Complete exception matrix

The exception list does not contain the generic phrase “exchanges required by law.” That phrase must be removed from PASS-04. Consumer Financial Protection Bureau

The official interpretation also clarifies that providing debt information for analytics, scrubbing, or archiving is not necessarily transferring the debt for consideration. Similarly, furnishing accurate information that a debt was paid, settled, or discharged is not itself a transfer of the debt for consideration. The latter communication remains subject to the applicable reporting-accuracy rules. P05-C007.

Separate §1006.30(a) debt-parking rule

Section 1006.30(a) governs furnishing before qualifying consumer contact. It has its own telephone/in-person versus letter/electronic-message pathways and reasonable nondelivery-monitoring period. Paragraph (a)(2) excepts the specified nationwide specialty CRA maintaining check-writing history.

The 14-consecutive-day reasonable-period interpretation belongs to paragraph (a), not to the transfer exceptions in paragraph (b). PASS-04's old C009 may continue to support its narrowly described paragraph (a) conclusion, but it no longer supports the paragraph (b) transfer analysis. Consumer Financial Protection Bureau

2. FCRA §1681s-2(a)(1)(C): the missing address qualification

Replacement for PASS-04 §5.1 and C019; P05-C008–C009

The full statutory structure is:

Corrected conclusion: Specifying a proper dispute address can disapply §623(a)(1)(A) under the literal conditions of (C), but does not eliminate (B), the correction/update and dispute-notation provisions in §623(a)(2)–(3), separate CRA-notice-triggered §623(b), or applicable Regulation V §1022.43 duties. Nor does (C) itself transform every consumer statement into established inaccuracy. USCode

Regulation V's direct-dispute address and sufficiency rules remain independently conditional. Section 1022.43 provides qualified routes involving an address on the consumer report, an address clearly and conspicuously specified for direct disputes, or another business address where neither specified address is available, plus subject-matter exclusions and sufficient dispute information. The §623(a)(1)(B) address test must not be silently replaced with that entire regulatory scheme. P05-C027. Consumer Financial Protection Bureau

G2. Corrected pinpoints and previously missing atomic claims

3. Turner — exact Wisconsin opinion-page mapping

Replacement for PASS-04 S006, C039, and the case grid; P05-C014

I freshly opened the official 16-page Wisconsin Court of Appeals PDF and visually inspected zero-based PDF pages 12, 13, and 14.

The PDF has a cover page, so printed page 12 is not zero-based PDF page 11.

Replacement pinpoint: Turner v. Gene Dencker Buick-Pontiac, Inc., 2001 WI App 28, ¶¶23–27, printed pages 12–14, zero-based PDF indexes 12–14.

The case applied the 1997–1998 Wisconsin statutes and decided Wisconsin merits issues. It did not decide whether a later claim survives Purcell-type federal furnishing preemption or establish modern private damages entitlement. Wisconsin Court System

4. Security freezes — corrected statutory cross-reference

Replacement for PASS-04 S020, C037, and the freeze coverage row; P05-C015–C016

Fresh access now succeeded to the October 15, 2026 OLRC compilation of 15 U.S.C. §1681c-1 at the literal /119-124/ URL. The earlier alternative /119-118/ URL was also opened, but its displayed text identified a different, October 7 compilation. Those URLs and displayed versions are separately recorded in the register.

The correct provisions are:

• §1681c-1(i)(2): Free placement of a security freeze, after the required request and identification.
• §1681c-1(i)(3): Free removal, including temporary removal, with the prescribed request and identification.
• §1681c-1(i)(4): The actual exceptions to a freeze, including specified existing-account review or collection, qualifying assignees and agents, enumerated governmental activities, and other listed permissible uses.
• §1681c-1(j): A different regime protecting minors under 16 and certain legally protected adults through representatives, files or records, and qualifying freezes.

The original PASS-04 attribution of ordinary freeze exceptions to (j) was incorrect. This correction does not undertake the separate protected-consumer or identity-theft dossier. USCode

A freeze does not automatically prevent access for covered existing-account collection activity, cancel a debt, remove tradelines, or halt furnishing. Its statutory exceptions remain conditional, not an unlimited right to access reports.

5. Negative-information notice — separate §623(a)(7) claim

Missing PASS-04 atomic coverage; P05-C010–C012

Actor: A financial institution as defined by 15 U.S.C. §6809 that extends credit and regularly furnishes information in the ordinary course to a nationwide CRA described in §1681a(p).

Trigger: Furnishing negative information about credit extended to a customer. For this subsection, negative information concerns delinquencies, late payments, insolvency, or default.

Timing: Written notice before or no later than 30 days after the qualifying first furnishing. A notice provided before furnishing cannot be buried in the initial credit disclosures under §1637(a).

Delivery/content: The notice must be clear and conspicuous. It may accompany a billing statement, default notice, or other customer materials.

Subsequent reporting: Once a valid notice is provided, later negative furnishing concerning the same transaction, credit extension, account, or customer generally does not require repeated notices.

Safe harbor/exception: Section 623(a)(7)(F) contains a protection involving reasonable compliance policies and procedures or reasonable belief that contacting the consumer is legally prohibited. This is not a blanket exemption from the underlying accuracy provisions.

The statute does not require a financial institution that sends a notice to furnish adverse information. USCode+1

Regulation V Appendix B supplies optional models, not mandatory dispute letters.

A model may be modified only within the appendix's permitted limits without losing its protection. It does not satisfy unrelated investigation or accuracy duties. Consumer Financial Protection Bureau

Old PASS-04 C019 addressed other §623(a) duties, C027 addressed date of first delinquency, and C038 addressed complaints. None supplied the complete §623(a)(7) notice predicates. This is new atomic coverage, not a retroactive declaration that the old claim did.

6. FDCPA remedies — separate §1692k claim

Correction to PASS-04 remedy coverage row; P05-C013

For an actionable FDCPA violation by a covered debt collector, 15 U.S.C. §1692k provides:

• proven actual damages caused by noncompliance;
• in an individual action, such additional damages as the court allows, up to $1,000 per action, not automatically $1,000 per letter or communication;
• in qualifying class actions, separate named-plaintiff treatment and a class-wide additional-damages ceiling of the lesser of $500,000 or 1% of the collector's net worth;
• costs and reasonable attorney's fees in successful actions, subject to the statute;
• a conditional bona-fide-error defense requiring the specified proof and preventive procedures;
• a one-year period from occurrence of the violation; and
• protection for qualifying good-faith conformity with a CFPB advisory opinion under subsection (e).

This is FDCPA §1692k, not FCRA §§1681n/o. Article III concrete-injury requirements, defendant identity, causation, available defenses, and state-court jurisdiction remain case-specific. P05-C013. USCode

G3. Current primary-access and confidence holds

7. Wisconsin official-source failure remains unresolved

A different versioned Wisconsin Legislature route was attempted in this pass for §427.104 and 2025 Act 105. Both returned an inaccessible-source error. Earlier official direct-section and chapter-PDF failures remain documented rather than treated as successful reads.

Consequently, the following PASS-04 assertions are provisional, not accepted as freshly verified current enacted Wisconsin text:

These statements are not erased; their evidentiary status is held pending accessible official enactment text. The pending review should obtain official Wisconsin act/statute/code publications or a genuinely verifiable alternative official copy and examine amendments and effective dates. P05-C017, C024, C026.

8. Free annual report — primary text newly recovered

The current OLRC §1681j page was successfully read in this PASS-05. This resolves the earlier federal primary-access gap for that exact section; there is no reason to continue labeling §1681j itself unread.

§1681j(a)(1): The described nationwide CRAs and nationwide specialty CRAs have a statutory once-per-12-month free-disclosure requirement, with the applicable centralized or streamlined request process.

§1681j(a)(2): A qualifying free annual disclosure must be provided no later than 15 days after receipt of the applicable request.

§1681j(a)(3): A separate reinvestigation provision says that a §611 reinvestigation requested after receiving a report under §1681j(a) must be completed within 45 days after receipt of the dispute request, notwithstanding §1681i(a)(1)'s periods. USCode

This requires a correction to the blanket implication in PASS-04's 30-versus-45-day workflow. There are at least two legally distinct ways a 45-day ceiling can become relevant:

The ordinary 30-day rule is not erased. Nor is it established here that every voluntary weekly report is necessarily a report received under subsection (a) for the special 45-day provision; that classification remains a narrower application question.

The FTC confirms that the three nationwide CRAs currently offer voluntary free reports weekly through the authorized centralized source. The baseline statutory annual entitlement and voluntary weekly availability must remain separate. P05-C018–C019. Consumer Advice

9. Medical publisher policies — exact verified wording

Correction to PASS-04 C032 and medical coverage row; P05-C020–C021

TransUnion: Its May 19, 2026 article specifically says that medical collection debt with an initial reported balance under $500 and paid medical collection debt do not appear on credit reports, and that unpaid medical collections are subject to a one-year waiting practice measured from original delinquency. TransUnion

Experian: Its October 22, 2026 article discusses medical collections below $500 and distinguishes medical from ordinary paid-collection reporting. It uses broader educational language about credit bureaus and credit-scoring models. The article is not independent inspection of Equifax's current actual policy implementation. Experian

Accordingly:

• “Under $500” is less than $500, not necessarily $500 exactly.
• The TransUnion amount refers to initial reported balance, not necessarily current outstanding balance.
• Paid medical collection exclusion is not a universal statutory entitlement created by the vacated CFPB rule.
• No all-product, all-specialty-CRA, or independently verified Equifax implementation claim is made.
• The unsourced or unnamed CFPB medical FAQ formerly referenced in PASS-04 C032 is withdrawn as independent evidence unless its exact page is later retrieved and read.

Medical assistance, clinical classification, veteran-specific circumstances, original debt instrument, charity care, state medical law, and any actual account remain separate holds.

G4. Rendering, medical-rule status, and observation corrections

10. Replace duplicated formulas with one plain expression each

These are arithmetic or symbolic relationships, not validations of a legal entitlement.

All seven coordinator-identified scalar relationships are numerically correct. The two Wisconsin penalty expressions establish only scalar arithmetic. They do not validate the applicable statute, whether actual damages may be added, standing, preemption, defenses, or any payment.

No exact receipt-based calendar, holiday computation, business-day count, statutory penalty award, score prediction, or deletion consequence is inferred. P05-C023–C024.

11. The January 2025 medical rule was final, then vacated

The prior reference to the amendments as “proposed additions” was wrong.

The rule was published as a final rule, Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V), 90 Fed. Reg. 3276 (January 14, 2025), directed at 12 C.F.R. §§1022.3, 1022.30, and 1022.38.

In Cornerstone Credit Union League v. CFPB, the Eastern District of Texas entered the July 11, 2025 opinion and final judgment setting aside and vacating that rule in its entirety. The current CFPB compliance page expressly acknowledges the vacatur and labels its earlier rule materials reference-only. Consumer Financial Protection Bureau

The actual court-document observations in this pass were:

The files were accessed from CourtListener's mirror of original court-filed documents, not a judiciary-operated document host. This pass does not certify every later appellate filing or a complete citator. The narrower October 26 conclusion is that the CFPB's current published status and these original court documents support treating the 2025 final medical rule as vacated. P05-C022.

12. Observation and version boundaries

• Turner was freshly inspected by page image, not only by text indexing.
• The cited Cornerstone pages and judgment were freshly inspected by page image.
• The CFPB, OLRC, FTC, TransUnion, and Experian text passages identified above were freshly read.
• The full Wisconsin official enactment bodies remained inaccessible on the attempted routes; no simulated source recovery is claimed.
• The newly retrieved OLRC §§1681j and 1681c-1 pages show the October 15, 2026 compilation. The §1681s-2 page shows October 7, 2026. Neither is misrepresented as sharing an identical compilation cutoff.
• Earlier coordinator reads, older PASS-04 source entries, and unopened linked sample letters are not counted as fresh PASS-05 reading.
• A publication, webpage-update, rulemaking, or opinion date is not automatically the statute's effective date.
• No complete subsequent-history service or all-source certification was performed.

P05-C025.

13. Bounded corrected comparisons

These examples demonstrate only the corrected legal boundaries.

No case history, contractual assignment, consumer reporting event, or actual institution compliance is determined by these hypotheticals.

14. Group-resolution and PASS-04 crosswalk

This table specifies which PASS-04 assertions are replaced, narrowed, supplemented, or retained with a hold. Resolved means the particular correction was supported by evidence read in PASS-05, not that the whole underlying legal topic has passed coordinator review.

Unaffected PASS-04 work: Findings outside these corrections remain in the original saved PASS-04 with their previous evidentiary status. They are not newly verified, independently reviewed, or accepted merely because this correction is complete.

15. Source register

All fresh accesses below occurred on October 26, 2026, America/Los_Angeles and October 26, 2026 UTC. Individual fetch timestamps are not asserted.

The status column distinguishes actual body reading, page-image inspection, unsuccessful access, and dated reuse from PASS-04.

Newly read federal authorities, opinions, and publisher materials

Wisconsin current-text and legacy-evidence holds

Additional newly read or failed federal passages

Source-register reconciliation: 34 unique S_WI-P05 source IDs. These comprise successful fresh reads, distinct failed retrievals, and clearly labeled prior-research references. The Wisconsin prior-read references are not counted as fresh official legal verification.

16. Atomic claim register

Confidence applies only to the specified legal proposition under its conditions. It does not imply coordinator acceptance, provider compliance, or a real claimant's result.

Claim-register reconciliation: 28 atomic S_WI-P05 claims, with no unsupported statement that all PASS-04 claims have been re-reviewed.

17. Complete four-group coverage and remaining-evidence table

This is the final coverage test for PASS-05 itself. An old claim backed only by a source locator is not marked answered as a currently verified legal rule.

18. Final reconciliation and researcher self-check

The correction establishes the specific federal provisions and identified document observations. It does not mean that every source in the original PASS-04 has been newly checked.

The principal remaining legal-evidence hold is the current enacted Wisconsin statutory and administrative text, especially how §§427.105, 425.304, and 425.307 interact with reporting violations, defenses, federal preemption, and remedies. The future Act 105 threshold likewise remains at its prior researcher-attributed status until the operative official enactment is recovered.

All four correction groups have visible replacements, citations, exact URLs, atomic claims and status entries. No legal amount, refund, score change, reporting deletion, statutory penalty, successful lawsuit, or actual authorization is promised.

Researcher self-check only; not independent review, all-source certification, Wisconsin approval, publication readiness, or parent/A066 acceptance.

END S_WI PASS-05