S_WI PASS-06 — Bounded corrections to PASS-05
Actual fresh access date: October 26, 2026, Pacific (America/Los_Angeles) and UTC.
Historical baseline: October 22, 2026.
Scope: Only the two authorized residual groups. PASS-04 and PASS-05 remain preserved; no statewide, parent, or A066 acceptance is implied.
G1. Exact Regulation F predicates and exceptions
1. Replace PASS-05 C001's inconsistent conditions cell
Old PASS-05 C001 conditions cell: “Federal collector and actual knowledge standard.”
Correct replacement: “Covered federal debt collector; the collector knows or should know that the debt has been paid, settled, or discharged in bankruptcy. Actual knowledge is sufficient but is not necessary where the constructive-knowledge standard is met. Subject to §1006.30(b)(2)'s precisely limited exceptions.”
New S_WI-P06-C001: Under 12 C.F.R. §1006.30(b)(1), the prohibition covers selling, transferring for consideration, or placing for collection a debt that the collector knows or should know was paid, settled, or discharged in bankruptcy. This is the literal disjunctive standard, not an actual-knowledge-only rule. Consumer Financial Protection Bureau
The main PASS-05 narrative was substantially correct. Only the inconsistent conditions cell and the related crosswalk/coverage wording require replacement.
2. Preserve the different scopes of the exceptions
| Operative provision |
Permitted action |
Exact conditions |
New claim |
| §1006.30(b)(2)(i), introductory language |
Transfer for consideration |
This is the limited action authorized by subparagraph (i), subject to one of (A)–(C). It does not generally authorize a new placement for collection. |
P06-C002 |
| (i)(A) |
Transfer for consideration to the debt's owner |
Recipient must be actual owner; official commentary distinguishes transfers to another collector on the owner's behalf. |
P06-C003 |
| (i)(B) |
Transfer for consideration to a previous owner |
Authorized under the original contract between collector and previous owner. |
P06-C004 |
| (i)(C) |
Transfer for consideration through listed corporate transactions |
Merger, acquisition, purchase-and-assumption transaction, or transfer of substantially all the collector's assets. |
P06-C005 |
| (b)(2)(ii) |
Sell, transfer for consideration, or place for collection certain bankruptcy-discharged debts |
Debt secured by an enforceable lien, and transferee notified that the consumer's personal liability was discharged. Both conditions required. |
P06-C006 |
| (b)(2)(iii) |
Securitization or pledge |
Paragraph (b)(1) does not prohibit securitization of a debt or pledging a debt portfolio as collateral in connection with borrowing. |
P06-C007 |
The difference in statutory verbs matters. Subparagraph (i) expressly permits transfer for consideration within its three categories. Subparagraph (ii) expressly permits the broader listed sale, transfer, or placement actions, but only for the qualifying discharged secured debt. Subparagraph (iii) is limited to securitizations and pledges. None creates general authority to resume otherwise prohibited collection activity. Consumer Financial Protection Bureau
Section 1006.30(a)'s separate pre-furnishing contact rule and specialty check-writing-CRA exception remain unchanged. They do not determine whether a debt transfer qualifies under paragraph (b).
3. Two bounded classification comparisons
Comparison A — Actual knowledge versus constructive knowledge
A collector's employee reads a system record confirming that the debt was settled. That can satisfy actual knowledge. Alternatively, the settlement is accurately and prominently recorded in the collector's ordinary account system, but the responsible employee says they never opened that entry. Depending on the facts and reasonable access to those records, the collector should know the debt was settled even without proof of the employee's personal awareness.
Both situations must be tested against §1006.30(b)(1). The second cannot be excluded merely for lack of actual awareness. Neither hypothetical adjudicates what reasonable knowledge an actual organization possessed.
Comparison B — Return to owner versus new collection placement
Collector A holds a settled debt for Owner B.
- Transferring for consideration back to the actual owner B may qualify under (b)(2)(i)(A).
- Placing the same settled debt with unrelated Collector C for renewed collection is not converted into an owner transfer simply because Owner B requested it.
- A separate statutory exception must genuinely apply before an otherwise prohibited sale, transfer, or placement can be justified.
No hypothetical establishes that the debt remains collectible, that compensation occurred, or that a consumer has an automatic private claim. Consumer Financial Protection Bureau
G2. Corrected self-check counts and provenance
4. Replace PASS-05's final audit counts
The historical PASS-05 counts are corrected using the coordinator's saved-DOM observations supplied for this correction. They are not presented as an independent recount.
| Audit metric |
Incorrect PASS-05 self-check |
Correct saved PASS-05 count |
| Visible tables |
16 |
16 |
| Source-register entries |
34 |
34 |
| Atomic claims |
28 |
28 |
| Group-resolution rows |
32 |
31 |
| Granular coverage rows |
50 |
52 |
S_WI-P06-C009: Replace only the two incorrect counts. Do not add or delete substantive rows to match the old figures.
5. Preserve the distinct source-access histories
Both OLRC editions were successfully opened and read in this PASS-06 session.
| Section |
URL edition |
Actual displayed compilation |
Observation |
| 15 U.S.C. §1681j |
/119-118/ |
Through Pub. L. 119-120, October 7, 2026 |
Coordinator previously read this route; freshly read here |
| 15 U.S.C. §1681j |
/119-124/ |
Through Pub. L. 119-124, October 15, 2026 |
Previously inaccessible to coordinator; successfully read here |
| 15 U.S.C. §1681c-1 |
/119-118/ |
Through Pub. L. 119-120, October 7, 2026 |
Coordinator previously read this route; freshly read here |
| 15 U.S.C. §1681c-1 |
/119-124/ |
Through Pub. L. 119-124, October 15, 2026 |
Previously inaccessible to coordinator; successfully read here |
The path /119-118/ does not establish that the displayed text was compiled only through Public Law 119-118; the actual returned headers identify Public Law 119-120.
A failed fetch in the coordinator's session does not disprove a successful fetch in this session. Conversely, this session's successful October 15-edition reads cannot be attributed retroactively to the coordinator. P06-C010. USCode+3
6. Preserve the separate federal investigation clocks
| Branch |
Operative predicate |
Limit |
P06 claim |
| Ordinary §1681i(a)(1)(A) |
CRA receives qualifying dispute |
Generally 30 days |
C011 |
| §1681i(a)(1)(B)–(C) |
New relevant information received within initial 30 days, without a disqualifying early finding |
Up to 15 additional days: 30 + 15 = 45 days |
C011 |
| §1681j(a)(3) |
Consumer requests reinvestigation after receiving a qualifying free annual report under §1681j(a) |
Separate 45-day rule |
C011 |
| §1681j(a)(4) |
CRA has not furnished consumer reports continuously to third parties during the prior 12 months for nationwide-resident consumers |
Subsection (a) does not apply to that qualifying CRA |
C012 |
The annual free-report pathway remains subject to §1681j(a)(1)'s predicates, including the centralized source for nationwide CRAs and the specified streamlined process for nationwide specialty CRAs.
The FTC confirms that the three nationwide CRAs currently make free weekly reports available voluntarily. Whether a particular voluntarily obtained weekly report qualifies as a report under §1681j(a), for purposes of the separate 45-day provision, remains held. USCode+2
7. Other holds remain untouched
PASS-06 does not resolve the outstanding official Wisconsin §§421, 425, 427, §100.54, DFI-Bkg 74, or Act 105 access gaps. It does not settle the Wisconsin $320 penalty example's legal applicability, state–federal preemption, contractual questions, actual account facts, Equifax-specific medical policy, complete citator history, or medical/local/tribal sector issues.
The seven previously checked scalar relations, single plain-text DOFD expression, final-but-vacated 2025 medical rule, and previously attributed PDF page-image observations remain preserved without a new numerical or legal entitlement claim.
P06-C013: These are retained evidentiary boundaries, not fresh resolution of the underlying matters.
8. Complete PASS-05 → PASS-06 crosswalk
| Old PASS-05 item |
New claim/source |
Exact correction |
Affected coverage |
Disposition |
| C001 conditions cell |
P06-C001 / S001 |
Replace “actual knowledge” with knows or should know |
G1 prohibition/predicate row |
Resolved |
| C001 prohibition description |
P06-C001 / S001 |
Preserve sell, transfer for consideration, place for collection |
G1 prohibited-action row |
Confirmed |
| C002 owner exception |
P06-C002–C003 / S001 |
Explicitly retain introductory transfer-for-consideration limitation |
G1 owner row |
Clarified |
| C003 previous-owner exception |
P06-C002, C004 / S001 |
Original-contract predicate; same introductory action scope |
G1 previous-owner row |
Clarified |
| C004 corporate exception |
P06-C002, C005 / S001 |
Enumerated transactions; same introductory action scope |
G1 corporate row |
Clarified |
| C005 secured-bankruptcy exception |
P06-C006 / S001 |
Broader listed actions, enforceable lien and discharge notice |
G1 secured exception row |
Confirmed precisely |
| C006 securitization/pledge |
P06-C007 / S001 |
Retain limited statutory carve-out |
G1 securitization row |
Confirmed |
| C007 and older C009 debt parking |
P06-C008 / S001 |
Paragraph (a) remains distinct; no renewed-collection authority inferred |
G1 scope distinction |
Preserved |
| Final self-check counts |
P06-C009 / coordinator-supplied PASS-05 DOM observation |
31 group rows and 52 coverage rows |
G2 audit |
Corrected |
| S008–S010 edition observations |
P06-C010 / S002–S005 |
Attribute October 7 and October 15 versions to actual sessions |
G2 provenance |
Resolved |
| C018–C019 investigation clocks |
P06-C011–C012 / S002, S004, S006–S007 |
Preserve separate 45-day branches, §1681j(a)(4), centralized/streamlined process predicates |
G2 clock and access rows |
Clarified |
| C017, C024–C026 and remaining holds |
P06-C013 / existing P05 registers |
No fresh acceptance or status upgrade |
G2 retained-gap rows |
Remain open |
The unchanged PASS-04/PASS-05 material is retained, not re-reviewed.
9. PASS-06 source register
All seven sources below were freshly accessed October 26, 2026, Pacific and UTC. No individual fetch timestamps, PDF inspection, or unpublished retrieval methods are claimed.
| Source ID |
Issuer, title, complete literal URL |
Exact pinpoint and version |
Actual read/status |
| S_WI-P06-S001 |
CFPB, Regulation F, §1006.30, Other prohibited practices. https://www.consumerfinance.gov/rules-policy/regulations/1006/30/ |
(a)(1)–(2), (b)(1), (b)(2)(i)(A)–(C), (ii), (iii); official interpretations of 30(b)(1) and 30(b)(2)(i)(A). Page identifies current regulation |
Fresh operative body and relevant commentary read. No PDF page indexes; HTML source. Consumer Financial Protection Bureau |
| S002 |
U.S. House OLRC, 15 U.S.C. §1681j. https://uscode.house.gov/us/usc/119-124/t15/s1681j/ |
(a)(1)(A)–(C), (a)(2)–(4). Through Pub. L. 119-124, Oct. 15, 2026 |
Fresh current official HTML body read. USCode |
| S003 |
U.S. House OLRC, 15 U.S.C. §1681c-1. https://uscode.house.gov/us/usc/119-124/t15/s1681c-1/ |
(i)(2)–(4), (j). Through Pub. L. 119-124, Oct. 15, 2026 |
Fresh current official HTML body and freeze exceptions read. USCode |
| S004 |
U.S. House OLRC, 15 U.S.C. §1681j, alternative edition route. https://uscode.house.gov/us/usc/119-118/t15/s1681j/ |
(a)(1)–(4). Actual page displays through Pub. L. 119-120, Oct. 7, 2026 |
Fresh official HTML read; older displayed compilation, not mislabeled as October 15. USCode |
| S005 |
U.S. House OLRC, 15 U.S.C. §1681c-1, alternative edition route. https://uscode.house.gov/us/usc/119-118/t15/s1681c-1/ |
(i)(2)–(4), (j). Actual page displays through Pub. L. 119-120, Oct. 7, 2026 |
Fresh official HTML read; independent of coordinator's earlier read. USCode |
| S006 |
U.S. House OLRC, 15 U.S.C. §1681i, Procedure in case of disputed accuracy. https://uscode.house.gov/us/usc/119-124/t15/s1681i/ |
(a)(1)(A)–(C), 30-day period and conditional extension; through Pub. L. 119-124 |
Fresh official HTML body read, limited to relevant timing. USCode |
| S007 |
Federal Trade Commission, Free Credit Reports. https://consumer.ftc.gov/articles/free-credit-reports |
“How To Get Your Free Annual Credit Reports” and “How often can I get a free report?” Page dated June 2026 |
Fresh official guidance read. Voluntary weekly practice is not statutory amendment. Consumer Advice |
No state enacted-body read, court-PDF inspection, medical-policy recertification, or full citator was conducted in PASS-06.
10. PASS-06 atomic claim register
| Claim ID |
Precise claim |
Primary source/pinpoint |
Conditions, exceptions, consequence and old mapping |
Confidence |
| S_WI-P06-C001 |
§1006.30(b)(1) uses knows or should know, not actual knowledge exclusively. |
S001 (b)(1) |
Covered debt collector, specified debt status and action; fixes P05-C001 cell |
High |
| C002 |
§1006.30(b)(2)(i)'s (A)–(C) exceptions expressly concern transfer for consideration. |
S001 (b)(2)(i) introductory clause |
No general renewed placement authority; clarifies P05-C002–C004 |
High |
| C003 |
Owner exception requires actual debt owner; owner-directed transfer to different collector not generally excepted. |
S001 (b)(2)(i)(A), official comment |
Other exceptions independently possible; clarifies P05-C002 |
High |
| C004 |
Previous-owner exception requires authorization in original collector–previous-owner contract. |
S001 (b)(2)(i)(B) |
Within (i)'s action scope; clarifies P05-C003 |
High |
| C005 |
Enumerated corporate-transaction exception is within (i)'s action scope. |
S001 (b)(2)(i)(C) |
Actual listed corporate event required; clarifies P05-C004 |
High |
| C006 |
Discharged secured-debt exception expressly covers sale, consideration transfer or placement when lien enforceability and transferee notice predicates hold. |
S001 (b)(2)(ii) |
Personal liability discharge must be disclosed; clarifies P05-C005 |
High |
| C007 |
Securitization and collateral pledge are independently identified carve-outs. |
S001 (b)(2)(iii) |
No blanket subsequent collection authority; retains P05-C006 |
High |
| C008 |
Paragraph (a) debt parking and paragraph (b) restricted debt transfers address different events. |
S001 (a)(1)–(2), (b)(1)–(2) |
Specialty check-writing CRA exception remains paragraph (a)-specific; retains P05-C007 |
High |
| C009 |
Correct saved PASS-05 historical audit is 16 tables, 34 sources, 28 claims, 31 group-resolution rows and 52 coverage rows. |
Coordinator-supplied saved-DOM observations in this request; non-web audit evidence |
Corrects erroneous 32/50, not independently recounted |
High as supplied; no independent DOM recount |
| C010 |
Distinct OLRC URLs display October 7 and October 15 compilations; successful P06 access cannot be attributed to coordinator. |
S002–S005, headers and § bodies |
Version/provenance correction; P05 currentness observations not conflated |
High |
| C011 |
§1681i 30+15 conditional extension differs from §1681j(a)(3)'s separate 45-day annual-report branch. |
S002 (a)(3); S004 (a)(3); S006 (a)(1)(A)–(C) |
No universal 45-day clock; preserves P05-C019 |
High |
| C012 |
§1681j(a)(1) process requirements and (a)(4) first-12-month exception condition annual-report applicability; voluntary weekly classification remains held. |
S002 (a)(1),(4); S004; S007 |
Report/source and CRA-history facts matter |
High statute; weekly classification unresolved |
| C013 |
All unaffected Wisconsin/currentness, remedies, policy, case, arithmetic and parent-scope holds remain unaccepted. |
PASS-05 saved record and scope instruction; no new state-law source |
Procedural status, not a newly verified state-law conclusion |
Certain within this correction |
11. Complete two-group coverage and retained holds
| Residual subissue |
Status |
Claim IDs |
Source IDs / evidence |
Missing evidence or next action |
| G1 actual versus constructive knowledge |
Resolved |
C001 |
S001 (b)(1) |
Actual records/knowledge facts only if a real matter is later authorized |
| G1 complete prohibited-action verbs |
Resolved |
C001 |
S001 (b)(1) |
No broader regulatory issue decided |
| G1 (i) introductory transfer-for-consideration scope |
Resolved |
C002 |
S001 (b)(2)(i) |
Do not generalize to placement |
| G1 owner exception |
Resolved |
C003 |
S001 (b)(2)(i)(A) and comment |
Actual ownership held |
| G1 previous-owner original-contract condition |
Resolved |
C004 |
S001 (b)(2)(i)(B) |
Original contract unsupplied |
| G1 corporate-transaction exception |
Resolved |
C005 |
S001 (b)(2)(i)(C) |
Corporate transaction facts unsupplied |
| G1 secured-discharge exception |
Resolved |
C006 |
S001 (b)(2)(ii) |
Lien validity and transferee notice unsupplied |
| G1 securitization/pledge exception |
Resolved |
C007 |
S001 (b)(2)(iii) |
Actual transaction structure unsupplied |
| G1 no general new collection authorization |
Resolved as limitation |
C002–C008 |
S001 |
Other laws and actual events excluded |
| G1 paragraph (a) and specialty CRA remain separate |
Preserved |
C008 |
S001 (a)(1)–(2) |
No fresh whole debt-parking investigation |
| G1 knowledge and owner hypotheticals |
Completed |
C001–C003, C008 |
S001 |
No actual case outcome claimed |
| G2 source and claim counts |
Corrected/confirmed from supplied audit |
C009 |
Coordinator saved-DOM observation |
Independent recount not performed |
| G2 group-resolution and coverage counts |
Corrected |
C009 |
Coordinator saved-DOM observation |
No rows added or removed |
| G2 October 7 versus October 15 editions |
Resolved for actual displayed sources |
C010 |
S002–S005 |
Subsequent legal changes beyond access date not certified |
| G2 separate coordinator/researcher access |
Resolved provenance |
C010 |
S002–S005 and supplied coordinator record |
Do not retroactively attribute reads |
| G2 ordinary 30+15 period |
Preserved/verified narrowly |
C011 |
S006 |
Actual receipt/new-information facts held |
| G2 §1681j(a)(3) 45-day branch |
Preserved/verified |
C011 |
S002, S004 |
Qualifying annual-report receipt required |
| G2 §1681j(a)(1) centralized/specialty processes |
Verified |
C012 |
S002, S004 |
Actual report pathway held |
| G2 §1681j(a)(4) first-12-month exception |
Verified |
C012 |
S002, S004 |
CRA continuous nationwide reporting history required |
| G2 voluntary weekly report classification |
Unresolved |
C012 |
S002, S007 |
Determine whether specific report legally falls under subsection (a) |
| G2 current Wisconsin §§421/425/427 |
Held |
C013 |
Prior PASS-05 state-source gaps |
Full operative official enactments and versions |
| G2 current DFI-Bkg 74, §100.54, Act 105 |
Held |
C013 |
Prior PASS-05 source gaps |
Official state text and effective history |
| G2 Wisconsin remedies and $320 legal application |
Held |
C013 |
Prior PASS-05 C024 |
Official formula, stacking, standing, preemption and defenses |
| G2 medical-policy/Equifax/veteran/contract facts |
Held |
C013 |
Prior PASS-05 C020–C022 |
Specific independently read authority and actual predicates |
| G2 final-vacated medical rule |
Unchanged, not re-investigated |
C013 |
Prior PASS-05 court/CFPB sources |
No new appeal or citator certification |
| G2 seven scalar checks and single plain formula |
Retained |
C013 |
Prior PASS-05 arithmetic self-check |
No recalculation of legal entitlement |
| G2 PDF page/pixel observations |
Retained as prior observations |
C010, C013 |
PASS-05 provenance |
No new page-image examination |
| G2 private cases, local/tribal, parent acceptance |
Excluded/open |
C013 |
PASS-05 boundaries |
Separate authorized research and review |
12. Final count and provenance reconciliation
| Item |
PASS-06 result |
| Authorized groups addressed |
2 of 2 |
| Correct historical PASS-05 tables |
16 |
| Correct historical PASS-05 sources |
34 |
| Correct historical PASS-05 claims |
28 |
| Correct historical PASS-05 group-resolution rows |
31 |
| Correct historical PASS-05 granular coverage rows |
52 |
| PASS-06 newly registered sources |
7 |
| PASS-06 atomic claims |
13 |
| PASS-06 crosswalk rows |
12 |
| PASS-06 coverage rows |
27 |
Researcher self-check: The operative Regulation F text and relevant official interpretations were freshly read. Both displayed OLRC compilation editions of §§1681j and 1681c-1, plus the narrow §1681i timing clauses and FTC weekly-report guidance, were freshly read. The earlier coordinator observations remain separately attributed. No Wisconsin enacted text was recovered or represented as newly verified, no PDF pages were visually inspected in this pass, and no complete citator or independent review was performed.
Disposition: Both PASS-06 correction groups are completed within their authorized bounds. The actual-knowledge-only error and inaccurate PASS-05 audit counts are corrected, with the owner/previous-owner/corporate exception scopes made explicit. All unaffected findings and unresolved evidence holds remain preserved without acceptance or publication/operations approval.
END S_WI PASS-06