Global Mapping and Document Updates: Wisconsin Consumer Act Indicator (FI 194780)

The Wisconsin Consumer Act establishes requirements and consumer protections for certain credit transactions made primarily for personal, family, or household purposes, including requirements related to fees, late charges, default remedies, and loan documentation. Several updates have been made in ConformX to provide additional support for loans that may be subject to the Wisconsin Consumer Act.

Wisconsin Consumer Act Indicator

New Wisconsin Consumer Act Indicator (FI 194780) is now available for use in ConformX. When the field is not set, it will default to "Yes" for Wisconsin loans that:

• Have a loan amount of $25,000 or less;
• Are not secured by a first lien; and
• Are secured by a primary residence or second home.

The indicator defaults to "No" otherwise.

Under Wis. Stat. § 421.202(6), consumer credit transactions with an amount financed exceeding $25,000 are currently excluded from Wis. Stat. chs. 421-427. The $25,000 threshold is scheduled to increase to $50,000 effective January 1, 2027, pursuant to 2025 Wis. Act 105.

Transactions secured by a first-lien real estate mortgage or equivalent security interest are also excluded under Wis. Stat. § 421.202(7).

Under Wis. Stat. § 421.301(17), the Wisconsin Consumer Act generally applies to transactions in which a customer seeks or acquires property, services, money, or credit for personal, family, or household purposes. Because loans secured by investment properties are generally associated with an investment or business purpose rather than a personal, family, or household purpose, the indicator defaults to "No" for investment properties.

The primary residence and second home occupancy conditions are intended to broadly identify transactions that may be subject to the Wisconsin Consumer Act. These criteria may not be fully determinative of whether the Act applies to a particular transaction. Clients may provide or override the Wisconsin Consumer Act Indicator as appropriate for their specific needs.

Second Lien Closed-End Late Charge Defaults

Under Wis. Stat. § 422.203(1), the delinquency charge for a consumer credit transaction other than an open-end credit plan is limited to the lesser of $10 or 5% of the unpaid installment.

The ConformX Late Charge Defaults have been updated to apply a maximum late charge of $10 for Wisconsin closed-end, junior lien loans when the Wisconsin Consumer Act Indicator is set to "Yes".

Second Lien Closed-End Document Updates

The following documents have been updated to include applicable Wisconsin Consumer Act language when the Wisconsin Consumer Act Indicator is set to "Yes":

• WI Mortgage Second (Cx515)
• Fixed Rate Note Wisconsin Second (Cx1080)

The updated provisions address notices and cure rights before acceleration, lender remedies, collection costs, attorneys' fees, and other amounts recoverable from the borrower.

No Update to HELOC Late Charge Defaults or Documents

While the Wisconsin Consumer Act Indicator may be set to "Yes" for HELOCs, the limitation under Wis. Stat. § 422.203(1) does not apply to open-end credit plans. Wis. Stat. § 422.202(2m)(a) separately permits agreed-upon fees and charges, including late payment charges, for open-end credit plans. Therefore, no changes have been made to ConformX Late Charge Defaults or documents for HELOCs.

The ConformX Late Fee Matrix has been updated to reflect the support of the Wisconsin Consumer Act.

These changes are available for testing on Stage & Stage 2 servers and will take effect on September 17, 2026. If you have any questions or concerns, please contact Client Support at 1.800.497.3584.

COM-7618
T3S-29117
DR-230901

The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third-party should consult with an attorney prior to embarking upon any specific course of action.