SettleADebt S_WI PASS-12
Four bounded qualification repairs to reviewed PASS-09
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, GPT-5.6 Sol Pro. No separately exposed power tier, quota state, reset, or measured ranking is claimed.
Scope: Only the four specified PASS-09 qualification groups. PASS-11 remains complete but unreviewed and supplies no premise here. Unaffected PASS-09 findings and all prior Wisconsin/currentness/private-fact/local/tribal/citator/A066/parent holds remain preserved, not recertified.
The exact OLRC /119-134/ sections that failed in the coordinator review were not retried. For §§1681c-1 and 1681c-2, this correction freshly read the official GPO 2024 Edition bodies. Current Regulation V §1022.3 and the OLRC definitions in §§1681a and 1602, compiled through Public Law 119-124 on October 15, 2026, were also freshly read. P09’s historical claim that the researcher accessed later OLRC bodies remains separately attributed; this pass does not replicate or erase it.
G1. Identity-theft-report acceptance clock and two ancillary cells
1. Replacement for PASS-09 paragraph 3 and S_WI-P09-C005
Exact Regulation V sequence
Replace the language saying qualifying late supplemental information provides “five additional days” with:
Regulation V establishes a staged, receipt-dependent process. First, the CRA or furnisher must make its initial request for reasonably necessary supplemental information no later than 15 days after the later of receiving the purported identity-theft report or receiving the consumer’s request for the particular service. Second, supplemental requests and the final acceptance determination ordinarily must occur within another 15 days after that initial request. Third, if the CRA or furnisher receives requested additional information on the 11th day or later within that second 15-day period, §1022.3(i)(1)(iii)(C) gives it five days to make the final acceptance determination. That five-day rule is triggered by the qualifying late receipt; it is not an automatic five-day extension appended to every second 15-day period. Consumer Financial Protection Bureau
Relative timing comparison
| Event in the second 15-day period |
Effect |
| Requested information received on days 1–10 |
Paragraph (C)’s special five-day rule is not triggered; the final determination remains subject to paragraph (B)’s second 15-day period |
| Requested information received on days 11–15 |
Paragraph (C) is triggered; the CRA or furnisher has five days to make the final acceptance determination |
| No requested information received |
No automatic extra five days arises merely because the second period ended |
| Report accepted and the other §1681c-2 elements are complete |
The separate four-business-day blocking clock can then be tested |
| Report remains deficient or unaccepted |
Receipt of an incomplete packet does not establish the complete four-element blocking trigger |
The regulation does not state in this clause whether the receipt day is counted as day zero or day one. No exact calendar endpoint is therefore invented here.
Replacement claim cell for S_WI-P09-C005
| Field |
Corrected content |
| Claim ID |
S_WI-P09-C005 |
| Precise assertion |
Regulation V permits reasonably necessary supplemental-information requests under three linked timing rules: an initial request within 15 days after the later triggering event; supplemental requests and the ordinary final decision within another 15 days after the initial request; and a five-day final-decision period when qualifying requested information arrives on day 11 or later of that second period. |
| Source |
12 C.F.R. §1022.3(i)(1)(iii)(A)–(C) |
| Consequence |
The late-receipt five-day rule is conditional and receipt-triggered, not a universal fixed extension beyond the second 15-day period. |
| Block-clock boundary |
The four-business-day §1681c-2 clock requires receipt of the complete four-element packet, including a qualifying identity-theft report. |
| Limit |
Exact day-count convention and actual completeness remain factual. |
The block statute separately requires all four elements before its four-business-day clock applies. GovInfo
2. Replacement for PASS-09 Example 2
Corrected Example 2 — incomplete or minimally detailed report:
Assume a CRA receives a minimally detailed automated report and reasonably requests additional identification or an affidavit within the first Regulation V 15-day period. The second 15-day period runs from the initial request. If responsive information arrives during days 1–10 of that second period, the special paragraph (C) rule is not triggered. If responsive information arrives on day 11 or later within that period, the CRA has five days to make its final acceptance determination. This is not an automatic “15 + 5” entitlement in every case. Only after a qualifying report is accepted and all four §1681c-2 packet elements are present does the separate four-business-day block analysis begin. Consumer Financial Protection Bureau+1
No actual report, request date, receipt date, or block outcome is determined.
3. Reseller wording correction
PASS-09 stated that the reseller-with-file branch applied when the reseller was the “source” of the identified information. That is not the statutory wording.
Replace it with:
Under §1681c-2(d)(2), the consumer must identify identity-theft information in accordance with subsection (a), and the CRA must be a reseller of the identified information. The reseller’s limited duty is to block the consumer report it maintains from subsequent use. Under paragraph (d)(3), it must promptly notify the consumer of the blocking decision and identify each CRA from which the consumer information was obtained for resale. The reseller need not itself be the original furnisher or source of the disputed account information. GovInfo
Replacement claim cell for S_WI-P09-C010
| Field |
Corrected content |
| Actor |
CRA acting as a reseller |
| Predicate |
Consumer identifies information under subsection (a), and the CRA is a reseller of that identified information |
| Required act |
Block the maintained consumer report from subsequent use |
| Notice |
Promptly notify the consumer and provide the name, address, and telephone number of every source CRA from which the information was obtained for resale |
| Correction |
“Reseller of the identified information” replaces “source of the identified information” |
4. Check-services matrix correction
Replace “after the fourth business day” with:
A check-services company acting in that capacity must, beginning four business days after receipt of the information described in §1681c-2(a)(1)–(3), stop reporting to a nationwide CRA the information identified in the identity-theft report as resulting from identity theft. The special branch does not list the subsection (a)(4) no-transaction statement as a trigger. It should not be rewritten as a fifth-day rule. GovInfo
Corrected actor-matrix cell
| Actor |
Correct trigger and consequence |
| Check-services company acting as such |
Beginning four business days after receipt of subsection (a)(1)–(3) information, it may not report the identified identity-theft information to a nationwide CRA |
G2. Fraud-alert user, credit, score, and trigger qualifications
5. Correct definition of “new credit plan”
Section 1681a(q)(5) defines a new credit plan as either:
- a new account under an open-end credit plan; or
- a new credit transaction not under an open-end credit plan.
The current cross-reference note explains that §1681c-1(h)’s reference to former §1602(i) now corresponds to §1602(j). Section 1602(j) defines an open-end plan as one contemplating repeated transactions under prescribed terms, with a finance charge that may be computed from time to time on the unpaid balance. U.S. Code+2
This produces four distinct §1681c-1(h) branches:
| Branch |
Fraud-alert treatment |
| New account under an open-end plan |
Covered because it is a statutorily defined new credit plan |
| New credit transaction not under an open-end plan |
Covered as a new credit plan |
| Further extension under an already existing open-end plan |
Excluded from the general “extension of credit” phrase by the statutory open-end qualification, unless a separately listed branch applies |
| Consumer-requested additional card on an existing credit account |
Separately covered |
| Consumer-requested increase in the credit limit of an existing account |
Separately covered |
The statutory open-end qualification therefore does not mean every open-end credit event is exempt. In particular, a new open-end account remains a covered “new credit plan.”
6. Replacement for PASS-09 paragraph 13 and S_WI-P09-C023
Initial and active-duty alerts
For an initial or active-duty alert, §1681c-1(h)(1)(B)(i) applies to a prospective user of a consumer report containing the alert. Before taking one of the listed actions, that user must use reasonable policies and procedures to form a reasonable belief that it knows the identity of the requester. The listed actions are:
- establishing a new credit plan;
- making an extension of credit other than under an existing open-end plan;
- issuing a consumer-requested additional card on an existing account; and
- granting a consumer-requested credit-limit increase. GovInfo+1
If the alert requester supplied a verification telephone number, subsection (h)(1)(B)(ii) requires the user, before authorizing a covered new credit plan or extension described in clause (i), either to contact the consumer using that number or take reasonable identity-verification steps and confirm that the application for a new credit plan is not identity theft. That sentence does not separately repeat the additional-card and limit-increase phrases, although those branches remain subject to the baseline reasonable-belief requirement in clause (i). GovInfo
Replacement claim cell
| Field |
Corrected S_WI-P09-C023 content |
| Actor |
Prospective user of a consumer report containing an initial or active-duty alert |
| Covered actions |
New credit plan; non-open-end extension of credit; consumer-requested additional card; consumer-requested limit increase |
| Baseline standard |
Reasonable policies and procedures forming a reasonable belief that the user knows the requester’s identity |
| Specified-phone standard |
For the new-plan/extension language of clause (ii), contact the specified number or take reasonable verification steps and confirm the application is not identity theft |
| Open-end boundary |
New open-end account is covered as a new credit plan; an ordinary further extension under an existing open-end plan is not automatically within the general extension branch |
7. Replacement for S_WI-P09-C024
Extended alerts
Section 1681c-1(h)(2)(B) applies to a prospective user of either:
- a consumer report containing the extended alert; or
- a credit score generated using information in the file containing the extended alert.
Before taking the listed action, the user must contact the consumer:
- in person; or
- through the telephone number or other reasonable contact method designated in the alert,
to confirm that the new-credit-plan application, credit-limit-increase application, or additional-card request is not the result of identity theft. The operative prohibition also includes the statutory non-open-end extension-of-credit branch. GovInfo+1
| Field |
Corrected S_WI-P09-C024 content |
| Actor |
Prospective user of a consumer report or a credit score generated using the alerted file |
| Covered actions |
New credit plan; qualifying non-open-end extension; requested additional card; requested credit-limit increase |
| Verification |
In-person contact or the consumer-designated telephone/other reasonable contact method |
| Required confirmation |
The relevant application or request is not the result of identity theft |
| Limit |
The provision does not itself approve the credit, establish identity, or decide liability for fraud |
8. Correct extended-alert period starts
PASS-09 correctly identified the durations but must separate their triggering dates:
| Extended-alert consequence |
Start event |
Period |
| Alert in consumer’s file |
Date of the consumer’s or representative’s request |
7 years |
| Exclusion from covered prescreen lists |
Date of that request |
5 years |
| Window in which two free file disclosures may be requested |
Date the alert was included in the file |
12 months |
| CRA response after each qualifying free-file request |
Date of the individual request |
No later than 3 business days |
Replacement for S_WI-P09-C020: The two-free-file window does not necessarily begin on the same date as the seven-year and five-year periods if actual request and placement dates differ. GovInfo
PASS-09 Example 4’s anniversaries remain only illustrative references, not last-day determinations.
G3. Complete ordinary-freeze exception (B)
9. Replacement for PASS-09’s A–J matrix row (B)
The exact statutory clause is:
“Any Federal, State, or local agency, law enforcement agency, trial court, or private collection agency acting pursuant to a court order, warrant, or subpoena.”
That complete actor-and-action phrase must be preserved. GovInfo
Corrected matrix row
| Clause |
Correct actor/action predicate |
Qualification |
| §1681c-1(i)(4)(B) |
Federal, state, or local agency; law-enforcement agency; trial court; or private collection agency, within the full phrase ending “acting pursuant to a court order, warrant, or subpoena” |
This pass does not treat every listed public actor as having unconditional access to a frozen report |
The participial phrase appears after the final actor in a single statutory series. No separate authority read for this bounded correction resolves whether the court-order/warrant/subpoena modifier grammatically applies only to the private collection agency or to every listed actor. The safest exact treatment is therefore to preserve the clause as a unit and hold that narrower allocation question rather than assigning unconditional access to the governmental and court actors.
10. Replacement for S_WI-P09-C029 and coverage row 67
| Field |
Corrected content |
| Exception (A) |
Unchanged: qualifying existing-account, contract, instrument, agent, affiliate, assignee, or prospective-assignee review/collection branch |
| Exception (B) |
Use the full actor/action phrase quoted above; do not state that only the private collection agency is subject to the order/warrant/subpoena language |
| Exception (C) |
Unchanged: Title IV-D child-support agency |
| Exception (D) |
Keep separate: federal agency, state, agent, or assignee investigating fraud; investigating or collecting delinquent taxes or unpaid court orders; or fulfilling another statutory responsibility consistent with a permissible FCRA purpose |
| Consequence |
Neither (B) nor (D) is a blanket governmental-access exception |
Exception (D) has its own activity and permissible-purpose predicates and should not be used to cure uncertainty in exception (B). GovInfo
G4. Protected-consumer freeze removal and complete proof
11. Replacement for PASS-09 paragraph 18 and S_WI-P09-C037
Section 1681c-1(j)(4) contains three removal routes:
- direct request of the protected consumer’s representative;
- direct request of the protected consumer, if that person is not under 16 at the time of the request; or
- CRA removal because the freeze resulted from a material misrepresentation by the representative.
For the third branch, the CRA must give the representative written notice before removing the freeze. GovInfo
For either requester-driven route, subsection (j)(4)(C) states that the CRA must receive:
- a direct removal request;
- sufficient proof of identification; and
- sufficient proof of authority.
Only after those predicates are received does the free removal clock apply:
- one hour for a toll-free-telephone or secure-electronic request; or
- three business days for a mailed request. GovInfo
A request alone—without either required proof category—does not establish the statutory removal clock.
Corrected S_WI-P09-C037
| Field |
Corrected content |
| Eligible requester |
Protected consumer’s representative, or protected consumer who is not under 16 when requesting removal |
| Required proof |
Sufficient proof of identification and sufficient proof of authority |
| Electronic/telephone clock |
One hour after receipt of the qualifying direct request and both proof categories |
| Mail clock |
Three business days after receipt of the qualifying direct request and both proof categories |
| CRA-initiated removal |
Material misrepresentation by representative, with prior written notice |
| Temporary removal |
Specified period, following subsection (j)(4)(D)’s cross-reference to paragraph (C) |
| Limit |
No capacity, guardianship, parentage, or proof-sufficiency decision is made here |
12. Textual implementation hold for self-requesting protected consumers
The statutory text applies subsection (j)(4)(C)’s proof-of-authority phrase to both:
- the representative; and
- the age-eligible protected consumer requesting removal personally.
At the same time, subsection (j)(1)(F) defines “sufficient proof of authority” in terms of documentation showing that a representative has authority to act for the protected consumer. No authority freshly read here resolves how that representative-focused definition operates when the no-longer-under-16 protected consumer personally requests removal. The proof requirement should therefore not be silently waived, nor should an impossible proof demand be invented. That implementation question remains held. GovInfo+1
13. Temporary removal qualification
Subsection (j)(4)(D) states that, upon a direct request from a protected consumer or representative and a request for temporary removal, the CRA must remove the freeze for the period specified, in accordance with paragraph (C). The text also cross-references subparagraph (A)(i), although the sentence names both the protected consumer and the representative. This pass preserves that wording and does not rewrite the cross-reference. GovInfo
Ordinary versus protected-consumer proof
| Operation |
Ordinary freeze §1681c-1(i) |
Protected-consumer freeze §1681c-1(j) |
| Placement |
Proper identification |
Sufficient proof of identification and authority |
| Consumer-requested removal |
Proper identification |
Sufficient proof of identification and authority |
| Telephone/electronic removal |
One hour after qualifying receipt |
One hour after qualifying receipt including both proof categories |
| Mail removal |
Three business days |
Three business days after qualifying receipt including both proof categories |
PASS-09 Example 8’s calendar remains conditional on the request being complete with both proof categories. No actual request or deadline is determined.
Source register — S_WI-P12-S001 onward
All fresh accesses occurred October 26, 2026 Pacific / October 27, 2026 UTC. Exact resource-specific clock times are unknown. All five sources are HTML; printed-page and zero-based PDF-index fields are therefore N/A.
| Source ID |
Issuer / title / complete literal URL |
Exact pinpoint, edition, and status |
Actual read and limitation |
| S_WI-P12-S001 |
CFPB, Regulation V, 12 C.F.R. §1022.3 — Definitions. https://www.consumerfinance.gov/rules-policy/regulations/1022/3/ |
§1022.3(i)(1)(iii)(A)–(C), plus related report examples; current regulation |
Fresh current operative body read. Supports the staged report-acceptance clocks. Consumer Financial Protection Bureau |
| S_WI-P12-S002 |
U.S. Government Publishing Office, 15 U.S.C. §1681c-2 — Block of information resulting from identity theft. https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapIII-sec1681c-2.htm |
§1681c-2(a), (d)(2)–(3), (e); United States Code 2024 Edition |
Fresh official 2024 Edition body read. Used for reseller and check-services corrections; not represented as October 2026 consolidation. GovInfo |
| S_WI-P12-S003 |
U.S. Government Publishing Office, 15 U.S.C. §1681c-1 — Identity theft prevention; fraud alerts and active duty alerts. https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapIII-sec1681c-1.htm |
§1681c-1(b)(1)–(2), (h)(1)–(2), (i)(4)(B)–(D), (j)(1), (j)(4); references-in-text note; 2024 Edition |
Fresh official 2024 Edition body read. Used for alert, freeze-exception, and protected-removal qualifications; not current-2026 certification. GovInfo+3 |
| S_WI-P12-S004 |
U.S. House OLRC, 15 U.S.C. §1681a — Definitions; rules of construction. https://uscode.house.gov/us/usc/119-124/t15/s1681a/ |
§1681a(q)(5); text through Pub. L. 119-124, Oct. 15, 2026 |
Fresh official body read. Supplies “new credit plan” definition. Later /119-134/ edition was not retried. U.S. Code |
| S_WI-P12-S005 |
U.S. House OLRC, 15 U.S.C. §1602 — Definitions and rules of construction. https://uscode.house.gov/us/usc/119-124/t15/s1602/ |
§1602(j), open-end credit plan; text through Pub. L. 119-124, Oct. 15, 2026 |
Fresh official body read. The 2024 §1681c-1 reference note confirms former §1602(i) was redesignated §1602(j). U.S. Code+1 |
New source rows: 5.
Atomic claim register — S_WI-P12-C001 onward
| Claim ID |
A066 status |
Atomic corrected assertion |
Predicate / required act / consequence |
Source pinpoint |
Old P09 crosswalk / hold |
| S_WI-P12-C001 |
Open/not accepted |
Initial supplemental-information request must be made within 15 days after the later triggering event |
Later of report receipt or service request controls |
S001 §1022.3(i)(1)(iii)(A) |
Qualifies P09 C005 |
| C002 |
Open |
Supplemental requests and ordinary final acceptance decision occur within a second 15-day period after the initial request |
Second period begins from initial request |
S001 §1022.3(i)(1)(iii)(B) |
Qualifies P09 C005 |
| C003 |
Open |
Information received on day 11 or later of that second period triggers a five-day final-decision period |
Conditional receipt-triggered period, not automatic extension |
S001 §1022.3(i)(1)(iii)(C) |
Replaces “five additional days” wording |
| C004 |
Open |
Four-business-day block clock requires the complete §1681c-2 packet, including a qualifying identity-theft report |
Acceptance process and packet completeness precede block clock |
S001; S002 §1681c-2(a) |
Corrects P09 Example 2 |
| C005 |
Open |
Reseller-with-file branch requires CRA to be a reseller of identified information, not necessarily its original source |
Block maintained report; notify consumer and identify source CRAs |
S002 §1681c-2(d)(2)–(3) |
Corrects P09 C010/narrative |
| C006 |
Open |
Check-services prohibition begins four business days after receipt of subsection (a)(1)–(3) information |
No subsection (a)(4) trigger in special branch; no invented fifth-day rule |
S002 §1681c-2(e) |
Corrects actor-matrix phrase |
| C007 |
Open |
“New credit plan” includes a new open-end account and a new non-open-end credit transaction |
Ordinary further extensions under an existing open-end plan are separately treated |
S004 §1681a(q)(5); S005 §1602(j) |
Qualifies P09 C023/C024 |
| C008 |
Open |
Initial/active-alert report user must apply reasonable identity-belief procedures to each listed credit/card/limit branch |
Specific phone clause has its own narrower wording |
S003 §1681c-1(h)(1) |
Replaces P09 C023 |
| C009 |
Open |
Extended-alert restriction reaches prospective users of a report or score generated from the alerted file |
In-person or designated-method confirmation for covered action |
S003 §1681c-1(h)(2) |
Replaces P09 C024 |
| C010 |
Open |
Seven-year alert and five-year prescreen periods start on request; two-free-file 12-month window starts when alert is included in file |
Separate trigger dates must not be merged |
S003 §1681c-1(b)(1)–(2) |
Qualifies P09 C020 |
| C011 |
Open |
Freeze exception (B) must be preserved as its full actor/action phrase |
Modifier allocation not resolved; no unconditional access inferred |
S003 §1681c-1(i)(4)(B) |
Corrects P09 C029/coverage 67 |
| C012 |
Open |
Protected-freeze requester-driven removal requires direct request plus sufficient identification and authority proof |
One-hour/three-business-day clocks start only on qualifying complete receipt |
S003 §1681c-1(j)(4)(A)–(C) |
Replaces P09 C037 |
| C013 |
Open |
Protected temporary removal cross-references paragraph (C) and uses a specified period |
Statutory proof/cross-reference wording preserved; implementation tension held |
S003 §1681c-1(j)(4)(D) |
Qualifies P09 removal matrix/coverage 79 |
New atomic claims: 13.
Complete affected PASS-09 → PASS-12 crosswalk
| # |
Affected PASS-09 item |
Exact PASS-12 disposition |
New claims / sources |
Status |
| 1 |
Paragraph 3: “5 additional days” |
Replace with conditional receipt-triggered five-day decision period |
C001–C003 / S001 |
Corrected |
| 2 |
S_WI-P09-C005 |
Replace timing cell with linked A–C structure |
C001–C003 / S001 |
Corrected |
| 3 |
Complete-packet/block relationship |
Clarify acceptance/completeness before four-business-day clock |
C004 / S001–S002 |
Corrected |
| 4 |
Example 2 |
Replace automatic-extension implication |
C001–C004 |
Corrected |
| 5 |
Coverage row 6 |
Initial request within first 15 days |
C001 |
Corrected |
| 6 |
Coverage row 7 |
Second 15-day period |
C002 |
Corrected |
| 7 |
Coverage row 8 |
Conditional day-11-or-later five-day rule |
C003 |
Corrected |
| 8 |
Reseller narrative |
Replace “source” with “reseller of identified information” |
C005 / S002 |
Corrected |
| 9 |
S_WI-P09-C010 |
Preserve block and source-CRA notice, correct predicate |
C005 |
Corrected |
| 10 |
Check-services actor matrix |
“Beginning 4 business days after receipt” of (a)(1)–(3) |
C006 |
Corrected |
| 11 |
S_WI-P09-C011 |
Main narrative retained; matrix phrase corrected |
C006 |
Narrow correction |
| 12 |
Paragraph 11 extended alert |
Separate request-start periods from file-inclusion free-file period |
C010 / S003 |
Corrected |
| 13 |
S_WI-P09-C020 |
Add precise 12-month start event |
C010 |
Corrected |
| 14 |
Paragraph 13 user duties |
Add all credit branches and open-end definition |
C007–C009 / S003–S005 |
Corrected |
| 15 |
S_WI-P09-C023 |
Replace initial/active user-scope cell |
C007–C008 |
Corrected |
| 16 |
S_WI-P09-C024 |
Add report-or-score actor and exact contact standard |
C007, C009 |
Corrected |
| 17 |
Coverage row 52 |
Initial/active branches and two standards |
C007–C008 |
Corrected |
| 18 |
Coverage row 53 |
Extended report/score user and contact standard |
C009 |
Corrected |
| 19 |
Example 4 |
Anniversary references retained; trigger distinction added |
C010 |
Clarified, no recalculation |
| 20 |
A–J matrix exception B |
Replace conditional cell with complete statutory phrase |
C011 / S003 |
Corrected |
| 21 |
S_WI-P09-C029 |
Preserve A/C/D; qualify B and keep D separate |
C011 |
Corrected |
| 22 |
Coverage row 67 |
No unconditional access for all listed public actors |
C011 |
Corrected |
| 23 |
Paragraph 18 protected removal |
Add both proof categories and complete-receipt trigger |
C012–C013 / S003 |
Corrected |
| 24 |
S_WI-P09-C037 |
Replace requester/proof/clock cell |
C012–C013 |
Corrected |
| 25 |
Protected-removal comparison table |
Add authority proof for protected branch |
C012 |
Corrected |
| 26 |
Coverage row 78 |
Add requesters, proof, and statutory textual tension |
C012 |
Corrected |
| 27 |
Coverage row 79 |
Preserve specified-period temporary lift and paragraph (C) cross-reference |
C013 |
Corrected |
| 28 |
Example 8 |
Calendar retained only if direct request includes both proof categories |
C012–C013 |
Qualified |
| 29 |
Currentness provenance |
GPO 2024 bodies freshly read; no Oct. 20 replication claimed |
S002–S003 |
Preserved |
| 30 |
Original P09 sources/claims/coverage |
Remain historical; not re-rendered or recertified |
— |
Unchanged |
Crosswalk rows: 30.
Affected-example table
| PASS-09 example |
PASS-12 treatment |
Claim support |
| Example 2 — incomplete report |
Replace “additional five days” with the conditional day-11-or-later receipt rule; block clock follows complete accepted packet |
C001–C004 |
| Example 4 — initial versus extended alert |
Keep illustrative anniversaries; distinguish request-start seven/five-year periods from file-inclusion-start twelve-month free-file window |
C010 |
| Example 8 — protected consumer |
Keep modeled dates only if both sufficient identification and authority proof were received with the qualifying direct request |
C012–C013 |
Affected-example rows: 3.
Complete four-group correction coverage
| # |
Group / residual subissue |
Status |
Claims |
Evidence |
Remaining exact hold |
| 1 |
G1 first 15-day trigger |
Answered |
C001 |
S001 |
Actual receipt dates absent |
| 2 |
G1 second 15-day period |
Answered |
C002 |
S001 |
Exact counting convention held |
| 3 |
G1 day-11-or-later late receipt |
Answered |
C003 |
S001 |
Actual receipt evidence absent |
| 4 |
G1 automatic extra-five-day reading |
Corrected as unsupported |
C003 |
S001 |
No universal extension |
| 5 |
G1 report acceptance vs block packet |
Answered boundary |
C004 |
S001–S002 |
Actual completeness untested |
| 6 |
G1 reseller predicate |
Answered |
C005 |
S002(d)(2) |
Actual reseller role excluded |
| 7 |
G1 reseller source-CRA notice |
Answered |
C005 |
S002(d)(3) |
Actual source CRAs excluded |
| 8 |
G1 check-services start wording |
Answered |
C006 |
S002(e) |
Business-day definition still held |
| 9 |
G1 check-services packet elements |
Answered |
C006 |
S002(e) |
Subsection (a)(4) not imported |
| 10 |
G2 new-credit-plan definition |
Answered |
C007 |
S004(q)(5) |
Actual credit transaction excluded |
| 11 |
G2 open-end-plan definition |
Answered |
C007 |
S005(j) |
No broad TILA dossier |
| 12 |
G2 new open-end account |
Answered as covered new plan |
C007 |
S004–S005 |
Actual application excluded |
| 13 |
G2 further extension under existing open-end plan |
Answered as distinct branch |
C007–C008 |
S003(h)(1), S004 |
Separate card/limit branches remain |
| 14 |
G2 requested additional card |
Answered |
C008–C009 |
S003(h)(1)–(2) |
Actual request excluded |
| 15 |
G2 requested credit-limit increase |
Answered |
C008–C009 |
S003(h)(1)–(2) |
Actual request excluded |
| 16 |
G2 initial/active report user |
Answered |
C008 |
S003(h)(1) |
Score-only user not added |
| 17 |
G2 initial/active baseline verification |
Answered |
C008 |
S003(h)(1)(B)(i) |
Actual procedures excluded |
| 18 |
G2 specified-phone clause |
Answered with textual limit |
C008 |
S003(h)(1)(B)(ii) |
Card/limit phrases not separately repeated |
| 19 |
G2 extended report user |
Answered |
C009 |
S003(h)(2)(B) |
Actual report use excluded |
| 20 |
G2 extended credit-score user |
Answered |
C009 |
S003(h)(2)(B) |
Score must derive from alerted file |
| 21 |
G2 extended contact standard |
Answered |
C009 |
S003(h)(2) |
Actual confirmation excluded |
| 22 |
G2 seven-year alert trigger |
Answered |
C010 |
S003(b)(1)(A) |
Early removal possible |
| 23 |
G2 five-year prescreen trigger |
Answered |
C010 |
S003(b)(1)(B) |
Early rescission possible |
| 24 |
G2 twelve-month free-file trigger |
Answered |
C010 |
S003(b)(2)(A) |
Actual inclusion date excluded |
| 25 |
G3 full exception-B clause |
Answered textually |
C011 |
S003(i)(4)(B) |
Modifier scope unresolved |
| 26 |
G3 unconditional-government-access inference |
Rejected |
C011 |
S003(i)(4)(B) |
Specific actor/action facts needed |
| 27 |
G3 exception-D separation |
Answered |
C011 |
S003(i)(4)(D) |
Permissible-purpose/statutory-duty predicates |
| 28 |
G4 representative removal request |
Answered |
C012 |
S003(j)(4)(A)(i), (C) |
Actual proof excluded |
| 29 |
G4 age-eligible consumer request |
Answered textually |
C012 |
S003(j)(4)(A)(ii), (C) |
Authority-proof implementation held |
| 30 |
G4 misrepresentation removal |
Answered |
C012 |
S003(j)(4)(A)(iii), (B) |
Materiality factual |
| 31 |
G4 prior written notice |
Answered |
C012 |
S003(j)(4)(B) |
Actual delivery excluded |
| 32 |
G4 sufficient identification proof |
Answered |
C012 |
S003(j)(4)(C) |
Sufficiency factual |
| 33 |
G4 sufficient authority proof |
Answered textually |
C012 |
S003(j)(4)(C) |
Self-requester interaction unresolved |
| 34 |
G4 one-hour clock |
Answered conditionally |
C012 |
S003(j)(4)(C)(i) |
Complete receipt required |
| 35 |
G4 three-business-day mail clock |
Answered conditionally |
C012 |
S003(j)(4)(C)(ii) |
Business-day definition held |
| 36 |
G4 temporary removal period |
Answered |
C013 |
S003(j)(4)(D) |
Actual request excluded |
| 37 |
G4 paragraph-(C) cross-reference |
Answered |
C013 |
S003(j)(4)(D) |
Statutory drafting tension preserved |
| 38 |
Current §1022.3 regulation |
Fresh current body read |
C001–C004 |
S001 |
None for cited provisions |
| 39 |
Current §§1681c-1/c-2 replication |
Not performed |
— |
S002–S003 are 2024 Edition |
P09 researcher’s later access remains separate |
| 40 |
Wisconsin §100.54 |
Unresolved and untouched |
— |
Prior P09 hold |
Fresh state body required |
Correction-coverage rows: 40.
Retained deferred and currentness holds
| # |
Retained hold |
PASS-12 disposition |
| D1 |
Current Wisconsin §100.54 body and fee provisions |
Unchanged |
| D2 |
Federal/state preemption and Wisconsin remedies |
Unchanged |
| D3 |
Actual consumer, report, block, alert, freeze, guardian, or military facts |
Excluded |
| D4 |
Business-day definition under the FCRA |
Unresolved |
| D5 |
Specialty-CRA edge treatment |
Unchanged |
| D6 |
Full identity-theft criminal procedure and report validity |
Excluded |
| D7 |
Full CRA/furnisher dispute architecture |
Not rerun |
| D8 |
Debt validity, collection, litigation, and cancellation |
Not decided |
| D9 |
Private cause of action, standing, damages, limitations, and class relief |
Deferred |
| D10 |
Tribal, local, other-state, and foreign overlays |
Deferred |
| D11 |
Complete appellate/citator treatment |
Not performed |
| D12 |
Publication, operational approval, Wisconsin component, parent, or A066 acceptance |
Expressly withheld |
Deferred rows: 12.
Final audit and provenance reconciliation
| Audit item |
Result |
| Authorized correction groups |
4 of 4 |
| Fresh source rows |
5 |
| New atomic claims |
13 |
| Old-to-new crosswalk rows |
30 |
| Correction-coverage rows |
40 |
| Affected-example rows |
3 |
| Retained deferred rows |
12 |
| Original PASS-09 sources |
21 — preserved, not recertified |
| Original PASS-09 claims |
43 — preserved, only identified cells qualified |
| Original PASS-09 coverage rows |
117 — preserved, only identified rows qualified |
| Original PASS-09 workflows |
9 — only Examples 2, 4, and 8 affected |
Researcher self-check
Freshly read in this bounded correction:
- current CFPB Regulation V §1022.3(i)(1)(iii)(A)–(C);
- official GPO 2024 Edition §§1681c-1 and 1681c-2;
- OLRC §1681a(q)(5), compiled through October 15, 2026; and
- OLRC §1602(j), compiled through October 15, 2026.
The failed /119-134/ coordinator routes were not retried. Consequently, this pass does not claim fresh replication of P09’s reported October 20, 2026 OLRC access. The 2024 GPO bodies are competent official statutory publications but are not represented as the latest 2026 consolidation.
The previously checked modeled dates remain unchanged:
- November 2 → November 6 block model;
- November 6 → November 12 protected-freeze placement model when November 11 is excluded;
- November 12 → November 19 confirmation model;
- 14:00 → 15:00 temporary-lift model; and
- May 24, 2018 + 120 days → September 21, 2018.
They remain conditional illustrations, not actual deadlines.
No named consumer, protected consumer, representative, CRA, lender, score provider, collector, furnisher, government agency, court, report, account, military record, identity-theft report, or private document was searched. No form, freeze, alert, block, dispute, complaint, filing, contact, account action, purchase, publication, API, new chat, subagent, browser-control action, or local coordinator file occurred.
This is a bounded researcher correction, not independent review, all-source certification, individualized legal advice, operational approval, publication approval, or acceptance of Wisconsin PASS-09, PASS-12, A066, or the parent dossier.
END S_WI PASS-12