Vermont — Consumer Protection Rule CP 104 (AG rule, not a statute) + SOL

Authority

Vermont has no debt-collection statute and no collection-agency license. Its mini-FDCPA is an Attorney General rule — Consumer Protection Rule CP 104, adopted under the rulemaking grant in 9 V.S.A. §2453(c) and effective January 28, 1974. CP 104 declares each listed collection practice to be "an unfair trade act and practice in commerce under 9 V.S.A. Section 2453(a)," which routes enforcement into the Consumer Protection Act: Attorney General / State's Attorney injunction and civil penalties (§2458), and a private right of action with treble exemplary damages and fees that expressly reaches rule violations (§2461(b)).

Limitations periods live in 12 V.S.A. ch. 23 (general 6-year period at §511; the witnessed-note outlier at §508), with negotiable notes governed by 9A V.S.A. §3-118. Medical debt has its own 2022/2025 regime in 9 V.S.A. §2466d and 18 V.S.A. ch. 221, subch. 10.

Verification note. Three fetch obstacles, all worked around with official sources:

1. legislature.vermont.gov (the official VSA publisher, Vermont General Assembly) serves an incomplete TLS chain — automated fetch fails with "unable to verify the first certificate." Same failure class as legislature.mi.gov and cga.ct.gov; curl -k fetches cleanly. Statute text below is from that host, section pages /statutes/section/<title>/<chapter>/<section>, pulled 2026-08-12.
2. ago.vermont.gov 403s all HTML to both automated fetch and curl, but serves its PDFs to curl to an ordinary browser request. CP 104's full text below is from the AG's own posted rule PDF, https://ago.vermont.gov/wp-content/uploads/2018/01/CP-104.pdf.
3. The legislature's statute search is a DataTables shell that renders nothing to a fetcher. Its official JSON endpoint is open: GET /statutes/loadStatuteSearchResults/?Keywords=<terms>&Title=0 (returns {"data":[{Parent, Section, …}]}). This is a relevance-ranked OR search, not exact phrase — usable as a finding aid, not as proof of a negative.

Currency of CP 104. The AG also posts the rule under its pre-2012 name, CF-104.pdf ("Consumer Fraud — Debt," Public Protection Division), from the era before 9 V.S.A. ch. 63 was retitled the Consumer Protection Act. Both PDFs were pulled and diffed: the operative text is identical (differences are the chapter rename and OCR artifacts), so the 1974 rule text is unchanged. Cross-checked against the Secretary of State's official APA rules database (secure.vermont.gov/SOS/rules, POST search.php, coverage confirmed back to 2011): searching LegalAuthority=2453 and Title=debt collection / Consumer / Collection returns no AG debt-collection rulemaking, proposed or adopted, 2011–2026. Vermont's fully adopted rule code is published through LexisNexis (a vendor host, not the source of record), so the AG's own PDF is used as the authority here.

Operative text

Scope — CP 104.07 (the rule covers ORIGINAL CREDITORS)

(1) The term "debt collector" means any person engaging or aiding directly or indirectly in enforcing claims, and includes creditors and their agents when they are so acting. (2) The term "debt" means money, property, or their equivalent which is due or owing or alleged to be due or owing. (3) The term "debtor" means a person from whom a debt collector seeks to collect a debt which is due and owing or alleged to be due and owing from such person. — Vt. Consumer Protection Rule CP 104.07

There is no third-party limitation anywhere in the rule and no consumer-purpose limitation in the definition of "debt" — though every substantive section is scoped to "any debt arising out of a consumer transaction."

Harassment — CP 104.02 (the frequency and call-time provisions)

The use of any conduct, the natural consequence of which is to oppress, harass, or abuse any person in connection with the collection of or attempt to collect any debt arising out of a consumer transaction constitutes an unfair trade act and practice in commerce under 9 V.S.A. 2453(a).

Such unfair acts include (but shall not be limited to) the following:

(a) The use of profane or obscene language or language that would ordinarily abuse the hearer or reader; (b) The placement of telephone calls to the debtor without disclosure to the debtor of the name of the business or company the debt collector represents; (c) Causing expense to any person in the form of long distance tolls, telegram fees, or other charge incurred through the use of a medium of communication by misrepresenting to such person the true purpose of the notice, letter, message or communication; (d) Causing a telephone to ring or engage any person in telephone conversation with such frequency as to be unreasonable or to constitute a harassment to the person under the circumstances, or at times known to be times other than normal waking hours of the person; (e) The placement of telephone calls to any person, contrary to his instructions, at his place of employment. — Vt. Consumer Protection Rule CP 104.02

No number appears anywhere in CP 104.02. The frequency limit is "such frequency as to be unreasonable," and the call-time limit is "times known to be times other than normal waking hours of the person" — a subjective, per-debtor standard, not a clock. (b) also requires company-name disclosure on every call, not just the first.

Unreasonable publication — CP 104.03 (broader than the FDCPA)

(a) The communication of any information relating to a consumer debt to any employer or his agent; provided, however, that a communication to an employer would be permitted if it were made after a judgment on the consumer debt had been entered against the debtor or made with the written consent of the debtor or his attorney, or in order to locate the debtor or his residence or his place of employment and no indication of indebtedness is conveyed including the fact that the call is being placed by a debt collection agency; (b) The disclosure, publication, or communication of any information relating to a consumer debt to any family member of the debtor other than the debtor's spouse or the parents or guardians of a debtor who is either a minor or who resides in the same household with such parent or guardian; provided, however, that the making of such communications would not be considered unfair acts if made after the obtaining of a judgment or if the debtor or his attorney had consented to them; (c) The disclosure, publication, or communication of any information relating to a consumer debt to any person other than as specified above, other than through proper legal action, process or proceeding; (d) The use of any form of communication to the debtor which ordinarily would be seen by any other person, except telegrams, that displays or conveys any information about the alleged claim other than the name, address, and phone number of the debt collector; (e) Notwithstanding the foregoing provisions of CP 104.03, the disclosure, publication or communication by a debt collector of information relating to a consumer debt or the debtor to a consumer reporting agency or to any other persons who request such information and who are reasonably believed to have a legitimate business need for such information shall not be deemed to violate this Rule. — Vt. Consumer Protection Rule CP 104.03

Unconscionable means — CP 104.05 (fees, time-barred acknowledgments, attorney cease)

(a) The seeking or obtaining of any written statement or acknowledgment in any form containing an affirmation of any obligation by a debtor who has been declared bankrupt, an acknowledgment of a debt barred by a statute of limitations, or a waiver of any legal right of a debtor, without clearly disclosing the nature and consequences of such affirmation or waiver and the fact that the debtor is not legally obligated to make such affirmation or waiver; provided, however, that this provision does not prohibit the accepting of promises to pay that are voluntarily written and offered by the debtor; (b) The collection of or the attempt to collect from the debtor any part or all of the debt collector's fee or charge for services rendered, unless legally entitled to such fee or charge; (c) The collection of or the attempt to collect any interest or other charge, fee, or expense incidental to the principal obligation unless such interest or incidental fee, charge, or expense is expressly authorized by the agreement creating the obligation and is legally chargeable to the debtor, or is legally chargeable under state law; (d) The initiation of communications with a debtor, other than statement of account used in the normal course of business to inform persons of money due, whenever the debt collector has been notified that the debtor is represented by an attorney and such notice includes the attorney's name and a request by such attorney that all communications regarding the consumer debt be addressed to the attorney; provided, however, that such communications would be allowed if the attorney has given prior approval to the communications. — Vt. Consumer Protection Rule CP 104.05

Threats and coercion — CP 104.01; deceptive representations — CP 104.04

CP 104.01 makes unfair "any unfair threat, coercion or attempt to coerce," listing (a) violence or criminal means; (b) false accusation or threat to falsely accuse of fraud or crime; (c) false accusation to any person including any credit reporting agency that the consumer is willfully refusing to pay a just debt; (d)–(e) threatening sale/assignment with a false suggestion the consumer will lose defenses or face "harsh, vindictive, or abusive collection attempts"; (f) arrest or seizure threats "without proper notice, and a court order permitting such action unless such action is in fact contemplated by the debt collector and permitted by the law"; (g) threatening action not in fact taken in the usual course of business; (h) threatening action prohibited by the rule.

CP 104.04's nine enumerated deceptive acts include the Vermont mini-Miranda and an assignee disclosure with no federal analog:

(b) The failure to clearly disclose in all written communications made to the debtor or to members of the debtor's family in order to collect or attempt to collect a claim or to obtain information about a debtor that the debt collector is attempting to collect a claim and any information obtained will be used for that purpose; … (d) The failure to clearly disclose the name and full business address of the person to whom the claim has been assigned at the time of communicating the first demand for money after the date of the assignment; … (h) Any representation that an existing obligation of the debtor may be increased by the addition of attorney's fees, investigation fees, service fees, or any other fees or charges, if in fact such fees or charges may not legally be added to the existing obligation; — Vt. Consumer Protection Rule CP 104.04

CP 104.06 makes the unlicensed practice of law by a debt collector an unfair and deceptive act, including "[a]ny communication with a debtor in the name of an attorney or upon stationery or other written matter bearing an attorney's name."

The rule's legal effect — 9 V.S.A. §2453

(a) Unfair methods of competition in commerce and unfair or deceptive acts or practices in commerce are hereby declared unlawful. … (c) The Attorney General shall adopt rules, when necessary and proper to carry out the purposes of this chapter, relating to unfair methods of competition in commerce and unfair or deceptive acts or practices in commerce. The rules shall not be inconsistent with the rules, regulations, and decisions of the Federal Trade Commission and the federal courts interpreting the Federal Trade Commission Act. (d) Violation of a rule adopted by the Attorney General is prima facie proof of the commission of an unfair or deceptive act in commerce. — 9 V.S.A. §2453 (as amended through 2017, No. 74, §13)

Penalties and private right of action — 9 V.S.A. §§2458, 2461

(b) In addition to the foregoing, the Attorney General or a State's Attorney may request and the court is authorized to render any other temporary or permanent relief, or both, as may be in the public interest, including: (1) the imposition of a civil penalty of not more than $10,000.00 for each unfair or deceptive act or practice in commerce … (2) an order for restitution of cash or goods on behalf of a consumer or a class of consumers similarly situated; (3) an order requiring reimbursement to the State of Vermont for the reasonable value of its services and its expenses in investigating and prosecuting the action; — 9 V.S.A. §2458(b)

(b) Any consumer who contracts for goods or services in reliance upon false or fraudulent representations or practices prohibited by section 2453 of this title, or who sustains damages or injury as a result of any false or fraudulent representations or practices prohibited by section 2453 of this title, or prohibited by any rule or regulation made pursuant to section 2453 of this title, may sue for appropriate equitable relief and may sue and recover from the seller, solicitor, or other violator the amount of his or her damages, or the consideration or the value of the consideration given by the consumer, reasonable attorney's fees, and exemplary damages not exceeding three times the value of the consideration given by the consumer. Any language, written or oral, used by a seller or solicitor, that attempts to exclude or modify recovery of the penalty or reasonable attorney's fees shall be unenforceable. — 9 V.S.A. §2461(b) (emphasis added)

§2461(a) adds a separate civil penalty of up to $10,000 per violation of an injunction issued under §2458.

Entry gate — NONE (positive negative, with method)

Vermont has no collection-agency license, registration, or bond. Verified by enumerating the official chapter tables of contents for all three titles that could carry one:

• 8 V.S.A. (Banking and Insurance) — 87 chapters. The licensing chapters are ch. 73 (Licensed Lenders, Mortgage Brokers, Mortgage Loan Originators, Sales Finance Companies, and Loan Solicitation Companies), ch. 74 (Consumer Litigation Funding Companies), ch. 79 (Money Services), ch. 83 (Debt Adjusters), ch. 85 (Loan Servicers). No collection-agency chapter.
• 9 V.S.A. (Commerce and Trade) — 78 chapters. Licensing/registration chapters cover pawnbrokers (ch. 97), precious metal dealers (ch. 97A), telemarketers (§2464b), and securities (chs. 131, 150). No collection-agency chapter.
• 26 V.S.A. (Professions and Occupations) — 74 chapters, the Office of Professional Regulation's full roster from Accountants to Well Drillers. No collection-agency chapter.

The nearest-neighbor licence, 8 V.S.A. ch. 83, is debtor-side and does not reach collectors:

As used in this chapter, "debt adjustment" means making an agreement with a debtor whereby the debt adjuster agrees to distribute, supervise, coordinate, negotiate, or control the distribution of money or evidences thereof among one or more of the debtor's creditors in full or partial payment of obligations of the debtor and includes services as an intermediary between a debtor and one or more of the debtor's creditors for the purpose of obtaining concessions. — 8 V.S.A. §2751

Consumer-paper protections — 9 V.S.A. §§2455, 2456

The holder of a promissory note or instrument, or other evidence of indebtedness of a consumer delivered in connection with a contract shall take or hold that note, instrument, or evidence subject to all defenses of such consumer that would be available to the consumer in an action on a simple contract, and all rights available to him or her under this chapter. — 9 V.S.A. §2455

Any agreement of a consumer in a contract that a power of attorney is given to confess judgment, or an assignment of wages is given, or any agreement of similar effect, is void and of no force and effect on any party. — 9 V.S.A. §2456

Statute of limitations — 12 V.S.A. ch. 23

Vermont has one six-year catch-all covering written contracts, oral contracts, and open accounts alike. There is no separate oral-contract or open-account period.

§ 511. Civil action. A civil action, except one brought upon the judgment or decree of a court of record of the United States or of this or some other state, and except as otherwise provided, shall be commenced within six years after the cause of action accrues and not thereafter. — 12 V.S.A. §511 (Amended 1959, No. 261, §3)

The three carve-outs from the six-year default that matter to collections:

§ 507. Specialties. Actions on specialties shall be brought within eight years after the cause of action accrues, and not after. — 12 V.S.A. §507

§ 508. Witnessed promissory note. An action brought on a promissory note signed in the presence of an attesting witness shall be commenced within 14 years after the cause of action accrues, and not after. — 12 V.S.A. §508

§ 506. Judgments. Actions on judgments and actions for the renewal or revival of judgments shall be brought by filing a new and independent action on the judgment within eight years after the rendition of the judgment, and not after. — 12 V.S.A. §506 (Amended 2009, No. 132 (Adj. Sess.), §8, eff. May 29, 2010)

Two scope provisions govern how those interact with everything else:

§ 464. Actions specially limited by other provisions. The provisions of this chapter shall not affect an action otherwise specially limited by law. — 12 V.S.A. §464

§ 509. Evidence of debt issued by a monied corporation. The provisions of this chapter shall not apply to an action brought to enforce payment on any bills, notes, or other evidences of debt issued by a bank or other monied corporation and put into circulation as money. — 12 V.S.A. §509

Contractual shortening or waiver of the period is void, and filing (not service) can stop the clock:

§ 465. Limitations or waiving limitation of actions in contracts. Except as otherwise provided by statute, any provision in a contract which limits the time in which an action may be brought under the contract or which waives the statute of limitations shall be null and void. — 12 V.S.A. §465 (1961, No. 187)

§ 466. When action deemed commenced. For the purpose of determining whether a period of limitation prescribed in this chapter has run, an action shall be deemed commenced upon the filing of the complaint with the clerk of the court in which the action is being brought if the action is commenced by filing or upon service of the summons and complaint if the action is commenced by service. — 12 V.S.A. §466

Negotiable notes — 9A V.S.A. §3-118 (six years)

Vermont adopted Revised UCC Article 3 effective January 1, 1995:

(a) Except as provided in subsection (e) of this section, 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) of this section, 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 10 years. — 9A V.S.A. §3-118(a)–(b) (Added 1993, No. 158 (Adj. Sess.), §12, eff. Jan. 1, 1995)

§3-118(c)–(g) give shorter periods for unaccepted drafts (3 years from dishonor or 10 years from the date of the draft, whichever expires first), certified/teller's/cashier's/traveler's checks (3 years from demand), certificates of deposit (6 years from demand), accepted drafts (6 years), and residual Article 3 claims including conversion and breach of warranty (3 years).

Tolling — 12 V.S.A. §§551, 552, 555, 558; 13 V.S.A. §5366

Absence from the state (note the third sentence — the only borrowing-statute-like limit located in ch. 23):

§ 552. Absence from State. If a person is out of the State when a cause of action of a personal nature mentioned in this chapter accrues against him or her, the action may be commenced within the time limited therefor after such person comes into the State. If a person is absent from and resides out of the State after a cause of action accrues against him or her and before the statute has run, and he or she has not known property within the State which can by common process of law be attached, the time of his or her absence shall not be taken as a part of the time limited for the commencement of the action. The provisions of this section shall not extend to a cause of action accruing in another state or government, when the parties thereto at the time of the accruing of such cause of action are residents of such other state or government. — 12 V.S.A. §552

§551 tolls for minority, incapacity due to a mental condition or psychiatric disability, or imprisonment at accrual (and §551(b) for incapacity arising mid-period). §555 excludes the pre-discovery period where the defendant fraudulently concealed the cause of action. §558 gives a one-year savings window to refile after an action timely commenced is dismissed for insufficient process, lack of jurisdiction, improper venue, failure to join an indispensable party, or a party's death.

A Vermont-specific tolling trigger with no analog in most states — a victims-compensation claim both freezes collection and stops the SOL clock for the related medical debt:

(a) When a person files a claim under this chapter, no health care provider that has been given notice of the claim shall conduct any debt collection activities relating to medical or dental treatment received by the person in connection with the claim until an award is made on the claim or until the claim is determined to be noncompensable pursuant to section 5355 of this title. The period during which the health care provider is prohibited from conducting debt collection activities under this section shall be excluded in determining the applicable limitations period for commencing an action to collect the debt. (b) As used in this section: (1) "Debt collection activities" means repeatedly calling or writing to the claimant and threatening to turn the matter over to a debt collection agency or to an attorney for collection, enforcement, or filing of other process. The term shall not include routine billing or inquiries about the status of the claim. — 13 V.S.A. §5366 (emphasis added)

Revival — 12 V.S.A. §§591, 592, 593 (payment revives; oral acknowledgment does not)

Vermont splits acknowledgments from payments, exactly as Massachusetts does at G.L. c. 260 §§13–14:

§ 591. New promise must be in writing and signed. An acknowledgment or promise shall not be held to affect a defense made under the provisions of this chapter, unless such acknowledgment or promise is in writing signed by the party affected thereby. — 12 V.S.A. §591

§ 592. Indorsement or memorandum of payment. This chapter shall not alter or take away the effect of the payment of any principal or interest; but an indorsement or memorandum of such payment made upon a promissory note, bill of exchange, or other writing, unless in the handwriting of the party making the payment, shall not be proof of the payment sufficient to take the cause out of the provisions of this chapter. — 12 V.S.A. §592

§ 593. Joint promisors—Promise or payment by one. When there are two or more joint contractors, or joint executors, or administrators of a contractor, such joint contractor, executor, or administrator shall not lose the benefit of the provisions of this chapter, so as to be chargeable by reason of an acknowledgment, promise, or payment made or signed by any other of them. — 12 V.S.A. §593

§594 lets a plaintiff take judgment against whichever joint contractors are revived "by virtue of a new acknowledgment or promise, or otherwise," while the others go free.

There is no statutory post-expiry suit bar and no statutory time-barred-debt disclosure in Vermont. All 140 sections of 9 V.S.A. ch. 63 were enumerated from the official chapter TOC and none imposes one, and CP 104's only SOL-adjacent obligation is the conditional disclosure in CP 104.05(a) quoted above.

Medical debt — 9 V.S.A. §2466d and 18 V.S.A. ch. 221, subch. 10

The 2025 change is 2025 Acts & Resolves No. 21 (S.27), "An act relating to medical debt relief and excluding medical debt from credit reports," signed May 15, 2025, effective July 1, 2025. (The dispatcher's lead named S.36; the enacted vehicle is S.27.) It works both sides of the furnisher/CRA relationship.

CRA side (new §2466d — note this sits inside the Consumer Protection Act, so a violation carries §§2458/2461 exposure):

(a) A credit reporting agency shall not report or maintain in the file on a consumer information relating to a medical debt. (b) As used in this section: … (2) "Medical debt" means debt arising from health care services, including dental services, or from health care goods, including products, devices, durable medical equipment, and prescription drugs. "Medical debt" does not include debt arising from services provided by a veterinarian, debt charged to a credit card unless the credit card is issued under an open-end or closed-end credit plan offered solely for the payment of health care services, debt charged to a home equity or general-purpose line of credit, or secured debt. — 9 V.S.A. §2466d (Added 2025, No. 21, §4, eff. July 1, 2025)

Furnisher side (in force since July 1, 2022; Act 21 §7 carried it forward):

(a)(1) No large health care facility shall sell its medical debt except as provided in subdivision (2) of this subsection. (2) A large health care facility may sell or otherwise transfer its medical debt to an organization that is exempt from taxation under Section 501(c)(3) of the Internal Revenue Code for the specific purpose of the tax-exempt organization abolishing the medical debt of one or more patients by cancellation of the indebtedness. (b) No large health care facility or medical debt collector shall report or otherwise furnish any portion of a medical debt to a credit reporting agency. — 18 V.S.A. §9485 (Added 2021, No. 119 (Adj. Sess.), §1, eff. July 1, 2022; amended 2025, No. 21, §7, eff. July 1, 2025) (emphasis added)

"Medical debt collector" is defined broadly and is not limited to collectors working large-facility paper:

(9) "Medical debt collector" means an individual or entity that regularly collects or attempts to collect, directly or indirectly, medical debts originally owed or due, or asserted to be owed or due, to another individual or entity. — 18 V.S.A. §9481(9)

A financial-assistance disclosure rides on every collection contact for large-facility debt:

(b) Each large health care facility shall directly notify individuals who receive care from the facility about the facility's financial assistance policy by, at a minimum: … (2) including a conspicuous written notice on billing statements, whether sent by the facility or by a medical debt collector, stating that financial assistance is available to some patients based on income and including: (A) a telephone number that the patient can call to request a financial assistance application …; and (B) the specific website address at which copies of the policy and application are available. (c) All written or oral attempts by a medical creditor or medical debt collector to collect a medical debt arising from health care services delivered by a large health care facility shall include information for the patient about the relevant financial assistance policy or policies. — 18 V.S.A. §9484(b)–(c) (emphasis added)

Forum limit — 12 V.S.A. §5531(e)

(e) Notwithstanding this section or any other provision of law, the small claims court shall not have jurisdiction over actions for collection of any debt greater than $5,000.00 arising out of: (1) a consumer credit transaction as defined in 15 U.S.C. § 1679a; or (2) medical debt as defined in 18 V.S.A. § 9481. — 12 V.S.A. §5531(e) (Amended 2023, No. 46, §9, eff. June 5, 2023)

The general small-claims ceiling is $10,000 (§5531(a)); consumer-credit and medical claims above $5,000 must go to Superior Court.

Plain English

Interpretation — the quotes above win on any conflict.

• Vermont's mini-FDCPA is a rule, not a statute, and it is older than the FDCPA (1974 vs 1978). Anyone searching V.S.A. for a debt-collection act finds nothing and wrongly concludes Vermont is a bare-federal-floor state. It is not.
• CP 104 covers original creditors. CP 104.07(1) says "debt collector" "includes creditors and their agents when they are so acting." A creditor collecting its own consumer paper in Vermont is fully bound.
• There is no entry gate. No license, no registration, no bond, no regulator roster. The Attorney General's Consumer Protection Division is the enforcement body, not a licensor.
• CP 104 has call-frequency and call-time provisions, but no numbers. "Such frequency as to be unreasonable" and "other than normal waking hours" are standards. In practice Reg F's 7-in-7 presumption and 8am–9pm window remain the operative hard limits in Vermont — but note that "normal waking hours of the person" is a known-to-the-collector subjective test that can be narrower than 8am–9pm for a given debtor, so Reg F compliance is a floor and not a safe harbor.
• Two disclosure duties are stricter than federal. CP 104.02(b) requires the collector to name the company it represents on every call. CP 104.04(d) requires the assignee's name and full business address in the first demand for money after assignment.
• The employer/family contact ban is much broader than FDCPA §1692c(b). CP 104.03(a) bars any communication of debt information to an employer pre-judgment absent written consent, and location calls to the employer must not reveal that a collection agency is calling. CP 104.03(b) bars disclosure to family members other than a spouse (or parents/guardians of a minor or co-resident).
• Rule violations reach consumers directly. §2461(b) expressly extends the private right of action to conduct "prohibited by any rule or regulation made pursuant to section 2453," with attorney's fees and exemplary damages up to three times the consideration. §2453(d) makes a rule violation "prima facie proof" of a UDAP violation — strong, but technically a burden-shifting presumption rather than a true per-se rule; CP 104's own sections say the conduct "constitutes" an unfair act, so both readings point the same direction.
• SOL is a flat six years for essentially all consumer debt — one statute (§511) covering written, oral, and open account alike, with negotiable notes also at six (9A §3-118(a)). The outliers are specialties at 8 (§507), judgments at 8 (§506), and witnessed promissory notes at 14 (§508).
• Payment revives; talk does not. §591 makes an acknowledgment or new promise ineffective unless in writing and signed by the debtor. §592 then expressly preserves the common-law effect of a payment of principal or interest — so a part payment can restart the clock without any writing, while a recorded phone acknowledgment cannot. §592's second clause is the trap: the collector's own endorsement or ledger memo of the payment is not sufficient proof unless it is in the debtor's handwriting.
• Medical debt is effectively invisible to credit reporting in Vermont, from both ends: CRAs may not report or maintain it (§2466d), and facilities and medical debt collectors may not furnish it (§9485(b)). Every collection attempt on large-facility medical debt must carry financial-assistance information (§9484(c)).

Traps / edge cases

• §508's 14-year witnessed-note track vs. 9A §3-118's 6 years — genuine conflict, do not resolve it silently. Both are current law. 12 V.S.A. §464 says ch. 23 "shall not affect an action otherwise specially limited by law," and §3-118 is both later-enacted (1995) and more specific to negotiable instruments, which reads toward six years for a negotiable witnessed note, with §508 surviving for non-negotiable witnessed notes. The opposite reading — that §508 is the more specific provision as to witnessed notes — is also available. UNVERIFIED / attorney review: no Vermont appellate authority was located reconciling them (see the case-law note below). Never auto-apply 14 years. Same structural problem as Maine's 14 M.R.S. §751 witnessed-note track.
• "Specialty" (§507, 8 years) is a live category in Vermont, not a historical curiosity. A sealed instrument or other specialty pushes past the six-year default. If contract paper carries a seal, the six-year assumption is wrong.
• Judgments do not renew by motion. §506 requires "a new and independent action on the judgment" within eight years of rendition. A docketed Vermont judgment quietly dies at year eight if nobody files a fresh suit.
• Contractual SOL shortening is void (§465), so a cardholder agreement's choice-of-shorter-period clause does not shorten the Vermont clock. Choice-of-law clauses are a separate question and are not addressed by §465.
• §552 is not a conventional borrowing statute. It tolls for a defendant's absence, and its third sentence merely withholds that tolling where the cause accrued in another state and both parties then resided there. No general borrowing statute was located in 12 V.S.A. ch. 23 (all 46 sections enumerated from the official chapter TOC) — so Vermont does not obviously import a shorter foreign period. Treat any out-of-state-accrual question as attorney review.
• CP 104.05(a) is a conditional disclosure duty, not a time-barred-debt notice requirement. It bites only when the collector seeks or obtains a written acknowledgment of a time-barred debt (or a bankruptcy-discharged debt, or a waiver of rights) — at which point the collector must clearly disclose the nature and consequences and that the debtor is not legally obligated to sign. Vermont has no Reg F–style standing disclosure on collecting time-barred debt. Reg F §1006.26 still applies federally.
• CP 104.05(c) is stricter than the FDCPA on fees: incidental interest/charges must be "expressly authorized by the agreement creating the obligation and … legally chargeable to the debtor, or … legally chargeable under state law." Read together with CP 104.04(h), representing that fees may be added when they may not is itself a separate deceptive act.
• Attorney-represented cease (CP 104.05(d)) has a carve-out the FDCPA lacks — a "statement of account used in the normal course of business to inform persons of money due" is not a prohibited "initiation of communications."
• Medical debt reporting bans are furnisher-side AND CRA-side, and the definitions differ. §2466d(b)(2) (CPA, 2025) excludes veterinary debt, general-purpose cards/lines, and secured debt; §9481(8) (Title 18, 2022) is a bare "debt arising from the receipt of health care services." A debt can fall outside §2466d and still be inside §9485(b). Apply the union, not either alone.
• Confessions of judgment and wage assignments in consumer contracts are void (9 V.S.A. §2456) — and §2455 strips holder-in-due-course insulation from consumer paper, so an assignee takes subject to every defense the consumer had against the original seller.
• 13 V.S.A. §5366 tolling is invisible in ordinary account data. A crime-victim compensation filing suspends both collection and the limitations clock on the related medical debt, and the trigger is notice to the provider, which may never reach a downstream collector.
• Vermont case law could not be verified in this pass. vermontjudiciary.org/opinions-decisions 301-redirects to a JS application, and the govinfo USCOURTS API returned OVER_RATE_LIMIT on the public demo key. Vermont case law is manual-verification-only. Every case-law-dependent question on this page is labeled rather than answered.

Related

• ../federal/fdcpa/overview.md · ../federal/fdcpa/harassment-abuse.md
• ../federal/reg-f/call-frequency.md · ../federal/reg-f/time-barred-debt.md
• ../federal/fcra-furnishing.md
• ./ma.md — the closest structural sibling on revival (G.L. c. 260 §§13–14 mirror 12 V.S.A. §§591–592)
• ./me.md — the other New England witnessed-note track (14 M.R.S. §751)
• ./tx.md — contrast: statutory no-revival regime for debt buyers
• ./_matrix.md