SettleADebt S_WI PASS-09
Federal identity-theft credit-report blocking, fraud alerts, ordinary security freezes, and protected-consumer freezes
Actual fresh source-access date: October 26, 2026, America/Los_Angeles; October 27, 2026 UTC.
Historical baseline: October 22, 2026 Pacific.
Mode/model: Regular Chat on GPT-5.6 Sol Pro. No separate power setting, quota state, reset, or measured model ranking is exposed to me, so none is claimed.
Scope: Federal reporting protections relevant to a hypothetical Wisconsin consumer. This is not debt cancellation, criminal identity-theft adjudication, creditor or collector authorization, an actual identity-theft report, or Wisconsin/A066/parent acceptance.
P01-P03, P07, and P08 remain unreviewed and supply no accepted premise. The P04-P06 freeze boundary and corrections are preserved but are independently re-read here from a newer current OLRC compilation where available.
Throughout this report, C001 means S_WI-P09-C001, and S001 means S_WI-P09-S001.
Executive disposition
The federal system has four different tools that should not be collapsed into one “identity theft dispute”:
| Protection |
Primary trigger |
Principal action |
Central clock |
| Identity-theft block |
Complete §1681c-2 packet identifying allegedly fraudulent report information |
CRA blocks reporting of the identified information |
No later than 4 business days after receipt of all four statutory packet elements |
| Initial fraud alert |
Good-faith suspicion of actual or impending fraud/identity theft; no identity-theft report required |
Alert appears in nationwide files; prospective credit users must use identity-verification procedures |
At least 1 year |
| Extended fraud alert |
Identity-theft report plus proper identification |
Stronger contact-confirmation rule, 7-year alert, 5-year prescreen exclusion |
7 years |
| Active-duty alert |
Qualifying active-duty status plus proper identification |
Alert and prospective-user identity-verification duties; prescreen exclusion |
12-month alert; 2-year prescreen exclusion |
| Ordinary security freeze |
Direct request to each nationwide CRA plus proper identification |
Restricts release of the report, subject to ten statutory use exceptions |
1 business day electronic/phone or 3 business days mail; 1-hour electronic/phone lift |
| Protected-consumer freeze |
Representative’s direct request plus proof of authority and identification |
Freezes an existing file or creates a protected record if none exists |
Similar 1-/3-business-day placement and 1-hour/3-business-day removal clocks |
The identity-theft block applies to a consumer reporting agency generally, subject to reseller and check-service rules. Fraud alerts and the federal national-freeze provisions apply specifically to CRAs meeting the nationwide-file definition in §1681a(p). A nationwide specialty CRA under §1681a(x) is not silently treated as a nationwide credit CRA merely because it maintains medical, tenant, check-writing, employment, or insurance files. U.S. Code+2
None of these protections:
- adjudicates whether the underlying obligation legally exists;
- orders a creditor to forgive money;
- automatically stops every collection communication or lawsuit;
- guarantees deletion of unsupported allegations;
- guarantees a credit-score increase;
- supplies an automatic damages award; or
- substitutes for a general accuracy dispute where identity theft cannot honestly be alleged.
G1. Identity-theft credit-report blocking
1. Actor and route matrix
| Actor |
Federal block role |
Material boundary |
| Consumer |
Identifies information alleged to result from identity theft and supplies the statutory packet |
§1681c-2(a) expressly speaks of action by “the consumer”; unlike fraud alerts, it does not separately spell out a personal-representative request route |
| Consumer reporting agency generally |
Blocks the reporting of identified information if the complete packet is received |
Broader actor phrase than the nationwide-CRA-only alert/freeze provisions |
| Nationwide CRA |
Subject to the block rule and complaint-referral coordination |
Referral procedures do not expressly say one completed block automatically becomes effective at every nationwide CRA |
| Reseller without relevant file/use |
May fall within the no-file exception after giving the required Bureau-contact information |
Does not perform the ordinary block solely because it is a reseller |
| Reseller maintaining the identified report |
Blocks that maintained report from subsequent use and identifies source CRAs |
Its statutory obligation is specially limited |
| Check-services company acting as such |
Special rule: after receipt of packet elements (1)-(3), cannot report identified information to a nationwide CRA after the fourth business day |
Element (4) is not listed in this special branch |
| Furnisher |
Receives CRA notice; must have procedures preventing refurnishing and may be subject to a direct identity-report no-furnish rule |
Blocking does not automatically erase the furnisher’s internal account records |
| Debt owner / collector / assignee |
Can face separate post-notice sale, transfer, placement, and information duties |
These duties are not a merits judgment canceling the debt |
| Law-enforcement agency |
May access blocked information when otherwise entitled under the FCRA |
A reporting block is not suppression of evidence from lawful governmental access |
C001–C016. U.S. Code+2
2. The complete four-element block packet
Under 15 U.S.C. §1681c-2(a), the four-business-day clock begins only after the CRA receives all of the following:
- Appropriate proof of the consumer’s identity.
- A copy of an identity-theft report.
- Identification of the specific report information alleged to result from identity theft.
- The consumer’s statement that the identified information does not relate to any transaction by the consumer.
The required action is to block reporting of the identified information, not to declare the account nonexistent for all legal purposes. C003. U.S. Code+1
Packet-element matrix
| Packet element |
What is legally required |
What is not automatically enough |
| Proof of identity |
CRA’s reasonable identity-match requirements under Regulation V |
An unsupported name alone |
| Identity-theft report |
An official, valid qualifying government report satisfying statutory/regulatory criteria |
A bare consumer accusation labeled “identity theft” |
| Information identification |
Specific tradeline, account, balance, inquiry, or other file information to be blocked |
A demand to “delete everything negative” |
| No-transaction statement |
Statement that the information does not relate to a transaction by that consumer |
Merely saying the balance seems too high |
| Complete receipt |
CRA possesses all four items |
Date on which an incomplete envelope or upload first arrived |
Regulation V permits CRAs to require information sufficient to match the consumer to the correct file and proportionate to the risk of misidentification. Illustrative proof can include identifying data, government-issued identification, utility bills, or knowledge-based authentication. It does not prescribe one mandatory national form or one universal document combination. C006. Consumer Financial Protection Bureau+1
3. “Identity theft” and “identity-theft report”
Federal law defines identity theft as fraud committed—or under Regulation V, committed or attempted—using another person’s identifying information without authority. Identifying information includes names, identifying numbers, birth dates, government identifiers, biometric data, electronic identifiers, routing codes, and specified telecommunications or access-device information. C004. U.S. Code+1
A qualifying identity-theft report must:
- allege identity theft with as much specificity as the consumer can provide;
- be a copy of an official, valid report filed with an appropriate federal, state, or local law-enforcement or other qualifying government agency; and
- subject a knowingly false filer to criminal penalties.
Regulation V allows a CRA or furnisher to request reasonably necessary supplemental information, but limits the request and decision periods:
- initial additional-information request: no later than 15 days after the later of report receipt or service request;
- supplemental requests and final acceptance decision: within another 15 days after the initial request; and
- if supplemental information arrives on day 11 or later of that second period: 5 additional days to make the final acceptance decision.
A detailed signed police report ordinarily should suffice absent an identifiable concern. An automated, minimally detailed report used for a tradeline block may justify additional identity documentation or an affidavit. The regulation says that comparable extra documentation ordinarily would not be reasonable merely to obtain an extended fraud alert. C004–C005. Consumer Financial Protection Bureau
The FTC identifies IdentityTheft.gov as the federal government’s one-stop reporting and recovery resource, and the CFPB says that using it generates an Identity Theft Report and recovery plan. No report was created, filed, or requested in this pass. C042. Federal Trade Commission+1
4. Four-business-day block and furnisher notice
Once the complete packet is received, the CRA must block reporting of the identified information no later than four business days after receipt. It must promptly tell the furnisher:
- that the information may result from identity theft;
- that an identity-theft report was filed;
- that a block was requested; and
- the effective dates of the block.
C003, C007. U.S. Code+1
The FCRA provisions read here do not define “business day.” The calendar examples below therefore disclose a modeling convention rather than pretending the statute expressly adopts a Monday-through-Friday/federal-holiday rule.
5. Declining or rescinding a block
A CRA may decline or rescind a block only after reasonably determining one of three statutory grounds:
- the information was blocked, or the block requested, in error;
- the request or block rested on a material factual misrepresentation by the consumer; or
- the consumer obtained goods, services, or money from the blocked transaction.
The CRA must notify the consumer promptly in the same manner as a reinsertion notice under §1681i(a)(5)(B). That referenced notice regime uses written notice within five business days after reinsertion—or another available means if the consumer authorized it—and supplies specified furnisher and dispute-right information. Section 1681c-2 itself uses the word promptly; this report does not silently rewrite it as an independent five-business-day decision deadline. C008–C009. U.S. Code+1
If a block is rescinded, the mere pre-block presence of the information in the consumer’s file is not evidence that the consumer knew or should have known that the consumer obtained the goods, services, or money. C008. U.S. Code
6. Resellers, check services, and law enforcement
Reseller without a relevant maintained or currently resold report
The ordinary block section does not apply when the reseller:
- is not then furnishing or reselling a report concerning the identified information; and
- tells the consumer that identity theft may be reported to the Bureau to obtain identity-theft information.
Reseller maintaining the identified report
Its sole §1681c-2 obligation is to block that maintained report from later use when the consumer satisfies the statutory identification requirements and the reseller is the source of the identified information. It must promptly notify the consumer of the decision and provide the name, address, and telephone number of each source CRA. C010. U.S. Code+1
Check-services company
A check-services company acting in that capacity is specially excepted, but beginning four business days after receiving:
- proof of identity;
- the identity-theft report; and
- identification of the information,
it may not report the identified identity-theft information to a nationwide CRA. The separate no-transaction statement in §1681c-2(a)(4) is not listed in this branch. C011. U.S. Code+1
Law enforcement
Nothing in §1681c-2 requires a CRA to prevent lawful federal, state, or local law-enforcement access to blocked information. C011. U.S. Code
7. Furnisher, transfer, and collector consequences
CRA notice to furnisher
A furnisher must maintain reasonable procedures to respond to a CRA’s §1681c-2 notification and prevent refurnishing the blocked information. C012. U.S. Code
Direct identity-theft report to a furnisher
If a consumer submits an identity-theft report to the address the furnisher specifies for such reports and states that information maintained by the furnisher resulted from identity theft, the furnisher may not furnish that information unless it later knows—or the consumer informs it—that the information is correct. This is a furnishing restriction, not an automatic ruling on the internal debt ledger or contract. C013. U.S. Code
Selling, transferring, or placing the debt for collection
After a person is notified under §1681c-2 that a debt resulted from identity theft, §1681m(f) generally prohibits selling it, transferring it for consideration, or placing it for collection. The prohibition applies to all persons collecting that debt after the statutory notification. Its limited exceptions are:
- repurchase required by an assignee because the debt resulted from identity theft;
- securitization or pledge of a debt portfolio as borrowing collateral; and
- transfer through a merger, acquisition, purchase-and-assumption transaction, or transfer of substantially all assets.
This is a different statutory branch from Regulation F’s paid/settled/discharged-debt transfer rule addressed in PASS-05/PASS-06. It is not a general debt-cancellation adjudication. C014. U.S. Code+1
Third-party debt collector
When a debt collector acting for a creditor or other report user is told that information relating to a debt may be fraudulent or identity-theft-related, the collector must:
- notify that third party; and
- on the consumer’s request, provide the information the consumer would otherwise receive when disputing the debt under law applicable to that collector.
The subsection does not say that the collector itself decides criminal guilt or automatically waives the balance. C015. U.S. Code
8. Block versus ordinary dispute
| Route |
Trigger |
Main result |
Does collection automatically stop? |
| §1681c-2 identity-theft block |
Complete four-part packet |
Blocks reporting of identified information |
Not universally; separate collection and transfer duties must be tested |
| §1681i CRA accuracy dispute |
Consumer disputes completeness/accuracy |
Reinvestigation, correction/modification/deletion according to results |
No universal collection stay |
| Regulation V direct furnisher dispute |
Proper direct dispute addressing covered subject |
Furnisher investigation and reporting correction if inaccurate |
No universal collection stay |
| §1681s-2(a)(6)(B) identity report to furnisher |
Report sent to specified identity-report address |
Furnisher cannot furnish unless information later known/confirmed correct |
Internal account and debt merits remain separate |
| Fraud alert |
Qualifying alert request |
Prospective credit users perform identity checks |
Does not delete existing information |
| Security freeze |
Direct request to a nationwide CRA |
Restricts report access, subject to exceptions |
Does not block existing-account collection access within §1681c-1(i)(4)(A) |
Regulation V recognizes identity theft as a subject of a direct furnisher dispute, but that does not erase the separate and more specific identity-theft blocking route. C016. Consumer Financial Protection Bureau
G2. Fraud alerts
9. Alert comparison
| Alert |
Eligible requester and proof |
Duration |
Prescreen exclusion |
Special free-file right |
| Initial |
Consumer or representative; good-faith suspicion of actual or impending fraud; proper identity proof; no identity-theft report required |
At least 1 year |
None created by subsection (a) |
1 free file disclosure from each nationwide CRA after request; due within 3 business days |
| Extended |
Consumer or representative; identity-theft report; proper identity proof |
7 years |
5 years |
2 free file disclosures from each nationwide CRA in the first 12 months; each due within 3 business days after request |
| Active duty |
Active-duty military consumer or representative; proper identity proof |
12 months under Regulation V |
2 years |
No separate alert-specific free-file benefit in subsection (c); other general free-report rights may apply |
C017–C021. U.S. Code+4
10. Initial fraud alert
A nationwide CRA maintaining a file must place an initial alert upon direct request by the consumer or a representative who:
- asserts in good faith that the consumer has been or is about to become a fraud or identity-theft victim; and
- supplies appropriate identity proof.
The alert lasts at least one year unless properly removed earlier. The contacted CRA refers it to the other nationwide CRAs. The receiving CRAs must act as though the consumer contacted them directly for the alert and free-file procedures specified by the statute. C017–C018. U.S. Code+1
The initial-alert provision gives the consumer a right to request a free file disclosure, supplied within three business days after that request. Through the mandatory referral process, the right attaches at the other nationwide CRAs as well. C018. U.S. Code+1
11. Extended fraud alert
An extended alert requires:
- direct request by the consumer or representative;
- an identity-theft report;
- proper identity proof; and
- an existing file at the nationwide CRA.
It lasts seven years and removes the consumer from covered uninitiated credit/insurance solicitation lists for five years, unless rescinded earlier. The consumer may request two free file disclosures from each nationwide CRA within the first twelve months, each supplied within three business days after request. C019–C020. U.S. Code+1
For the extended alert, a prospective credit user cannot approve the covered new credit, card, or limit-increase request unless it contacts the consumer in person or through the alert’s designated contact method to confirm the request is not identity theft. C024. U.S. Code
12. Active-duty alert
An “active-duty military consumer” is a consumer who:
- is on active duty or qualifying reserve duty; and
- is assigned away from the usual duty station.
A consumer or representative may request the alert with proper identity proof. The statutory period is at least twelve months, and current Regulation V fixes the duration at twelve months. The prescreen exclusion lasts two years. The contacted nationwide CRA refers the alert to the others. C021–C022. U.S. Code+3
Section 1681c-1(c) does not provide the separate one- or two-file alert benefit supplied for initial and extended alerts. Other free-report provisions can still apply, but should not be attributed to the active-duty subsection itself. C021.
Free active-duty electronic credit monitoring under §1681c-1(k) is a separate program, not part of the alert’s mechanics. Its separate proof, service, rulemaking, and enforcement questions are deferred. C043. U.S. Code
13. User verification duties
Initial and active-duty alerts
A prospective report user seeking to establish covered new credit, issue an additional card requested by the consumer, or increase a requested credit limit must use reasonable policies and procedures to form a reasonable belief that it knows the requester’s identity.
If the alert supplies a verification telephone number, the user must either:
- contact the consumer at that number; or
- take reasonable identity-verification steps and confirm that the request is not identity theft.
C023. U.S. Code+1
Extended alert
The extended-alert standard is more prescriptive. The user must contact the consumer in person or using the alert’s designated contact method before approving the covered request. C024. U.S. Code
Neither alert type absolutely prevents report access. It changes the prospective credit user’s duties.
14. Referral, resellers, and other CRAs
- Initial, extended, and active-duty alerts expressly use a one-contact referral system among nationwide CRAs.
- A referred nationwide CRA acts as if it received the relevant request directly.
- A reseller must reconvey any alert appearing in the underlying report.
- A non-nationwide CRA contacted about suspected identity theft must provide information about contacting the Bureau and nationwide CRAs for alert assistance.
- Nationwide CRAs must maintain procedures to refer identity-theft complaints, alert requests, and block requests to one another—but the block statute does not contain the same explicit “act as if directly requested” language that governs fraud-alert referrals.
C022. U.S. Code+1
G3. Ordinary and protected-consumer security freezes
15. Ordinary national freeze: coverage and operation
The ordinary federal freeze in §1681c-1(i) applies to a CRA satisfying the nationwide credit-file definition in §1681a(p). It is free and available on direct request with proper identification; identity theft need not already have occurred. C026. U.S. Code+1
Placement, confirmation, removal, and temporary lift
| Event |
Request method |
Statutory deadline |
Required proof / action |
| Place freeze |
Toll-free telephone or secure electronic means |
1 business day after direct receipt |
Proper identification |
| Place freeze |
Mail |
3 business days after direct receipt |
Proper identification |
| Confirm placement |
Any valid placement |
5 business days after placement |
Confirmation, removal process, authentication mechanism, prescreen opt-out right |
| Permanent removal |
Toll-free telephone or secure electronic means |
1 hour after direct receipt |
Proper identification |
| Permanent removal |
Mail |
3 business days after direct receipt |
Proper identification |
| Temporary lift |
Same methods |
Same removal deadlines |
Consumer identifies the lift period |
| CRA-initiated removal |
Material consumer misrepresentation |
Prior written notice |
No consumer request required |
| Credit application during freeze |
Consumer denies access |
No lifting duty imposed by application |
Prospective creditor may treat application as incomplete |
C026–C028. U.S. Code+3
The statute requires an authentication mechanism, not a particular PIN, app, paid lock, bureau subscription, or online account. A bureau may use a lawful authentication process, but its branded implementation is not transformed into the statutory definition. C027.
Unlike fraud alerts, a freeze request to one nationwide CRA is not statutorily referred to the others for automatic placement. A consumer seeking freezes across the nationwide files must make a direct request to each CRA. C032. Consumer Financial Protection Bureau+1
16. Complete ordinary-freeze exception matrix
A freeze does not apply to making a consumer report for the following uses:
| Clause |
Permitted use despite freeze |
Limitation |
| (A) |
Existing or previously assigned account/contract/negotiable-instrument relationship; affiliates, agents, assignees, and prospective assignees |
Only account review or collection of that obligation; “review” includes maintenance, monitoring, credit-line increases, upgrades, and enhancements |
| (B) |
Federal, state, or local agency; law enforcement; trial court; or private collection agency |
Private collection agency must act under a court order, warrant, or subpoena for this branch |
| (C) |
Title IV-D child-support agency |
Child-support function |
| (D) |
Federal agency, state, or agents/assigns |
Fraud investigation, taxes, unpaid court orders, or other statutory duties consistent with a permissible FCRA purpose |
| (E) |
Prescreened credit/insurance use under §1681b(c) |
Separate prescreen opt-out right remains relevant |
| (F) |
Credit-file monitoring or similar subscribed service |
Consumer must have subscribed |
| (G) |
Providing consumer’s own report or score |
Consumer request |
| (H) |
Insurance underwriting |
Not a new-credit opening use |
| (I) |
Employment, tenant, or background screening |
Separate user and consent laws still apply |
| (J) |
Identity assessment/authentication unrelated to granting credit, or fraud investigation/prevention |
Does not authorize unrelated credit granting |
C029–C030. U.S. Code+1
Two practical consequences follow:
- A freeze is not a universal ban on report access.
- The existing-account/collection exception is not an exemption for every collector in every situation. It requires the relationship described in clause (A), or another actual exception such as a court-order branch.
17. Freeze rights notice and web access
The statutory rights notice explains that a freeze can delay or prevent later credit applications and that existing-account review and collection can continue under the statutory exception.
Each nationwide CRA must maintain a webpage allowing requests for:
- a freeze;
- initial, extended, and active-duty alerts; and
- prescreen opt-out.
But the webpage cannot be the only freeze-request method. C031. U.S. Code+1
A freeze does not itself stop prescreened offers because §1681c-1(i)(4)(E) is an exception. The separate opt-out mechanism must be used if that protection is desired.
18. Protected consumers under subsection (j)
Who is a protected consumer?
A protected consumer is:
- an individual under age 16 when the placement request is made; or
- an incapacitated or protected person for whom a guardian or conservator was appointed.
The representative must provide sufficient proof of authority. Examples include:
- a court order;
- a valid power of attorney;
- government-issued proof of parentage, including a birth certificate; or
- a qualifying foster-care certification.
Sufficient identification examples include a Social Security number/card, official birth certificate, driver’s license, motor-vehicle identification card, or other government identification for the protected consumer and representative. C033–C034. U.S. Code+2
Placement and creation of a record
Upon the representative’s direct request and receipt of both sufficient identity and authority proof, the nationwide CRA must place the freeze free:
- within 1 business day for toll-free telephone or secure electronic requests; or
- within 3 business days for mail.
Confirmation and the authentication/removal process are due within 5 business days after placement.
If the protected consumer has no file, the CRA must create a special record solely to implement subsection (j). That record may not be used to assess creditworthiness or the other consumer-report characteristics listed by the statute. C035–C036. U.S. Code+1
Release and removal
After placement, the protected consumer’s report, derived information, or created record cannot be released unless the freeze is removed in accordance with subsection (j). The defined protected-consumer freeze focuses on requests for opening a new credit account. The ordinary subsection (i)(4) exception list is not textually incorporated into subsection (j); this pass therefore does not assume that every ordinary-freeze exception applies identically to a protected record. C036, C040. U.S. Code+1
Removal is allowed:
- on the representative’s direct request;
- on the protected consumer’s own direct request once the person is no longer under 16;
- after material misrepresentation by the representative, with prior written notice.
Requested removal is free and due:
- within 1 hour for telephone or secure electronic requests; or
- within 3 business days for mail.
Temporary removal is also available for a specified period. C037. U.S. Code+1
19. Ordinary versus protected-consumer freeze
| Issue |
Ordinary freeze §1681c-1(i) |
Protected-consumer freeze §1681c-1(j) |
| Requester |
Consumer directly |
Protected consumer’s representative for placement |
| Identity-theft event required |
No |
No |
| Existing file required |
No special record-creation clause |
No; CRA must create protected record if no file |
| Proof |
Proper identification |
Sufficient identity plus representative-authority proof |
| Cost |
Free |
Free |
| Placement timing |
1 business day electronic/phone; 3 by mail |
Same |
| Confirmation |
5 business days after placement |
Same |
| Lift/removal |
Consumer direct request |
Representative, or consumer once not under 16 |
| Exception list |
Explicit ten-item §1681c-1(i)(4) list |
No identical list expressly set out |
| Defined access focus |
Broad restriction subject to exceptions |
New-credit-account opening requests, plus special no-release text |
| Representative pathway |
Not expressly stated for placement |
Expressly required for placement |
G4. Fictional workflows and statutory clocks
The following are invented. No form was sent, no report was created, and no actual consumer result is predicted.
Example 1 — Complete block packet
Actors: Consumer and a CRA.
Facts: The CRA receives all four §1681c-2(a) elements on Monday, November 2, 2026. Assume for illustration that:
- receipt day is day zero;
- “business day” means Monday through Friday;
- no holiday falls within the four-day interval; and
- the identity-theft report is accepted as complete.
Calculation
- Tuesday, November 3: business day 1
- Wednesday, November 4: day 2
- Thursday, November 5: day 3
- Friday, November 6: day 4
Conditional result: Reporting of the identified information must be blocked no later than Friday, November 6. The CRA must promptly send the furnisher the statutory notice. C003, C007; S001 §1681c-2(a)-(b).
Adverse branch: If the statement denying the transaction or proper identity proof is missing, the four-business-day complete-packet clock has not yet been established.
Missing evidence: Actual receipt log, packet contents, report-acceptance status, and the CRA’s business-day convention.
Example 2 — Incomplete or minimally detailed identity-theft report
Facts: A CRA receives an automated report containing a bare allegation but lacking information needed to match the consumer to the file.
Required process: Regulation V may permit reasonable requests for identity proof or a more detailed affidavit. The first request must be made within 15 days after the later of report receipt or the service request. Supplemental requests and the final report-acceptance decision generally occur within the next 15-day period, with a possible 5-day decision period for information arriving on day 11 or later of that second period. C005–C006; S006 §1022.3(i); S007 §1022.123.
Conditional result: The four-business-day block clock is not computed as though all §1681c-2 elements were complete when the report or identity proof remained deficient.
Adverse branch: A detailed official report generally should not attract extra-document demands without an identifiable concern.
Missing evidence: Exact report, requested service, request dates, and requested documentation.
Example 3 — Block declined or rescinded
Facts: A CRA initially blocks a retail account but later receives reliable evidence that the consumer personally received the purchased goods.
Decision-maker: CRA.
Conditional result: The CRA may rescind if it reasonably determines §1681c-2(c)(1)(C) is met and must promptly send the reinsertion-style notice. C008–C009.
Adverse branch: The fact that the account previously appeared in the file is not, standing alone, proof that the consumer received the goods or knew of the transaction.
Missing evidence: Delivery records, authentication, consumer response, and notice date.
Example 4 — Initial versus extended alert
Initial-alert branch
- Consumer has a good-faith suspicion but no completed identity-theft report.
- Proper identity proof is supplied.
- One nationwide CRA is contacted.
- Alert period: at least one year.
- One special free file from each nationwide CRA can be requested.
Extended-alert branch
- Consumer has a qualifying identity-theft report.
- Alert period: seven years.
- Prescreen exclusion: five years.
- Two special free file disclosures from each nationwide CRA in the first twelve months.
If requested on November 2, 2026, the anniversary references would be November 2, 2027 and November 2, 2033, respectively. Because the statute says the periods begin on the request date but supplies no general endpoint-counting convention in the provisions read, those are anniversary references—not individualized last-day determinations. C017–C020.
Example 5 — Active-duty alert
Facts: A hypothetical consumer meets the statutory active-duty definition and supplies proper identity proof through a representative.
Result:
- alert: 12 months;
- prescreen exclusion: 2 years;
- contacted nationwide CRA refers the alert to the others;
- prospective users use the initial/active identity-verification standard.
Adverse branch: Military affiliation without qualifying active duty away from the usual duty station does not establish this specific statutory status.
Missing evidence: Actual duty orders, assignment, requester authority, identity proof, and alert placement date.
C021–C023.
Example 6 — Ordinary freeze and one-hour temporary lift
Facts: A consumer directly submits an authenticated secure-electronic temporary-lift request at 2:00 p.m. Pacific on Tuesday, November 10, 2026, identifying the permitted lift period.
Conditional calculation: The statutory one-hour deadline produces a modeled deadline of 3:00 p.m. Pacific the same day.
Result: The CRA must temporarily remove the freeze for the consumer-specified period. C028; S003 §1681c-1(i)(3)(C), (E).
Adverse branch: An incomplete authentication attempt does not establish receipt of the qualifying direct request.
Missing evidence: Actual receipt timestamp, time zone used by the CRA, authentication, and lift-period specification.
Example 7 — Existing creditor or collector versus a new creditor
Existing-account branch: A creditor with whom the consumer has an existing account—or its qualifying agent, affiliate, assignee, or collection party—seeks the report for account review or collection. Clause (i)(4)(A) can permit that use despite the freeze.
New-credit branch: An unrelated prospective creditor cannot access the frozen report under the existing-account exception. If the consumer does not permit access, it may treat the application as incomplete.
Adverse branch: Calling oneself a “collector” does not automatically satisfy clause (A); the relevant relationship or another statutory exception must exist.
C025, C029.
Example 8 — Child or protected adult with missing authority proof
Facts: A mailed placement request for a protected consumer arrives Friday, November 6, 2026, but contains identification documents without proof that the requester has authority.
Result: The statutory placement predicate is incomplete; the three-business-day deadline is not established on those facts.
Alternative complete-packet calculation: Assume the complete request arrives Friday, November 6 and, solely for illustration, business days are weekdays excluding Veterans Day, Wednesday, November 11:
- Monday, November 9: business day 1
- Tuesday, November 10: day 2
- Wednesday, November 11: excluded as a federal legal public holiday
- Thursday, November 12: day 3 — modeled placement deadline
If placement occurs November 12, the modeled five-business-day confirmation deadline is:
- Friday, November 13: day 1
- Monday, November 16: day 2
- Tuesday, November 17: day 3
- Wednesday, November 18: day 4
- Thursday, November 19: day 5
The FCRA provisions read do not themselves define business day by reference to the federal holiday statute. The calculation is expressly conditional. Veterans Day is listed as November 11 in 5 U.S.C. §6103. C035, C037, C042. GovInfo
Example 9 — Blocked debt transferred to another collector
Facts: A debt owner receives the statutory §1681c-2 identity-theft notification and nevertheless places the same debt with a new third-party collector.
Conditional result: Section 1681m(f) prohibits that placement unless an actual statutory exception applies. A routine reassignment to another collector is not one of the three listed exceptions. C014.
Adverse branch: A genuine assignee-required repurchase, securitization/pledge, or enumerated corporate transfer is separately treated.
Missing evidence: Notification, debt identity, transfer document, transferee role, and exception facts.
G5. Currentness and old-to-new disposition
20. Current primary text
This pass freshly read the following OLRC sections through Public Law 119-134, October 20, 2026:
- 15 U.S.C. §1681c-2;
- §1681c-1;
- §1681s-2;
- §1681m;
- §1681i;
- §1681h; and
- §1681j.
The exact current §1681s URL was inaccessible in this browsing session, so the complaint-referral provision was read from the official 2024 Edition published by the Government Publishing Office. Section 1681a was read from the OLRC compilation through Public Law 119-124, October 15, 2026; an attempted later /119-134/ retrieval was unavailable. No claim is made that the older displayed editions are the same as a successfully read October 20 body. U.S. Code+7
The 2018 amendments changed the initial alert from 90 days to one year and added subsections (i) and (j). Those changes took effect 120 days after May 24, 2018—September 21, 2018. The separate active-duty monitoring amendment had a one-year effective-date rule. C038. U.S. Code
21. P04/P05 old-to-new crosswalk
| Prior reviewed item |
PASS-09 disposition |
New claims |
Remaining hold |
| P04 C037: federal free nationwide freeze supersedes conflicting Wisconsin fee implication |
Federal free placement/removal and ordinary exceptions are now independently verified from current §1681c-1(i) |
C026–C032 |
Wisconsin §100.54’s current body and any state/federal interaction remain unverified |
| P05 C015: ordinary national-freeze rules are §1681c-1(i)(2)-(4) |
Confirmed and expanded to placement, confirmation, removal, temporary lift, full A-J exception list, webpage, and new-credit application consequence |
C026–C032 |
No actual bureau request or account |
| P05 C016: protected-consumer freeze belongs in subsection (j), not ordinary exceptions |
Confirmed and expanded to definitions, representative proof, record creation, placement/removal clocks, and age branch |
C033–C040 |
Exact noncredit-use edge cases remain held |
| P04 coverage row 11: full alerts, blocks, and freezes excluded |
The federal component is now substantively researched in PASS-09 |
C001–C043 |
P04 is not retroactively accepted; Wisconsin overlay and remedies remain open |
C039–C040.
22. Wisconsin §100.54 hold
No new Wisconsin §100.54 body was read in PASS-09. The earlier official integrated-source failure and current-fee/body hold remain intact. This federal pass establishes the federal no-charge rights but does not certify:
- the complete current Wisconsin statutory text;
- every Wisconsin-protected-consumer variation;
- any distinct Wisconsin deadline or exception;
- preemption of every state provision; or
- a private Wisconsin claim.
C039.
Source register — S_WI-P09-S001 onward
All fresh accesses occurred October 26, 2026 Pacific / October 27, 2026 UTC. Exact per-resource access times are unavailable. All cited source bodies are HTML; therefore printed-page and zero-based PDF-index fields are N/A unless expressly noted.
| Source ID |
Issuer / title / complete literal URL |
Exact pinpoint, version, status |
Actual read and limit |
| S_WI-P09-S001 |
U.S. House OLRC, 15 U.S.C. §1681c-2 — Block of information resulting from identity theft. https://uscode.house.gov/us/usc/119-134/t15/s1681c-2/ |
§1681c-2(a)-(f); laws through Pub. L. 119-134, Oct. 20, 2026; HTML, pages N/A |
Fresh complete operative body read. U.S. Code+2 |
| S002 |
U.S. Government Publishing Office, 15 U.S.C. §1681c-2, 2024 Edition. https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapIII-sec1681c-2.htm |
Entire §1681c-2; 2024 annual edition; HTML |
Fresh official alternate body read; not substituted for current S001. GovInfo |
| S003 |
U.S. House OLRC, 15 U.S.C. §1681c-1 — Identity theft prevention; fraud alerts and active duty alerts. https://uscode.house.gov/us/usc/119-134/t15/s1681c-1/ |
§1681c-1(a)-(k), especially (a)-(j); amendments/effective-date notes; laws through Pub. L. 119-134, Oct. 20, 2026 |
Fresh complete material body read. U.S. Code+2 |
| S004 |
U.S. Government Publishing Office, 15 U.S.C. §1681c-1, 2024 Edition. https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapIII-sec1681c-1.htm |
Entire §1681c-1; 2024 annual edition; HTML |
Fresh official alternate read; current rule controlled by S003. GovInfo |
| S005 |
U.S. House OLRC, 15 U.S.C. §1681a — Definitions. https://uscode.house.gov/us/usc/119-124/t15/s1681a/ |
§1681a(c), (f), (p), (q), (u), (x); laws through Pub. L. 119-124, Oct. 15, 2026 |
Fresh relevant body read. Later /119-134/ route was unavailable; definition-currentness bounded accordingly. U.S. Code+2 |
| S006 |
CFPB, Regulation V, 12 C.F.R. §1022.3 — Definitions. https://www.consumerfinance.gov/rules-policy/regulations/1022/3/ |
§1022.3(f)-(i), especially identity theft/report and supplemental-document timelines; current regulation |
Fresh complete relevant body read. Consumer Financial Protection Bureau |
| S007 |
CFPB, Regulation V, §1022.123 — Appropriate proof of identity. https://www.consumerfinance.gov/rules-policy/regulations/1022/123/ |
§1022.123(a)-(b); current regulation |
Fresh complete body read. Consumer Financial Protection Bureau |
| S008 |
CFPB, Regulation V, §1022.121 — Active duty alerts. https://www.consumerfinance.gov/rules-policy/regulations/1022/121/ |
§1022.121(a), 12-month duration; current regulation |
Fresh complete body read. Consumer Financial Protection Bureau |
| S009 |
U.S. House OLRC, 15 U.S.C. §1681i — Procedure in case of disputed accuracy. https://uscode.house.gov/us/usc/119-134/t15/s1681i/ |
§1681i(a)(5)(B), reinsertion notice; related dispute provisions; laws through Pub. L. 119-134 |
Fresh relevant body read; not a full PASS-03 rerun. U.S. Code |
| S010 |
U.S. House OLRC, 15 U.S.C. §1681s-2 — Furnisher responsibilities. https://uscode.house.gov/us/usc/119-134/t15/s1681s-2/ |
§1681s-2(a)(6)(A)-(B); laws through Pub. L. 119-134 |
Fresh operative body read. U.S. Code |
| S011 |
U.S. House OLRC, 15 U.S.C. §1681m — Requirements on users of consumer reports. https://uscode.house.gov/us/usc/119-134/t15/s1681m/ |
§1681m(f)-(g); laws through Pub. L. 119-134 |
Fresh relevant operative body read. U.S. Code+1 |
| S012 |
U.S. Government Publishing Office, 15 U.S.C. §1681s — Administrative enforcement, 2024 Edition. https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapIII-sec1681s.htm |
§1681s(f); 2024 annual edition |
Fresh official alternate read. Exact current /119-134/ OLRC route was inaccessible. GovInfo |
| S013 |
U.S. House OLRC, 15 U.S.C. §1681j — Charges for certain disclosures. https://uscode.house.gov/us/usc/119-134/t15/s1681j/ |
§1681j(c)-(e), particularly (d); laws through Pub. L. 119-134 |
Fresh relevant body read. U.S. Code |
| S014 |
U.S. House OLRC, 15 U.S.C. §1681h — Conditions and form of disclosure. https://uscode.house.gov/us/usc/119-134/t15/s1681h/ |
§1681h(a)-(b); proper identification and disclosure forms; laws through Pub. L. 119-134 |
Fresh relevant body read. U.S. Code |
| S015 |
CFPB, Regulation V, §1022.43 — Direct disputes. https://www.consumerfinance.gov/rules-policy/regulations/1022/43/ |
§1022.43(a)(1), (b)-(e); current regulation |
Fresh narrow identity-theft crossover read; general dispute dossier not rerun. Consumer Financial Protection Bureau |
| S016 |
CFPB, Regulation V, Appendix I — Summary of Consumer Identity Theft Rights. https://www.consumerfinance.gov/rules-policy/regulations/1022/i/ |
Appendix I introductory prescription; model images not opened; current regulation |
Fresh text body read. Linked image forms remained unopened and were not submitted. Consumer Financial Protection Bureau |
| S017 |
Federal Trade Commission, Credit Freezes and Fraud Alerts. https://consumer.ftc.gov/articles/credit-freezes-and-fraud-alerts |
Current public guidance; freeze/alert distinctions and current operational overview |
Fresh agency guidance read; not substituted for statutory text. Consumer Advice |
| S018 |
CFPB, What do I do if I am a victim of identity theft? https://www.consumerfinance.gov/ask-cfpb/what-do-i-do-if-i-am-a-victim-of-identity-theft-en-31/ |
Last reviewed July 30, 2026; alert, freeze, block, and IdentityTheft.gov guidance |
Fresh agency guidance read; no bureau or consumer account accessed. Consumer Financial Protection Bureau+1 |
| S019 |
Federal Trade Commission, Report Identity Theft. https://www.ftc.gov/news-events/topics/identity-theft/report-identity-theft |
IdentityTheft.gov reporting and recovery route |
Fresh agency guidance read. No report made. Federal Trade Commission |
| S020 |
U.S. Government Publishing Office, 5 U.S.C. §6103 — Holidays, 2024 Edition. https://www.govinfo.gov/content/pkg/USCODE-2024-title5/html/USCODE-2024-title5-partIII-subpartE-chap61-subchapI-sec6103.htm |
§6103(a), Veterans Day; 2024 edition |
Fresh official body read solely for a disclosed hypothetical calendar assumption. GovInfo |
| S021 |
Wisconsin Legislature, Wis. Stat. §100.54 — Security freezes. https://docs.legis.wisconsin.gov/statutes/statutes/100/54 |
Current complete body not read in PASS-09 |
Not freshly accessed by design. Prior integrated-source/current-fee hold preserved; no Wisconsin claim based on unread text. |
Source-register count: 21.
Atomic claim register — S_WI-P09-C001 onward
| Claim ID |
A066 |
Actor / predicate |
Atomic assertion and required act |
Clock / consequence |
Evidence |
Exception / retained limit |
| C001 |
66 / open |
Consumer and CRA |
§1681c-2 applies to CRA-held information identified as alleged identity theft |
Block route available upon complete packet |
S001 §1681c-2(a) |
Reseller/check-service branches differ |
| C002 |
66 / open |
Consumer vs representative |
Block subsection expressly refers to consumer; alerts expressly permit representatives |
No general block-representative rule inferred |
S001; S003(a)-(c) |
Capacity/agency law held |
| C003 |
66 / open |
CRA receives all four items |
CRA must block reporting of identified information |
Within 4 business days after complete receipt |
S001(a) |
No clock from incomplete packet |
| C004 |
66 / open |
Consumer/reporting actor |
Identity theft and identity-theft report have statutory/regulatory definitions |
Official valid report with specificity and false-report consequence |
S005(q); S006(g)-(i) |
Actual crime not adjudicated |
| C005 |
66 / open |
CRA/furnisher reviewing report |
Reasonable additional information may be requested under regulated time limits |
15 days + another 15; possible final 5 days |
S006(i) |
Detailed reports ordinarily need no unsupported extra demands |
| C006 |
66 / open |
CRA |
Reasonable proof of identity must match file and risk |
Proof can include identifying data/documents/authentication |
S007 |
No mandatory single document |
| C007 |
66 / open |
CRA to furnisher |
CRA promptly sends four specified block notices |
Furnisher receives block status/effective dates |
S001(b) |
Prompt has no numerical period here |
| C008 |
66 / open |
CRA |
CRA may decline/rescind only on three specified reasonable determinations |
Block can be removed |
S001(c)(1),(3) |
Prior file appearance is not evidence of benefit |
| C009 |
66 / open |
CRA to consumer |
Decline/rescission requires prompt reinsertion-style notice |
Cross-reference uses §1681i(a)(5)(B) manner |
S001(c)(2); S009(a)(5)(B) |
No independent decision deadline invented |
| C010 |
66 / open |
Reseller |
No-file and maintained-report reseller branches carry different duties |
Notice/source-CRA disclosure where required |
S001(d) |
Sole obligation text preserved |
| C011 |
66 / open |
Check service / law enforcement |
Check service has special three-element four-day rule; lawful law-enforcement access preserved |
Narrow exceptions |
S001(e)-(f) |
Not universal CRA treatment |
| C012 |
66 / open |
Furnisher receiving CRA notice |
Furnisher must prevent refurnishing blocked information |
Reasonable procedures required |
S010(a)(6)(A) |
Internal debt records not erased |
| C013 |
66 / open |
Consumer to furnisher |
Identity report sent to specified address bars furnishing unless later known/confirmed correct |
No-furnish status |
S010(a)(6)(B) |
Does not decide collection or debt merits |
| C014 |
66 / open |
Person notified under block statute |
Sale, consideration transfer, or collection placement generally prohibited |
Limited repurchase/securitization/corporate exceptions |
S011(f) |
Distinct from Reg F PASS-05 rule |
| C015 |
66 / open |
Third-party debt collector |
Collector tells creditor/user and supplies otherwise available dispute information on request |
Information duty |
S011(g) |
No automatic waiver |
| C016 |
66 / open |
CRA/furnisher/consumer |
Block, CRA dispute, direct furnisher dispute, alert, and freeze are distinct routes |
Different consequences |
S001, S009, S015 |
No universal collection stay |
| C017 |
66 / open |
Consumer/representative |
Initial alert requires good-faith suspicion and identity proof, not an identity-theft report |
At least 1 year |
S003(a)(1) |
Early removal possible |
| C018 |
66 / open |
Nationwide CRAs |
Initial alert is referred; one free file disclosure per CRA on request |
Disclosure within 3 business days |
S003(a)(2),(e); S013(d) |
Not an annual-report replacement |
| C019 |
66 / open |
Consumer/representative |
Extended alert requires identity-theft report and identity proof |
7 years |
S003(b)(1) |
Early removal possible |
| C020 |
66 / open |
Nationwide CRA |
Extended alert carries 5-year prescreen exclusion and two free file copies in first 12 months |
Files within 3 business days after request |
S003(b) |
Consumer may rescind prescreen exclusion |
| C021 |
66 / open |
Active-duty military consumer/representative |
Qualifying duty definition, identity proof, 12-month alert, 2-year prescreen exclusion |
Referral to other nationwide CRAs |
S003(c); S005(q)(1); S008 |
No identity-theft report required |
| C022 |
66 / open |
Nationwide CRA/reseller/non-nationwide CRA |
Alerts referred; resellers reconvey; other CRAs provide contact information |
Coordination duties |
S003(e)-(g); S012(f) |
Block referrals not identical to alert referrals |
| C023 |
66 / open |
Prospective credit user |
Initial/active alert requires reasonable identity-verification procedures |
Contact specified number or other reasonable verification |
S003(h)(1) |
Does not prohibit report access |
| C024 |
66 / open |
Prospective credit user |
Extended alert requires in-person or designated-method confirmation |
Covered credit cannot proceed without confirmation |
S003(h)(2) |
Exact credit-request scope preserved |
| C025 |
66 / open |
Consumer/user |
Alert, freeze, and block have different purposes |
Alert verifies; freeze restricts access; block suppresses identified reporting |
S001, S003, S017 |
None cancels debt |
| C026 |
66 / open |
Consumer / nationwide CRA |
Ordinary freeze is free and requires direct request plus proper ID |
1 business day electronic/phone; 3 mail |
S003(i)(1)-(2) |
Identity theft not required |
| C027 |
66 / open |
Nationwide CRA |
Confirmation and authentication mechanism required |
5 business days after placement |
S003(i)(2)(B) |
Statute does not mandate PIN/product/account |
| C028 |
66 / open |
Consumer / nationwide CRA |
Removal and temporary lift use direct request and proper ID |
1 hour electronic/phone; 3 business days mail |
S003(i)(3) |
Application may be treated incomplete if access denied |
| C029 |
66 / open |
Existing-account and public actors |
Freeze exceptions (A)-(D) allow specified account/collection and governmental uses |
Report may be furnished despite freeze |
S003(i)(4)(A)-(D) |
Relationship/order/purpose predicates required |
| C030 |
66 / open |
Other specified users |
Exceptions (E)-(J) cover prescreening, monitoring, consumer copy, insurance, screening, authentication/fraud |
Freeze not universal access ban |
S003(i)(4)(E)-(J) |
Other FCRA duties remain |
| C031 |
66 / open |
Nationwide CRA |
Freeze/alerts/opt-out webpage required, but webpage not exclusive freeze mechanism |
Consumer-access route |
S003(i)(5)-(6) |
Prescreen opt-out remains separate |
| C032 |
66 / open |
Consumer / multiple nationwide CRAs |
Freeze has no alert-style automatic referral placement |
Direct request needed at each CRA |
S003(i); S017–S018 |
Complaint-referral procedures do not equal automatic placement |
| C033 |
66 / open |
Minor/protected adult |
Protected consumer means under 16 at placement or guardian/conservator-protected person |
Subsection (j) applies |
S003(j)(1)(B) |
No individual capacity decision made |
| C034 |
66 / open |
Representative |
Placement requires sufficient authority and identification proof |
Examples statutorily listed |
S003(j)(1)(C),(F),(G) |
Actual document sufficiency untested |
| C035 |
66 / open |
Representative / nationwide CRA |
Protected freeze free placement and confirmation |
1/3 business days; confirmation in 5 |
S003(j)(2) |
Complete proof required |
| C036 |
66 / open |
CRA with no protected file |
CRA creates special non-creditworthiness record and restricts release after freeze |
Record protected until removal |
S003(j)(1)(D)-(E),(2)(C),(3) |
Exact noncredit edge scope held |
| C037 |
66 / open |
Representative or age-eligible protected consumer |
Protected freeze removal/temporary lift |
1 hour electronic/phone; 3 business days mail |
S003(j)(4) |
Misrepresentation branch needs prior notice |
| C038 |
66 / open |
Statutory currentness |
2018 law created one-year alert and (i)/(j), effective 120 days after May 24, 2018 |
Current OLRC through Oct. 20, 2026 read |
S003 amendment/effective notes |
No complete citator claim |
| C039 |
66 / open |
Wisconsin overlay |
Wisconsin §100.54 current body remains unread in this pass |
State-specific additions/conflicts held |
S021 |
No state-law clearance |
| C040 |
66 / open |
Prior-report crosswalk |
P04/P05 boundary corrections confirmed and expanded federally |
No retroactive acceptance |
Supplied review rows; C026-C039 |
P04-P06 provenance preserved |
| C041 |
66 / open |
Consumer/debt |
Block, alert, or freeze does not itself invalidate or forgive debt or create automatic damages |
Separate merits/remedies required |
S001, S003, S010–S011 |
Private relief not researched |
| C042 |
66 / open |
Clock/report route |
Business day not defined in provisions read; IdentityTheft.gov is official report route |
Calendar examples expressly conditional |
S019–S020 |
No report created |
| C043 |
66 / open |
Active-duty consumer |
Free active-duty monitoring under subsection (k) is separate from active-duty alert |
Separate proof/enforcement structure |
S003(k) |
Full monitoring program deferred |
Atomic-claim count: 43.
Complete granular coverage table
Core federal coverage
| # |
Group / subissue |
Status |
Claims |
Evidence |
Exact remaining fact or next action |
| 1 |
G1 consumer and CRA block scope |
Answered |
C001 |
S001(a) |
Apply actual CRA/file facts only if later authorized |
| 2 |
Block request by representative |
Unresolved beyond text |
C002 |
S001 vs S003 |
Research capacity/agency law if needed |
| 3 |
Identity-theft definition |
Answered |
C004 |
S005(q)(3), S006(h) |
Actual criminal event excluded |
| 4 |
Identity-theft-report definition |
Answered |
C004 |
S005(q)(4), S006(i) |
Actual report not supplied |
| 5 |
Supplemental-document reasonableness |
Answered |
C005 |
S006(i)(1)-(3) |
Apply to actual report detail |
| 6 |
Initial 15-day extra-information request |
Answered |
C005 |
S006(i)(1)(iii)(A) |
Actual receipt dates absent |
| 7 |
Second 15-day report-acceptance period |
Answered |
C005 |
S006(i)(1)(iii)(B) |
Actual request/response absent |
| 8 |
Five-day late-supplement determination |
Answered |
C005 |
S006(i)(1)(iii)(C) |
Actual arrival date absent |
| 9 |
CRA proof-of-identity standard |
Answered |
C006 |
S007 |
Actual documents excluded |
| 10 |
Packet: proof of identity |
Answered |
C003, C006 |
S001(a)(1), S007 |
Completeness factual |
| 11 |
Packet: identity-theft report |
Answered |
C003–C005 |
S001(a)(2), S006 |
Acceptance factual |
| 12 |
Packet: identify information |
Answered |
C003 |
S001(a)(3) |
Actual tradeline/report excluded |
| 13 |
Packet: no-transaction statement |
Answered |
C003 |
S001(a)(4) |
Actual statement excluded |
| 14 |
Four-business-day trigger |
Answered |
C003 |
S001(a) |
Business-day convention held |
| 15 |
Furnisher notification content |
Answered |
C007 |
S001(b) |
“Promptly” has no number here |
| 16 |
Decline because error |
Answered |
C008 |
S001(c)(1)(A) |
Reasonable determination factual |
| 17 |
Decline because misrepresentation |
Answered |
C008 |
S001(c)(1)(B) |
Materiality factual |
| 18 |
Decline because consumer received benefit |
Answered |
C008 |
S001(c)(1)(C) |
Goods/services/money evidence factual |
| 19 |
Decline/rescind notice |
Answered with timing limit |
C009 |
S001(c)(2), S009 |
Prompt cross-reference; no invented decision period |
| 20 |
Pre-block file presence |
Answered |
C008 |
S001(c)(3) |
Evidentiary rule narrow |
| 21 |
Reseller with no relevant file |
Answered |
C010 |
S001(d)(1) |
Actual reseller role |
| 22 |
Reseller maintaining report |
Answered |
C010 |
S001(d)(2)-(3) |
Source-CRA identities factual |
| 23 |
Check-services exception |
Answered |
C011 |
S001(e) |
Actor must be acting as check service |
| 24 |
Law-enforcement access |
Answered |
C011 |
S001(f) |
Underlying permissible access still required |
| 25 |
Furnisher anti-refurnishing procedures |
Answered |
C012 |
S010(a)(6)(A) |
Actual system untested |
| 26 |
Direct identity report to furnisher |
Answered |
C013 |
S010(a)(6)(B) |
Specified address and report needed |
| 27 |
Identity-theft debt sale/placement ban |
Answered |
C014 |
S011(f)(1)-(2) |
Statutory notice required |
| 28 |
Repurchase exception |
Answered |
C014 |
S011(f)(3)(A) |
Assignee-required repurchase facts |
| 29 |
Securitization/pledge exception |
Answered |
C014 |
S011(f)(3)(B) |
Actual structure excluded |
| 30 |
Corporate-transfer exception |
Answered |
C014 |
S011(f)(3)(C) |
Actual merger/acquisition facts |
| 31 |
Debt-collector creditor notification |
Answered |
C015 |
S011(g)(1) |
Collector and third-party roles factual |
| 32 |
Debt-collector information response |
Answered |
C015 |
S011(g)(2) |
Underlying dispute law separately determines information |
| 33 |
Block versus CRA dispute |
Answered boundary |
C016 |
S001, S009 |
PASS-03 not adopted |
| 34 |
Block versus direct furnisher dispute |
Answered boundary |
C016 |
S010, S015 |
No full dispute rerun |
| 35 |
Nationwide block-referral coordination |
Partial |
C022, C032 |
S012(f) |
No automatic multi-CRA block conclusion |
| 36 |
G2 initial-alert eligibility |
Answered |
C017 |
S003(a)(1) |
Good-faith suspicion factual |
| 37 |
Initial-alert report not required |
Answered |
C017 |
S003(a)(1) |
No identity-theft adjudication |
| 38 |
Initial-alert duration |
Answered |
C017 |
S003(a)(1)(A) |
Early removal possible |
| 39 |
Initial-alert free file |
Answered |
C018 |
S003(a)(2), S013(d) |
Request required |
| 40 |
Initial-alert 3-business-day file clock |
Answered |
C018 |
S003(a)(2)(B) |
Receipt/date factual |
| 41 |
Extended-alert identity report |
Answered |
C019 |
S003(b)(1) |
Actual report absent |
| 42 |
Extended-alert duration |
Answered |
C019 |
S003(b)(1)(A) |
Early removal possible |
| 43 |
Extended-alert prescreen exclusion |
Answered |
C020 |
S003(b)(1)(B) |
Early rescission possible |
| 44 |
Extended-alert two free files |
Answered |
C020 |
S003(b)(2) |
Requests required |
| 45 |
Active-duty consumer definition |
Answered |
C021 |
S005(q)(1) |
Actual status excluded |
| 46 |
Active-duty 12-month alert |
Answered |
C021 |
S003(c), S008 |
Early removal/renewal possible |
| 47 |
Active-duty 2-year prescreen exclusion |
Answered |
C021 |
S003(c)(2) |
Early rescission possible |
| 48 |
Active-duty alert-specific free file |
Answered as not supplied by subsection (c) |
C021 |
S003(c) |
Other free-report rights remain |
| 49 |
Alert referral to other nationwide CRAs |
Answered |
C018–C022 |
S003(a)-(e) |
Direct initial request still needs proper proof |
| 50 |
Reseller reconveys alerts |
Answered |
C022 |
S003(f) |
Actual reseller report |
| 51 |
Non-nationwide CRA contact-information duty |
Answered |
C022 |
S003(g) |
Does not create alert at specialty CRA |
| 52 |
Initial/active prospective-user verification |
Answered |
C023 |
S003(h)(1) |
Actual application/user process excluded |
| 53 |
Extended-alert contact confirmation |
Answered |
C024 |
S003(h)(2) |
Actual contact method needed |
| 54 |
Alert versus block versus freeze |
Answered |
C025 |
S001, S003 |
No generic interchangeability |
| 55 |
Active-duty monitoring |
Excluded/deferred |
C043 |
S003(k) |
Separate monitoring-rule pass |
| 56 |
G3 ordinary-freeze CRA scope |
Answered |
C026 |
S003(i)(1), S005(p) |
Nationwide specialty CRA different |
| 57 |
Freeze available without identity theft |
Answered |
C026 |
S003(i)(2), S017 |
Direct request still needed |
| 58 |
Freeze placement electronic/phone |
Answered |
C026 |
S003(i)(2)(A)(i) |
Complete direct request/proper ID |
| 59 |
Freeze placement mail |
Answered |
C026 |
S003(i)(2)(A)(ii) |
Receipt factual |
| 60 |
Placement confirmation |
Answered |
C027 |
S003(i)(2)(B) |
Actual delivery factual |
| 61 |
Authentication mechanism, not mandatory PIN |
Answered |
C027 |
S003(i)(2)(B) |
Bureau implementation can vary |
| 62 |
Consumer-requested permanent removal |
Answered |
C028 |
S003(i)(3)(C) |
Proper ID/direct request |
| 63 |
CRA removal for material misrepresentation |
Answered |
C028 |
S003(i)(3)(A)-(B) |
Prior written notice |
| 64 |
Temporary lift |
Answered |
C028 |
S003(i)(3)(E) |
Consumer must specify period |
| 65 |
Frozen credit application treated incomplete |
Answered |
C028 |
S003(i)(3)(D) |
Only where access denied |
| 66 |
Exception A: existing account/collection |
Answered |
C029 |
S003(i)(4)(A) |
Relationship/purpose predicates |
| 67 |
Exceptions B-D: court/government/support |
Answered |
C029 |
S003(i)(4)(B)-(D) |
Orders, statutory duties, permissible purpose |
| 68 |
Exceptions E-J |
Answered |
C030 |
S003(i)(4)(E)-(J) |
Each use-specific |
| 69 |
Freeze webpage |
Answered |
C031 |
S003(i)(6) |
Cannot be exclusive request route |
| 70 |
Prescreen opt-out separate from freeze |
Answered |
C031 |
S003(i)(4)(E), (6)(A)(v) |
Separate consumer act required |
| 71 |
Freeze referral to other CRAs |
Answered negatively |
C032 |
S003(i), S017–S018 |
Each direct request required |
| 72 |
Protected-consumer definition |
Answered |
C033 |
S003(j)(1)(B) |
Individual capacity not decided |
| 73 |
Representative authority proof |
Answered |
C034 |
S003(j)(1)(C),(F) |
Actual sufficiency excluded |
| 74 |
Protected identification proof |
Answered |
C034 |
S003(j)(1)(G) |
Actual documents excluded |
| 75 |
Protected placement and deadlines |
Answered |
C035 |
S003(j)(2) |
Complete proof required |
| 76 |
Protected no-file record creation |
Answered |
C036 |
S003(j)(2)(C) |
Record not a creditworthiness file |
| 77 |
Protected release restriction |
Answered with scope hold |
C036, C040 |
S003(j)(1)(E),(3) |
Noncredit edge interaction unresolved |
| 78 |
Protected removal and age branch |
Answered |
C037 |
S003(j)(4)(A)-(C) |
Status at removal date matters |
| 79 |
Protected temporary lift |
Answered |
C037 |
S003(j)(4)(D) |
Specified period required |
| 80 |
Ordinary (i)(4) vs protected (j) exceptions |
Answered as textual distinction |
C040 |
S003(i)(4), (j) |
No automatic incorporation inferred |
| 81 |
G5 current OLRC block source |
Answered |
C038 |
S001 |
Through Pub. L. 119-134 |
| 82 |
Current OLRC alert/freeze source |
Answered |
C038 |
S003 |
Through Pub. L. 119-134 |
| 83 |
GovInfo different official alternate |
Answered |
C038 |
S002, S004 |
2024 annual edition, not current substitute |
| 84 |
§1681a compilation boundary |
Partial/currentness held |
C004, C038 |
S005 |
Later /119-134/ body unavailable |
| 85 |
§1681s referral compilation boundary |
Partial/currentness held |
C022 |
S012 |
Current exact OLRC route unavailable |
| 86 |
Wisconsin §100.54 |
Unresolved |
C039 |
S021 |
Fresh current state body required |
| 87 |
P04 C037 crosswalk |
Answered |
C040 |
Prior supplied review row + C026-C032 |
No retroactive P04 acceptance |
| 88 |
P05 C015 ordinary-freeze correction |
Answered/confirmed |
C040 |
S003(i) |
Wisconsin overlay remains open |
| 89 |
P05 C016 protected-consumer correction |
Answered/confirmed |
C040 |
S003(j) |
Edge use cases remain held |
| 90 |
Business-day definition |
Unresolved |
C042 |
S001, S003 |
Congress did not define it in provisions read |
| 91 |
IdentityTheft.gov official route |
Answered operationally |
C042 |
S018–S019 |
No filing/contact performed |
| 92 |
No automatic debt cancellation |
Answered boundary |
C041 |
S001, S010–S011 |
Underlying debt/remedies later |
| 93 |
No automatic private award |
Answered boundary |
C041 |
Scope limitation |
Full remedies and standing deferred |
Core coverage rows: 93.
Territorial and actor branches
| # |
Branch |
Status |
Claims |
Exact boundary |
| T1 |
Hypothetical Wisconsin consumer using federal FCRA protections |
Answered federally |
C001–C043 |
Wisconsin residence does not alter the federal trigger requirements |
| T2 |
Nationwide credit CRA under §1681a(p) |
Answered |
C017–C040 |
Alert/freeze provisions expressly use this actor |
| T3 |
Nationwide specialty CRA under §1681a(x) |
Partial |
C001, C022, C026 |
General block can apply to a CRA; alert/freeze nationwide-credit provisions are not silently extended |
| T4 |
Reseller |
Answered within block/alert branches |
C010, C022 |
General reseller dispute procedures remain outside scope |
| T5 |
Check-services company |
Answered narrowly |
C011 |
Only §1681c-2(e) special rule established |
| T6 |
Wisconsin, tribal, foreign-country, and other-state overlays |
Excluded/open |
C039 |
Separate state/local/tribal/foreign-law work required |
Territorial/actor rows: 6.
Explicit deferred families
| # |
Deferred family |
Reason |
| D1 |
Current full Wis. Stat. §100.54 body and fees |
Prior source/currentness hold preserved |
| D2 |
Wisconsin private remedy, preemption, and local procedure |
Federal pass only |
| D3 |
Tribal identity-theft and reporting rules |
Separate sovereign regime |
| D4 |
Criminal investigation, police-report sufficiency, prosecution, and proof of crime |
No criminal procedure or actual crime supplied |
| D5 |
Actual consumer report, account, inquiry, tradeline, or identity-theft report |
Private data expressly excluded |
| D6 |
General FCRA accuracy and CRA reinvestigation dossier |
PASS-04/PASS-03 scope not rerun |
| D7 |
Full Regulation V direct-dispute dossier |
Only identity-theft crossover read |
| D8 |
FDCPA and Wisconsin collection-conduct consequences |
P02 remains unreviewed |
| D9 |
Debt validity, contract formation, account ownership, and assignment merits |
A block does not adjudicate them |
| D10 |
Collection suit, service, judgments, garnishment, and limitations |
P08 not adopted and not rerun |
| D11 |
Bankruptcy and discharge |
Separate federal regime |
| D12 |
Medical debt, hospital financial assistance, provider status |
P07 unreviewed and outside this component |
| D13 |
Monitoring, identity-theft insurance, locks, apps, and paid bureau products |
Product/policy—not statutory-freeze—questions |
| D14 |
Full active-duty electronic monitoring program |
Separate subsection (k) and FTC rule |
| D15 |
Private action, standing, willfulness, negligence, damages, class relief, and limitations |
No automatic remedy inferred |
| D16 |
Named CRA, creditor, collector, furnisher, lender, employer, landlord, or insurer compliance |
No named-entity search authorized |
| D17 |
Other-state and international protections |
No other jurisdiction adopted |
| D18 |
Publication, operations, A066, component, state, or parent acceptance |
Expressly withheld |
Deferred-family rows: 18.
Evidence-backed article and tool opportunities
A responsible SettleADebt article or tool can classify the requested protection without collecting sensitive data:
- “Which identity-theft credit tool applies?”
Ask whether the issue is a false report item, fear of new-account fraud, confirmed identity theft with a qualifying report, active-duty status, or a child/protected adult. Output the block, alert, or freeze branch with uncertainty—not a promise of deletion.
- Block-packet checklist
Display the four §1681c-2 elements, distinguish identity proof from the identity-theft report, and warn that a general balance dispute is not automatically an identity-theft block request.
- Conditional clock calculator
Accept a user-entered complete-packet receipt date and a user-selected business-day convention. It must state that the FCRA sections read do not define business day and that actual CRA receipt/completeness controls.
- Freeze-exception classifier
Separate a new creditor from an existing creditor, its collector, a court-order collector, an insurer, employer, landlord screener, monitoring service, or identity-authentication user.
- Protected-consumer evidence checklist
Separate proof of representative authority from proof of identity, and explain the no-file record-creation branch.
These are research opportunities only. No tool was built, published, or approved for operation.
Example inventory
| Example |
Subject |
Main claims |
| 1 |
Complete four-element block packet |
C003, C007 |
| 2 |
Incomplete/minimal report and supplemental information |
C004–C006 |
| 3 |
Declined or rescinded block |
C008–C009 |
| 4 |
Initial versus extended alert |
C017–C020 |
| 5 |
Active-duty alert |
C021–C024 |
| 6 |
One-hour temporary freeze lift |
C028 |
| 7 |
Existing collector versus new creditor |
C025, C029 |
| 8 |
Protected consumer with missing authority proof |
C033–C037, C042 |
| 9 |
Identity-theft debt placed with new collector |
C014–C015 |
Worked-flow count: 9.
Old-to-new boundary crosswalk
| Prior row |
PASS-09 finding |
New claims |
Remaining gap |
| P04 C037 |
Federal free ordinary freeze independently verified and fully expanded |
C026–C032 |
Wisconsin §100.54 remains held |
| P05 C015 |
§1681c-1(i)(2)-(4) confirmed from Oct. 20, 2026 OLRC body |
C026–C031, C038 |
Actual bureau operation excluded |
| P05 C016 |
Protected-consumer branch confirmed as subsection (j) and fully researched |
C033–C040 |
Noncredit edge cases and Wisconsin overlay |
| P04 row 11 |
Federal blocks, alerts, and full freeze operations now researched |
C001–C043 |
No retroactive P04/state/parent acceptance |
Crosswalk rows: 4.
Researcher self-check
Actual reading
Freshly read:
- the current OLRC bodies of §§1681c-2, 1681c-1, 1681s-2, 1681m, 1681i, 1681h, and 1681j through Public Law 119-134;
- the relevant §1681a definitions through Public Law 119-124;
- official GPO 2024 alternate editions of §§1681c-1, 1681c-2, and 1681s;
- current Regulation V §§1022.3, 1022.121, 1022.123, and the narrow identity-theft portion of §1022.43;
- CFPB Appendix I’s prescribing text, but not its linked image forms;
- current FTC and CFPB identity-theft, fraud-alert, and freeze guidance; and
- 5 U.S.C. §6103 only for the explicitly conditional holiday example.
Access and currentness limitations
- The current exact OLRC §1681s page was inaccessible; GPO’s official 2024 body supplied the referral provision.
- The later /119-134/ §1681a route was inaccessible; the October 15, 2026 /119-124/ body was read.
- Wisconsin §100.54 was deliberately not subjected to another unchanged failed-endpoint loop. Its current body remains held.
- No commercial citator, named-entity compliance review, private record, or actual CRA operational log was used.
- No source publication date was treated automatically as its effective date.
Clock checks
Two business-day calculations were completed, but both expressly use an assumed convention because the FCRA sections read do not define “business day”:
- November 2, 2026 complete block packet → modeled fourth business day November 6.
- November 6, 2026 protected-consumer mailed complete request → modeled third business day November 12 when November 11 is excluded; modeled fifth confirmation business day November 19.
The secure-electronic lift example uses the statutory one-hour period: 2:00 p.m. → 3:00 p.m. on the same assumed receipt day.
No actual deadline, bureau receipt, score effect, account result, award, refund, or debt cancellation was calculated.
Register reconciliation
| Register |
Visible rows |
| Source register |
21 |
| Atomic claims |
43 |
| Core granular coverage |
93 |
| Territorial/actor branches |
6 |
| Deferred families |
18 |
| Worked flows |
9 |
| Old-to-new crosswalk |
4 |
Source, claim, coverage, scenario, crosswalk, and deferred rows are counted separately.
No actions performed
No named consumer, child, protected adult, servicemember, CRA, lender, collector, debt buyer, furnisher, employer, landlord, insurer, provider, account, report, crime report, court record, military record, or license was searched. No identity-theft report, fraud alert, freeze, block, dispute, complaint, filing, form, account, purchase, contact, or record request was made. No credentials were entered. No website, private account, local coordinator file, or publication was created or changed.
This is the researcher’s self-check, not independent review, legal advice for an actual person, all-source certification, operational approval, publication approval, or acceptance of Wisconsin PASS-09, A066, or the parent dossier.
END S_WI PASS-09.