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Executive Letter: WCA Law Change

From the Desk of Rose Oswald Poels

By Rose Oswald Poels

A law was passed this session which increased the threshold of transactions subject to the Wisconsin Consumer Act (WCA). Previously, covered consumer credit transactions were those for which the amount financed was $25,000 or less. As of January 1, 2027, that amount will increase to $50,000.

2025 Wisconsin Act 105 (Act) expands the dollar thresholds that govern both consumer credit coverage and access to small claims court. The Act amends Wis. Stat. section 421.202(6), which increases the dollar limit threshold used to determine whether certain consumer credit transactions are covered by the WCA from $25,000 to $50,000. Meaning, consumer credit transactions with an amount financed over $50,000, motor vehicle consumer leases with total lease obligations exceeding $50,000, and other consumer transactions with a cash price above $50,000 are excluded.

This law change will result in more transactions being subject to the WCA based upon the amount of the transaction. Banks will need to review and update lending policy and procedures to ensure proper compliance. FIPCO will update its software accordingly as well.

The Act also expands the jurisdictional limits of Wisconsin small claims court. The general small claims monetary cap increases from $10,000 to $15,000. Additionally, the maximum value of property eligible for replevin actions in small claims court increases from $10,000 to $15,000. This threshold increases the range of actions which may be pursued through small claims procedures and recovery of personal property collateral for higher-value replevin actions.

The Act was enacted on March 20, 2026, and takes effect on January 1, 2027.

In addition to the changes made by Act 105, this session brought changes to tax incremental financing, environmental programs, business development credits, vehicle regulation, agricultural compliance, and land development procedures. These additional changes may potentially indirectly influence lending policy, collateral evaluation, customer advisory practices, and financial product opportunities across the state. More information on these changes may be found in the March 2026 WBA Compliance Journal.

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