§ 8.01-465.28.(Effective July 1, 2027) Complaint requirements.

A default judgment against a consumer who never appears in court puts a lot of weight on the paperwork alone, and this section makes sure that paperwork carries real content. A default judgment can be entered only if the complaint or amended complaint complies with this section and includes the notice § 8.01-465.29 requires.

The complaint has to identify the players and the account in detail: the consumer's name and address as it appeared in the creditor's records at charge off or default, the creditor's name including any merchant or affinity brand, at least the last four digits of the account number, the date and amount of the last payment, and the date of charge off or default. It also has to show the money: the outstanding balance, and an itemized breakdown of the judgment amount sought — separating out finance charges, fees or costs, attorney fees, and credits or payments — plus a statement of whether the judgment amount might grow from accruing interest or charges.

Procedural facts get their own line items too: the plaintiff's authority to bring the action, facts showing the action is in a proper venue, and facts showing it is within the statute of limitations. And if the plaintiff bought the debt rather than originating it, the complaint must trace every link in that chain — each person that acquired the debt after charge off or default, and the date of each acquisition.

None of that is just assertion. The plaintiff must attach at least one document proving the debt exists — a signed agreement, a record of purchase, payment, or account use, or another record showing the debt was incurred — and, if the plaintiff is not the creditor, documentation proving its authority to collect.