Wisconsin Statutes
Wis. Stat. § 427.103 (2026)
Definitions: “claim”; “debt collection”; “debt collector”
✓ current as of July 2026
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427.103(1)(1) “Claim” means any obligation or alleged obligation arising from a consumer transaction, including a transaction that is primarily for an agricultural purpose.
427.103(2)(2) “Debt collection” means any action, conduct or practice of soliciting claims for collection or in the collection of claims owed or due or alleged to be owed or due a merchant by a customer.
427.103(3)(3) “Debt collector” means any person engaging, directly or indirectly, in debt collection, and includes any person who sells, or offers to sell, forms represented to be a collection system, device or scheme, intended or calculated to be used to collect claims. The term does not include a printing company engaging in the printing and sale of forms.
427.103 AnnotationIn this case, the landlord acted as a “debt collector,” as defined in sub. (3), and violated s. 427.104 (1) (j) when the landlord served an eviction notice on the tenant during a declared eviction moratorium. Koble Investments v. Marquardt, 2024 WI App 26, 412 Wis. 2d 1, 7 N.W.3d 915, 22-0182.
Notes of Decisions
Cited in 11
cases (3 in the last 5 years), 1996–2026 · leading case: Timothy Parent v. Home Depot U.S.A., 694 F.3d 919 (7th Cir. 2012).
Timothy Parent v. Home Depot U.S.A., 694 F.3d 919 (7th Cir. 2012). “” Wis. Stat. § 427.103 (2). Similarly, the Act defines debt collector as “any person engaging, directly or indirectly, in debt collection, and includes any person who sells, or offers to sell, forms represented to be a collection system, device or scheme, intended or calculated…”
Hartman v. Meridian Fin. Servs., Inc., 191 F. Supp. 2d 1031 (W.D. Wis. 2002). “” Wis. Stat. § 427.103 (2). As it did with respect to the FDCPA allegations, defendant argues that it is not a “debt collector” because it was performing in-house billing services and was collecting debt that was not in default.”
Gable v. Universal Acceptance Corp., 338 F. Supp. 3d 943 (E.D. Wis. 2018). “" Wis. Stat. § 427.103 (3). Unlike the FDCPA, the WCA includes within its coverage merchants engaged in collecting their own debts, as well as collectors of debts owed third parties.”
Myers v. Americollect Inc., 194 F. Supp. 3d 839 (E.D. Wis. 2016). “” Wis. Stat. § 427.103 (2). “Merchant” includes “a person who regularly advertises, distributes, offers, supplies or deals in .”
Zehetner v. Chrysler Fin. Co., LLC., 2004 WI App 80 (Wis. Ct. App. 2004). “See Wis. Stat. § 427.103 (2) (" 'Debt collection' means any action, conduct or practice .”
Patzka v. Viterbo Coll., 917 F. Supp. 654 (W.D. Wis. 1996). “It is undisputed that Viterbo College is a “debt collector” under Wis.Stat. § 427.103, which defines debt collector as “any person engaging, directly or indirectly, in debt col-lection_” (Emphasis added.”
Kett v. Cmty. Credit Plan, Inc., 586 N.W.2d 68 (Wis. Ct. App. 1998). “Because Community Credit was not attempting to collect an "obligation arising from a consumer transaction," §427.103(1), Stats, (defining "claim," "debt collection" and "debt collector"), the debt collection prohibitions do not apply to it.”
Nelson v. Santander Consum. USA, Inc., 931 F. Supp. 2d 919 (W.D. Wis. 2013). “” Wis. Stat. § 427.103 (2). Because plaintiff does not explain how simply entering into a loan agreement could qualify as an attempt to collect a debt under these circumstances, I am denying her summary judgment motion as to this claim as well.”
Jeanne Fransway v. Markquart Auto. Inc. (Wis. Ct. App. 2021). “§ 427.103(3). “Debt collection,” in turn, means “any action, conduct or practice of soliciting claims for collection or in the collection of claims owed or due or alleged to be owed or due a merchant by a customer.”
Koble Investments v. Elicia Marquardt (Wis. Ct. App. 2024). “§ 427.103(3). “Debt collection,” in turn, means “any action, conduct or practice of soliciting claims for collection or in the collection of claims owed or due or alleged to be owed or due a merchant by a customer.”
Desjurdin Lacey v. Credit Acceptance Co. (Wis. Ct. App. 2026). “§ 427.103(2) (“‘Debt collection’ means any action, conduct or practice of soliciting claims for collection or in the collection of claims owed or due or alleged to be owed or due a merchant by a customer.”
— Wis. Stat. § 427.103(1) — 1 case
Kett v. Cmty. Credit Plan, Inc., 586 N.W.2d 68 (Wis. Ct. App. 1998). “Because Community Credit was not attempting to collect an "obligation arising from a consumer transaction," §427.103(1), Stats, (defining "claim," "debt collection" and "debt collector"), the debt collection prohibitions do not apply to it.”
— Wis. Stat. § 427.103(2) — 1 case
Desjurdin Lacey v. Credit Acceptance Co. (Wis. Ct. App. 2026). “§ 427.103(2) (“‘Debt collection’ means any action, conduct or practice of soliciting claims for collection or in the collection of claims owed or due or alleged to be owed or due a merchant by a customer.”
— Wis. Stat. § 427.103(3) — 3 cases
Hartman v. Meridian Fin. Servs., Inc., 191 F. Supp. 2d 1031 (W.D. Wis. 2002). “” Wis. Stat. § 427.103 (2). As it did with respect to the FDCPA allegations, defendant argues that it is not a “debt collector” because it was performing in-house billing services and was collecting debt that was not in default.”
Jeanne Fransway v. Markquart Auto. Inc. (Wis. Ct. App. 2021). “§ 427.103(3). “Debt collection,” in turn, means “any action, conduct or practice of soliciting claims for collection or in the collection of claims owed or due or alleged to be owed or due a merchant by a customer.”
Koble Investments v. Elicia Marquardt (Wis. Ct. App. 2024). “§ 427.103(3). “Debt collection,” in turn, means “any action, conduct or practice of soliciting claims for collection or in the collection of claims owed or due or alleged to be owed or due a merchant by a customer.”
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