Nebraska — Collection Agency Act (Neb. Rev. Stat. ch. 45) + SOL

Authority

Nebraska regulates debt collection almost entirely as an entry-gate licensing matter, not a conduct matter. The Collection Agency Act, Neb. Rev. Stat. §§45-601 to 45-623, requires a license issued by the Collection Agency Licensing Board, whose chairperson and administrator is the Secretary of State (§45-603). The Board's rules are 433 Neb. Admin. Code ch. 2 ("Collection Agency Licensing," effective 2021-11-01). There is no Nebraska mini-FDCPA: the Act contains no prohibited-practices sections, no call-frequency cap, no call-time window, and no time-barred-debt disclosure. Conduct is policed by the federal FDCPA plus the general Consumer Protection Act, Neb. Rev. Stat. §§59-1601 et seq. (Attorney General enforcement and a private action).

Statute of limitations for suit on a debt: §25-205 (written, 5 years), §25-206 (not in writing, 4 years), Neb. U.C.C. §3-118 (negotiable notes, 6 years). Revival/tolling on payment or written acknowledgment: §25-216. Borrowing statute: the Uniform Conflict of Laws Limitations Act, §§25-3201 to 25-3207.

Verification note. nebraskalegislature.gov (the Legislature's own publisher, including the Revisor of Statutes' annotations) fetches cleanly to an ordinary browser request and is the source for all statute text below. The Nebraska UCC is published on a separate path from the Revised Statutes — /laws/ucc.php?code=3-118; the Revised-Statutes path statutes.php?statute=3-118 returns Chapter 3 (Aeronautics), an easy and dangerous mis-cite. The regulations site rules.nebraska.gov is a JavaScript SPA whose PDF paths under the old nebraska.gov/rules-and-regs/regsearch/... now 301 to the SPA root; its official JSON API is open and unauthenticated — /api/title lists titles (Title 433 = id 201), /api/chapter/GetByTitleId/<titleId> lists chapters (ch. 2 = id 1534), and /api/chapter/<id> returns the full rule text in a chapterHtml field. Rule text below came from that endpoint.

Operative text

Entry gate — §45-601 (license required; per-day misdemeanor)

Sections 45-601 to 45-622 shall be known and may be cited as the Collection Agency Act.

No person, firm, corporation, or association shall conduct or operate a collection agency or do a collection agency business as defined in the act until he, she, or it has secured a license as provided in the act. Any person, firm, corporation, or association conducting or operating such a collection agency or doing such a collection agency business without a license shall be guilty of a Class III misdemeanor for each day that such unlawful business is conducted. Any officer or agent of a firm, corporation, or association who personally participates in any violation of the act shall be guilty of a Class III misdemeanor.

Nothing contained in this section shall be construed to require a regular employee of a collection agency duly licensed as such in this state to procure a collection agency license.

Nothing in the act shall be construed to prohibit a person, firm, corporation, or association regulated as a collection agency in another state and residing in another state from communicating with a debtor in this state. — Neb. Rev. Stat. §45-601 (Laws 1963, c. 500, §1; last amended Laws 2020, LB909, §25)

Scope — §45-602 (who is a "collection agency"; debt buyers and first-party creditors are excluded)

(2) Collection agency means and includes:

(a) All persons, firms, corporations, and associations directly or indirectly engaged in soliciting, from more than one person, firm, corporation, or association, claims of any kind owed or due or asserted to be owed or due such solicited person, firm, corporation, or association, and all persons, firms, corporations, and associations directly or indirectly engaged in asserting, enforcing, or prosecuting such claims;

(b) Any person, firm, corporation, or association which, in attempting to collect or in collecting his, her, or its own accounts or claims, uses a fictitious name or any name other than his, her, or its own name which would indicate to the debtor that a third person is collecting or attempting to collect such account or claim; and

(c) Any person, firm, corporation, or association which attempts to or does give away or sell to any person, firm, corporation, or association, other than one licensed under the act, any system or series of letters or forms for use in the collection of accounts or claims which assert or indicate, directly or indirectly, that the claim or account is being asserted or collected by any other person, firm, corporation, or association other than the creditor or owner of the claim or demand;

(3) Collection agency does not mean or include (a) regular employees of a single creditor, (b) banks, (c) trust companies, (d) savings and loan associations, (e) building and loan associations, (f) abstract companies doing an escrow business, (g) duly licensed real estate brokers and agents … (h) express and telegraph companies subject to public regulation and supervision, (i) attorneys at law handling claims and collections in their own names and not operating a collection agency under the management of a layperson, (j) any person, firm, corporation, or association handling claims, accounts, or collections under an order or orders of any court, or (k) a person, firm, corporation, or association which, for valuable consideration, purchases accounts, claims, or demands of another and then, in such purchaser's own name, proceeds to assert or collect such accounts, claims, or demands; and — Neb. Rev. Stat. §45-602 (last amended Laws 2020, LB909, §26) (bold added)

Licensee qualifications — §45-607 (Nebraska residency / in-state office)

(1) The license provided for by section 45-606 shall be granted only to applicants who are trustworthy, who have a good reputation for honesty and fair dealings, who are financially responsible, and who are, in the opinion of the board, competent to engage in the collection of accounts and claims of others. No license shall be issued to a partnership, limited liability company, corporation, or association unless the manager or executive officer thereof has been engaged in the collection business either as owner, officer, partner, member, or employee of an established reputable collection agency for a period of at least two years, except that the board may, if satisfied that the applicant or the manager or executive officer thereof has had sufficient business experience to be fully competent to engage in the collection business without such previous collection experience, approve such application.

(2) No such license shall be issued to any person, firm, limited liability company, corporation, or association who or which is not a resident of this state or does not keep and maintain a regular office in this state in which are kept complete records of collections and claims handled … except that a foreign corporation or limited liability company duly authorized, admitted, and licensed to do business in this state may be issued such a license if it complies with all requirements of the Collection Agency Act, nor shall any license be issued to any person … who or which or the principal officers of which have, within the past five years, been convicted in any court of fraud or have been convicted of or had judgment entered against them in any court for failure to account to their client or customer for money or property collected by them for such client or customer. — Neb. Rev. Stat. §45-607

Bond — §45-608 (tiered by solicitor headcount; 45-day remittance condition)

No license shall be issued under section 45-607 until the applicant has furnished a good and sufficient corporate surety bond in the sum of fifteen thousand dollars for those agencies or foreign corporations having sixteen or more licensed solicitors, ten thousand dollars for any agency having five to fifteen licensed solicitors, and five thousand dollars for any agency having less than five solicitors, payable to and approved by the board and conditioned that the licensee shall faithfully and truly perform all agreements entered into with the licensee's clients or customers and shall, within forty-five days after the close of each calendar month, report to and pay to his, her, or its client or customer the net proceeds of all collections made during the preceding calendar month and due to each client or customer, which bond shall be in such form as approved by the board and shall be filed in the office of the Secretary of State. No person shall be required to post a bond in excess of one hundred thousand dollars.

An action may be brought in any court of competent jurisdiction upon such bond by any person to whom the licensee fails to account and pay as set forth in such bond or who has been damaged by failure of the licensee to comply with all agreements entered into with such person, except that the aggregate liability of the surety to all such persons shall, in no event, exceed the sum of such bond. — Neb. Rev. Stat. §45-608 (bold added)

Fees — §45-620 (statutory caps) and 433 NAC ch. 2, §012 (amounts actually charged)

No license, renewal of license, branch office certificate, or solicitor's certificate … shall be issued by the board until any processing fee allowed under section 45-605.01 has been paid and the following fees have been paid to the Secretary of State: For a license, not to exceed two hundred dollars; for renewal of a license, not to exceed one hundred dollars; for a branch office certificate, not to exceed fifty dollars; for renewal of a branch office certificate, not to exceed thirty-five dollars; for a solicitor's certificate and for renewal of a solicitor's certificate, not to exceed ten dollars. — Neb. Rev. Stat. §45-620

012.01 In addition to the fees charged by the Registry, license fees payable to the Board are as follows: 012.01A Collection Agency License Fee---$200.00 012.01B Collection Agency License Investigation Fee--$200.00 012.01C Collection Agency Annual Renewal Fee--$75.00 012.01D Branch Office Certificate Initial--$50.00 012.01E Branch Office Certificate Renewal--$35.00 012.01F Solicitor's Certificate (new or renewal)--$1.00 … 012.03A For those agencies having sixteen or more solicitors --$15,000 012.03B For those agencies having five to fifteen solicitors--$10,000 012.03C For those agencies having less than five solicitors--$5,000 — 433 Neb. Admin. Code ch. 2, §012

Applications and renewals run through NMLS (the "Registry"), which the Act defines and the rules require:

003.01 Each application to be considered by the Board will be submitted through the Registry. — 433 Neb. Admin. Code ch. 2, §003.01

Renewal — §45-611 / 433 NAC ch. 2, §006 (Dec. 31 hard deadline)

(1) All licenses and certificates issued under the Collection Agency Act shall expire on December 31 following the date of issuance unless renewed as provided in this section prior to such date. … — Neb. Rev. Stat. §45-611

006.02 Every renewal application received by the Board after the December 31 deadline will be considered as an initial license application. Such application will not be considered until the proper application and investigation fees have been paid. — 433 Neb. Admin. Code ch. 2, §006.02 (bold added)

Records retention — 433 NAC ch. 2, §007.04 (2 years, itemized allocation)

007.04 Licensees will maintain a record of all collection payments for two (2) years following the date the payment was received. Records of collection payments will include the consumer's or business's name, the client's name, the amounts paid, the dates on which payments were received, the allocation of each payment to, as applicable, principal interest, court costs, attorney fees, other costs, the interest rate, the current balance due, and the date of deposit of the collection payment to the applicable bank account. — 433 Neb. Admin. Code ch. 2, §007.04 (bold added)

The only "conduct" rule in the Nebraska scheme — 433 NAC ch. 2, §008

008 FAIR DEBT COLLECTION PRACTICES ACT 008.01 The Board will inform each applicant for a collection agency license of the existence of Federal Fair Debt Collection Practices Act. (15 U.S.C. sec. 1692 et. seq.) and will inform each applicant how they can acquire a copy of the Federal Act. — 433 Neb. Admin. Code ch. 2, §008

The Nebraska Attorney General's consumer site says the same thing — the federal Act governs, and the only Nebraska-specific obligation is licensure:

In Nebraska, debt collectors are required to register with the Secretary of State before doing business as a collection agency. See Neb. Rev. Stat. § 45-601 et seq.

The FDCPA generally governs how debt collectors may legally attempt to collect debts both nationally and in Nebraska. — Nebraska Attorney General, "Debt Collection," protectthegoodlife.nebraska.gov/debt-collection

Revocation grounds — §45-612 and 433 NAC ch. 2, §010

Upon final conviction of any licensee or solicitor by any court in Nebraska of fraud or embezzlement or upon final judgment against such licensee or solicitor in any court in Nebraska for fraud or embezzlement or for failure to account to his, her, or its client or customer within the time provided for in section 45-608 or upon the termination of the bond furnished by the licensee under such section without another sufficient bond being substituted therefor, the board shall forthwith revoke such license … Such license shall also be revoked by the board at any time a licensee fails to maintain a regular office in this state … or at any time the licensee becomes a nonresident of this state … — Neb. Rev. Stat. §45-612

Public-debt collection — §45-623 (30-day pre-assignment notice)

(2) No debt owed pursuant to subsection (1) of this section may be assigned to a collection agency unless (a) there has been an attempt to advise the debtor by first-class mail, postage prepaid, at the last-known address of the debtor (i) of the existence of the debt and (ii) that the debt may be assigned to a collection agency for collection if the debt is not paid and (b) at least thirty days have elapsed from the time the notice was sent …

(3) A collection agency which is assigned a debt under this section shall have only those remedies and powers which would be available to it as an assignee of a private creditor. … — Neb. Rev. Stat. §45-623 (bold added)

Statute of limitations — written contracts, §25-205 (5 years)

(1) Except as provided in subsection (2) of this section, an action upon a specialty, or any agreement, contract, or promise in writing, or foreign judgment, can only be brought within five years. … — Neb. Rev. Stat. §25-205(1) (last amended Laws 1999, LB 550, §3) (bold added)

Statute of limitations — contracts not in writing, §25-206 (4 years)

An action upon a contract, not in writing, expressed or implied, or an action upon a liability created by statute, other than a forfeiture or penalty, can only be brought within four years. — Neb. Rev. Stat. §25-206 (R.S.1943, §25-206) (bold added)

Nebraska has no separate "open account" limitations section. The 4-year period reaches open and mutual accounts through §25-206's "contract, not in writing, expressed or implied," and the last-item accrual rule is annotation authority rather than statutory text. From the Revisor of Statutes' official annotations to §25-206:

Action on commission account was barred four years from last item. In re Automatic Equipment Mfg. Co., 103 F.Supp. 427 (D. Neb. 1952).

Statute runs from the date of an account stated, and not from incurring of original debt. In re Estate of Black, 125 Neb. 75, 249 N.W. 84 (1933).

The 4-year statute of limitations for oral contracts provided in this section applies where, although there is a written contract between the parties, parol evidence is necessary in order to establish the terms of the agreement; in other words, the statute of limitations in this section, rather than that provided by section 25-205, applies where a contract is partly oral and partly written. Aurora Technology v. Labedz, 30 Neb. App. 33, 964 N.W.2d 474 (2021). — Revisor's annotations to Neb. Rev. Stat. §25-206

Relevant to the card fight, Nebraska's credit-agreement statute of frauds carves credit cards out of the writing-and-signature requirement:

(1) A debtor or a creditor may not maintain an action or assert a defense in an action based on a credit agreement unless the credit agreement is in writing, expresses consideration, sets forth the relevant terms and conditions of the credit agreement, and is signed by the creditor and by the debtor.

(2) Subsection (1) of this section shall not apply to (a) credit extended on an account as defined in section 4-104, Uniform Commercial Code, (b) loans initiated by credit card or other type of transaction card, or (c) credit agreements as defined in subdivision (1)(a)(ii) of section 45-1,112 … — Neb. Rev. Stat. §45-1,113 (bold added)

Statute of limitations — negotiable notes, Neb. U.C.C. §3-118 (6 years, not 5)

Nebraska enacted Revised UCC Article 3, so a negotiable note runs six years and §25-205's general 5-year written-contract period does not govern it:

(a) Except as provided in subsection (e), an action to enforce the obligation of a party to pay a note payable at a definite time must be commenced within six years after the due date or dates stated in the note or, if a due date is accelerated, within six years after the accelerated due date.

(b) Except as provided in subsection (d) or (e), if demand for payment is made to the maker of a note payable on demand, an action to enforce the obligation of a party to pay the note must be commenced within six years after the demand. If no demand for payment is made to the maker, an action to enforce the note is barred if neither principal nor interest on the note has been paid for a continuous period of ten years.

(c) Except as provided in subsection (d), an action to enforce the obligation of a party to an unaccepted draft to pay the draft must be commenced within three years after dishonor of the draft or ten years after the date of the draft, whichever period expires first.

(d) An action to enforce the obligation of the acceptor of a certified check or the issuer of a teller's check, cashier's check, or traveler's check must be commenced within three years after demand for payment is made to the acceptor or issuer, as the case may be.

(e) Subject to the provisions of section 25-227, an action to enforce the obligation of a party to a certificate of deposit to pay the instrument must be commenced within six years after demand for payment is made to the maker …

(g) Unless governed by other law regarding claims for indemnity or contribution, an action (i) for conversion of an instrument, for money had and received, or like action based on conversion, (ii) for breach of warranty, or (iii) to enforce an obligation, duty, or right arising under this article and not governed by this section must be commenced within three years after the cause of action accrues. — Neb. U.C.C. §3-118 (Laws 1991, LB 161, §22; Laws 2008, LB151, §2) (bold added)

Catch-all — §25-212 (4 years)

An action for relief not otherwise provided for in Chapter 25 can only be brought within four years after the cause of action shall have accrued. — Neb. Rev. Stat. §25-212

Revival and tolling — §25-216 (part payment or written acknowledgment)

In any cause founded on contract, when any part of the principal or interest shall have been voluntarily paid, or an acknowledgment of an existing liability, debt or claim, or any promise to pay the same shall have been made in writing, an action may be brought in such case within the period prescribed for the same, after such payment, acknowledgment or promise; Provided, that the provisions of this section shall not be applicable to real estate mortgages which have become barred under the provisions of section 25-202 as against subsequent encumbrancers and purchasers for value. — Neb. Rev. Stat. §25-216 (R.S.1943, §25-216)

The Revisor's annotations resolve both of the questions the text leaves open — that a payment need not be in writing, and that a payment can revive an already-barred debt:

Voluntary part payment will toll statute of limitations, or will revive debt, if same is barred. Blair v. Willman Estate, 105 Neb. 735, 181 N.W. 615 (1921).

Part payment operates to revive a contract debt of its own vigor and not as evidence of an acknowledgment or new promise. Ebersole v. Omaha National Bank, 71 Neb. 778, 99 N.W. 664 (1904).

Part payment of a debt does not have the effect of tolling the statute of limitations, unless payment is made under circumstances which justify the inference that the debtor recognizes the whole debt as an existing liability. T.S. McShane Co., Inc. v. Dominion Constr. Co., 203 Neb. 318, 278 N.W.2d 596 (1979).

Payment to remove bar of statute must be voluntary and not obtained by subterfuge. Kyger v. Ryley, 2 Neb. 20 (1873).

Voluntary payment is one that was intentionally and consciously made and accepted. Beacom v. Daley, 164 Neb. 120, 81 N.W.2d 907 (1957).

A promise to pay a debt or other existing liability in a cause founded on a written contract, to prevent the running of the statute of limitations, must be in writing. Meyer v. Linch, 145 Neb. 1, 15 N.W.2d 317 (1944).

To remove bar of statute, debtor must unqualifiedly acknowledge an existing liability. France v. Ruby, 93 Neb. 214, 140 N.W. 175 (1913).

The unilateral crediting of defendant's debt without defendant's consent or knowledge was not a voluntary acknowledgment of the debt sufficient to toll the statute of limitations. Hejco, Inc. v. Arnold, 1 Neb. App. 44, 487 N.W.2d 573 (1992).

The mere entry of credit by a creditor without consent of his debtor is without effect upon the statute of limitations … T.S. McShane Co., Inc. v. Dominion Constr. Co., 203 Neb. 318, 278 N.W.2d 596 (1979).

Payment made on a debtor's note by the sale of his property on execution, or other legal process, is not such part payment within the meaning of this section. Moffitt v. Carr, 48 Neb. 403, 67 N.W. 150 (1896). — Revisor's annotations to Neb. Rev. Stat. §25-216

Tolling — absence from the state, §25-214

If a cause of action accrues against a person while he or she is out of the state or has absconded or concealed himself or herself, the period limited for the commencement of the action shall not begin to run (1) until he or she comes into the state or (2) while he or she is absconded or concealed. If the person departs from the state or absconds or conceals himself or herself after the cause of action accrues, the time of his or her absence or concealment shall not be computed as any part of the period within which the action must be brought. — Neb. Rev. Stat. §25-214

Borrowing statute — Uniform Conflict of Laws Limitations Act, §§25-3201 to 25-3207

(1)(a) Except as provided by section 25-3205 and subsection (2) of this section, if a claim is substantively based: (i) Upon the law of one other state, the limitation period of that state applies; or (ii) Upon the law of more than one state, the limitation period of one of those states chosen by the law of conflict of laws of this state applies. (b) The limitation period of this state applies to all other claims. — Neb. Rev. Stat. §25-3203 (bold added)

If the statute of limitations of another state applies to the assertion of a claim in this state, the other state's relevant statutes and other rules of law governing tolling and accrual apply in computing the limitation period, but its statutes and other rules of law governing conflict of laws do not apply. — Neb. Rev. Stat. §25-3204

If the court determines that the limitation period of another state applicable under section 25-3203 or 25-3204 is substantially different from the limitation period of this state and has not afforded a fair opportunity to sue upon, or imposes an unfair burden in defending against, the claim, the limitation period of this state applies. — Neb. Rev. Stat. §25-3205

General UDAP — Consumer Protection Act, §§59-1602, 59-1609, 59-1614

Unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce shall be unlawful. — Neb. Rev. Stat. §59-1602

Any person who is injured in his or her business or property by a violation of sections 59-1602 to 59-1606 … may bring a civil action in the district court to enjoin further violations, to recover the actual damages sustained by him or her, or both, together with the costs of the suit, including a reasonable attorney's fee, and the court may in its discretion, increase the award of damages … except that such increased award for violation of section 59-1602 shall not exceed one thousand dollars. — Neb. Rev. Stat. §59-1609

Any person who violates section 59-1602 shall pay a civil penalty of not more than two thousand dollars for each violation … — Neb. Rev. Stat. §59-1614

Medical debt — Medical Debt Relief Act, §§45-1301 to 45-1307 (a funding program, not a collections rule)

Sections 45-1301 to 45-1307 shall be known and may be cited as the Medical Debt Relief Act. — Neb. Rev. Stat. §45-1301 (Laws 2024, LB937, §43)

(1) The Medical Debt Relief Program is established for the purpose of discharging medical debt of eligible residents by contracting with a medical debt relief coordinator as described in subsection (3) of this section. The State Treasurer shall administer the program. — Neb. Rev. Stat. §45-1303 (Laws 2024, LB937, §45; Laws 2025, LB150, §51)

(2) Eligible resident means an individual eligible for relief who: (a) Is a resident of the State of Nebraska; and (b) Has a household income at or below four hundred percent of the federal poverty guidelines or has medical debt equal to five percent or more of the individual's household income; — Neb. Rev. Stat. §45-1302

Pending, not law. LB779 (2026) would impose the first Nebraska conduct rules specific to medical debt. As of 2026-08-12 it exists only as an Introduced copy (Conrad, 46; read first time January 7, 2026; Judiciary Committee) — FloorDocs/109/PDF/Slip/LB779.pdf and .../Final/LB779.pdf both return 404, so it was neither passed on Final Reading nor enacted. Its full operative text, for watch purposes:

Section 1. (1) No health care facility, as defined in section 71-413, or collection agency, as defined in section 45-602, shall charge a patient interest or late fees on medical debt until ninety days after the due date of the final invoice and no such interest or fees shall exceed three percent of the amount of the medical debt per year. For purposes of this section, medical debt means an obligation to pay money arising from the receipt of health care services.

(2) An individual's primary residential property shall not be the subject of liens or foreclosures for the purpose of collecting medical debt. — LB779, 109th Leg., 2d Sess. (2026), Introduced copy — NOT ENACTED

Plain English

Interpretation — the quotes above win on any conflict.

• Nebraska is a license state, and the license is unusually sticky. A third-party agency needs a Collection Agency Licensing Board license from the Secretary of State, obtained through NMLS, plus a surety bond of $5,000 / $10,000 / $15,000 scaled to how many licensed solicitors it employs (§45-608), plus a physical office inside Nebraska staffed during posted business hours (§45-607(2); 433 NAC ch. 2, §009.02). Losing the in-state office or Nebraska residency is mandatory revocation, not discretionary (§45-612). Operating unlicensed is a Class III misdemeanor for each day.
• Debt buyers are outside the Act entirely. §45-602(3)(k) excludes anyone who buys accounts for value and collects them in their own name. Nebraska therefore has no debt-buyer licensing, no debt-buyer pleading requirements, and no debt-buyer time-barred-debt regime — the opposite of Texas's §392.307.
• First-party creditors are outside it too, via §45-602(3)(a) ("regular employees of a single creditor"), unless they collect their own paper under a fictitious or third-party-sounding name, which §45-602(2)(b) pulls back into the definition and thus into the license requirement.
• There is no Nebraska mini-FDCPA. No harassment section, no fee-restriction section, no mini-Miranda, no validation overlay, no call-frequency cap, no call-time window, no time-barred disclosure. The federal FDCPA and Reg F are the operative conduct rules; the state's own regulation on the subject (433 NAC ch. 2, §008) does nothing but require the Board to tell applicants the FDCPA exists.
• SOL: written contracts 5 years (§25-205); anything not in writing, express or implied, including open accounts, 4 years (§25-206); negotiable promissory notes 6 years (U.C.C. §3-118(a)) — not 5.
• Revival is permissive and broad. A voluntary part payment restarts the full period and can resurrect an already-expired debt; only acknowledgments and promises must be in writing. Nebraska is a re-aging state.
• Nebraska borrows other states' limitation periods. Under §25-3203 a claim substantively based on another state's law carries that state's period, together with that state's tolling and accrual rules (§25-3204).

Traps / edge cases

• Two different §3-118s. The Legislature publishes the UCC at /laws/ucc.php?code=3-118. statutes.php?statute=3-118 is Chapter 3 — Aeronautics, a records-privilege section. Citing "Neb. Rev. Stat. §3-118" for note limitations is a wrong cite; the correct form is Neb. U.C.C. §3-118.
• The written/oral line is drawn by what has to be proved, not by what exists. Under Aurora Technology v. Labedz, 30 Neb. App. 33 (2021), a contract that is partly written and partly oral — one where parol evidence is needed to establish the terms — falls under §25-206's 4 years, not §25-205's 5. A card issuer that cannot produce a complete cardholder agreement is arguing for its own shorter period.
• The credit-card bucket is genuinely contested and is not resolved by statute. §45-1,113(2)(b) exempts card loans from Nebraska's credit-agreement writing requirement, which cuts against automatically treating a card account as a §25-205 written contract; §25-206 plus the account-stated and last-item annotations support 4 years. FLAGGED / interpretation: no Nebraska appellate decision squarely classifying revolving consumer card debt was locatable in official sources. Treat 4 years as the working default and 5 years as a live adverse period wherever a signed, self-contained written agreement is produced.
• Revival cuts against consumers here, and the trigger is low. Because a bare voluntary payment revives a barred debt "of its own vigor" (Ebersole), a single small payment on decade-old Nebraska paper can restart five (or four) years. But it must be voluntary and knowing: garnishment or execution proceeds are not part payment (Moffitt v. Carr), a creditor's unilateral book entry is not (T.S. McShane, Hejco), and payments obtained by subterfuge do not count (Kyger v. Ryley). Nebraska also conditions the effect on circumstances "which justify the inference that the debtor recognizes the whole debt as an existing liability" (T.S. McShane) — so a payment expressly made on a disputed or partial basis is not automatically a full revival.
• The borrowing statute is the sleeper. Most national card agreements pick another state's law. §25-3203 makes that state's limitation period — and its tolling and accrual rules — govern in a Nebraska court, subject only to the §25-3205 unfairness escape hatch. A "Nebraska = 4 or 5 years" answer can be wrong on a Nebraska-resident account.
• §25-214 is broader than a typical absence-tolling statute. If the cause of action accrues while the debtor is out of state, the clock does not begin; departure after accrual excludes the absence from the count. There is no cap in the text. Treat any absence adjustment as attorney-review territory.
• The bond protects clients, not consumers. §45-608's condition is faithful performance of agreements with clients or customers and remittance of net proceeds within 45 days of month-end. A consumer harmed by collection conduct is not the bond's intended claimant.
• Missing the December 31 renewal is not a late fee — it is a new application. 433 NAC ch. 2, §006.02 re-characterizes a late renewal as an initial application, which means the full investigation fee, the Board's review, and a gap in licensed status.
• Government collections carry a 30-day cooling-off notice. Under §45-623(2) a public body must mail first-class notice and wait 30 days before assigning a public debt to an agency, and §45-623(3) limits the agency to ordinary private-assignee remedies.

Related

• ../federal/fdcpa/overview.md
• ../federal/reg-f/call-frequency.md
• ../federal/reg-f/time-barred-debt.md
• ./tx.md · ./_matrix.md