Wisconsin Statutes
Wis. Stat. § 423.201 (2026)
Definition
✓ current as of July 2026
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423.201(1)(1) “Consumer approval transaction” means a consumer transaction other than a sale or lease or listing for sale of real property or a sale of goods at auction that:
423.201(1)(a)(a) Is initiated by face-to-face solicitation away from a regular place of business of the merchant or by mail or telephone solicitation directed to the particular customer; and
423.201(1)(b)(b) Is consummated or in which the customer’s offer to contract or other writing evidencing the transaction is received by the merchant away from a regular place of business of the merchant and involves the extension of credit or is a cash transaction in which the amount the customer pays exceeds $25.
423.201(2)(2) “Consumer approval transaction” does not include a catalog sale that is not accompanied by any other solicitation or a consumer loan conducted and consummated entirely by mail.
423.201 AnnotationThis section does not restrict the ability of a merchant or seller to have more than one regular place of business. Reusch v. Roob, 2000 WI App. 76, 234 Wis. 2d 270, 610 N.W.2d 168, 98-3102.
Notes of Decisions
Cited in 6
cases (3 in the last 5 years), 1979–2026 · leading case: Reusch v. Roob, 2000 WI App 76 (Wis. Ct. App. 2000).
Reusch v. Roob, 2000 WI App 76 (Wis. Ct. App. 2000). “The trial court erred as a matter of law in *273 concluding: (1) that his relationship with the Reusches was a consumer approval transaction under Wis. Stat. § 423.201 (1997-98) 1 or a home solicitation under Wis.”
Wind Point Restoration, Inc. v. Anne Weikel (Wis. Ct. App. 2020). “§ 423.201(1)(a) consumer approval transaction with an associated WIS.”
Lietz (E.D. Wis. 2026). “Wis. Stat. §423.201 (1). The Wisconsin Court of Appeals has strictly construed this definition, stating that “it is essential that the solicitation or consummation of a sale must occur away from ‘a regular place of business,’” otherwise “the buyer is afforded no protection.”
Koble Investments v. Elicia Marquardt (Wis. Ct. App. 2024). “§ 423.201(1), in turn, states that a “[c]onsumer approval transaction” means “a consumer transaction other than a sale or lease … of real property.”
Bechstein v. Brandenburger & Davis, 474 F. Supp. 971 (E.D. Wis. 1979). “Section 423.201 defines three essential elements for an agreement to fall into the category of a “consumer approval transaction”: (1) the agreement must be “initiated by face-to-face solicitation away from a regular place of business of the merchant or by mail or telephone…”
Michelle Lynn McNeil v. Carvana, LLC (Wis. Ct. App. 2025). “§ 423.201(1)(a)); 15 U.S.C. § 1635 (a) (allowing rescission when a consumer gives a security interest “in any property which is used as the principal dwelling of the person to whom credit is extended”).”
— Wis. Stat. § 423.201(1) — 1 case
Koble Investments v. Elicia Marquardt (Wis. Ct. App. 2024). “§ 423.201(1), in turn, states that a “[c]onsumer approval transaction” means “a consumer transaction other than a sale or lease … of real property.”
— Wis. Stat. § 423.201(1)(a) — 2 cases
Wind Point Restoration, Inc. v. Anne Weikel (Wis. Ct. App. 2020). “§ 423.201(1)(a) consumer approval transaction with an associated WIS.”
Michelle Lynn McNeil v. Carvana, LLC (Wis. Ct. App. 2025). “§ 423.201(1)(a)); 15 U.S.C. § 1635 (a) (allowing rescission when a consumer gives a security interest “in any property which is used as the principal dwelling of the person to whom credit is extended”).”
— Wis. Stat. § 423.201(1)(b) — 1 case
Wind Point Restoration, Inc. v. Anne Weikel (Wis. Ct. App. 2020). “§ 423.201(1)(a) consumer approval transaction with an associated WIS.”
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