Wis. Stat. » CHAPTER 425 — CONSUMER TRANSACTIONS — REMEDIES AND PENALTIES
Wisconsin Statutes

Wis. Stat. § 425.210 (2026)

Computation of deficiency

✓ current as of July 2026
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425.210425.210 Computation of deficiency. If the creditor is entitled to a deficiency judgment pursuant to s. 425.209 (1), the creditor shall be entitled to recover from the customer the deficiency, if any, remaining after deducting the fair market value of the collateral from the unpaid balance.
425.210 HistoryHistory: 1971 c. 239.
Notes of Decisions
Cited in 6 cases (4 in the last 5 years), 1984–2025 · leading case: Kett v. Cmty. Credit Plan, Inc., 586 N.W.2d 68 (Wis. Ct. App. 1998).
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Kett v. Cmty. Credit Plan, Inc., 586 N.W.2d 68 (Wis. Ct. App. 1998). · cites it 2× “See § 425.210, Stats. The Waukesha County Circuit Court granted summary judgment to Community Credit on the customers' claims and ordered trial on Community Credit's defi *123 ciency judgment claim.”
Daniel Birge v. Simplicity Credit Union (Wis. Ct. App. 2025). · cites it 40× “§ 425.210, a provision of the Wisconsin Consumer Act (WCA).”
First Wisconsin Nat'l Bank v. Wilson, 360 N.W.2d 548 (Wis. Ct. App. 1984). · cites it 3× “Because the trial court did not determine the fair market value of the automobile as required by sec. 425.210, Stats., we reverse the judgment and remand the matter to the trial court with directions.”
Hanson, Randy v. Santander Consum. USA, Inc. (W.D. Wis. 2025). · cites it 13× “2 Although relief is sought under the Wisconsin UCC, these causes of action all rely in part on plaintiffs’ contention that Wisconsin Consumer Act, specifically Wis. Stat. § 425.210 , modifies creditors’ obligations.”
Valerie Kennedy v. Ripco Credit Union (Wis. Ct. App. 2021). “§ 425.210 she is entitled to a “declaratory” judgment determining the fair market value of the loan collateral sold.”
Creative Fin., Inc. v. Carlos Rangel (Wis. Ct. App. 2025). “§ 425.210. However, the WCA imposes certain restrictions on a creditor’s action to recover a deficiency.”
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