Any complaint based on a credit card debt shall contain additional information necessary to provide the court with sufficient information regarding standing and the statute of limitations. At a minimum, the complaint must include the following, unless otherwise ordered by the court:
Rule 9.1.Complaint in a credit card debt action
Group III: Pleadings and Motions · Last amended September 1, 2015 · Last verified July 14, 2026
In one sentenceRule 9.1 requires anyone suing to collect a credit card debt in Vermont to plead specific facts up front - the original creditor, account details, default date, amount owed, and the full chain of any assignment - so the court can see the plaintiff has standing and the claim is not time-barred.
Full Text of Rule 9.1
(a) The name of the original creditor, as well as the name of the current owner of the debt, if different.
(b) The last four digits of the original account number or other identifying information uniquely associated with the account.
(c) The date of last payment by the accountholder and the amount due at that time.
(d) The date the plaintiff claims the defendant defaulted and the basis for that default.
(e) The total amount currently due on the debt, with any amount of interest claimed post-default separately identified.
(f) The date and parties to the contract or other source of the original debt.
(g) If the debt was assigned, the date and parties to the assignment. If the debt has been assigned more than once, then the date and parties to each assignment must be identified to establish an unbroken chain of ownership. The complaint must allege that each assignment or other writing evidencing transfer of ownership contains at least the last four digits of the original account number of the debt purchased or other identifying information uniquely associated with the account and shows the debtor’s name associated with that account number.
Notes
Reporter’s Notes: V.R.C.P. 9.1 is added to incorporate in the civil rules the pleading requirements for an action on a credit card debt added to the Vermont Rules of Small Claims Procedure by the addition of V.R.S.C.P. 3(h) in a 2013 amendment and a simultaneous 2015 clarifying amendment to V.R.S.C.P. 3(h)(7). By simultaneous amendment, V.R.C.P. 55(b)(7) is added to incorporate the provisions of the 2013 amendment of V.R.S.C.P. 3(e) and a simultaneous 2015 clarifying amendment covering the requirements for a motion for default in a credit card debt action. New V.R.C.P. 9.1 requires that the complaint in a civil action on a credit card debt must plead the details of the original transaction and subsequent assignments of the debt. New V.R.C.P. 55(b)(7) requires that a motion for default judgment in a credit card action must be accompanied by documentary evidence of the matters required to be pleaded. See Reporter’s Notes, V.R.C.P. 55. These new rules adopt virtually verbatim the 2013 amendment of V.R.S.C.P. 3(e) and addition of V.R.S.C.P. 3(h) and their 2015 amendments. These rules were based on rules and statutes in other states, including North Carolina, Delaware, and New York. The new rules require the plaintiff creditor to establish the existence of the debt and ownership of it—or at least that the plaintiff is acting as an agent of one who can establish ownership. The new rules are necessary because many credit card collection actions are brought in the Superior Court, Civil Division, as civil, rather than small claims, actions. The amendments reflect best practices followed by many plaintiffs’ attorneys in such civil actions, but some do not follow the pleading and motion practice provided for small claims actions. As a result, defendants must expend significant resources and time on lengthy and difficult discovery to obtain the information and documents that V.R.S.C.P. 3(h) and (e) require to be pleaded and attached to a motion for default judgment in a small claims action. The rules will harmonize practice in small claims and civil actions and avoid the need for discovery with regard to basic items related to a credit card collection claim.
Amendment History
Added July 1, 2015, eff. Sept. 1, 2015.
Plain-English Summary
Rule 9.1 singles out one category of case for extra pleading detail: a complaint based on a credit card debt. Unless the court orders otherwise, the complaint must identify the original creditor and, if different, the current owner of the debt; the last four digits of the original account number or other identifying information tied to the account; the date of the accountholder's last payment and the amount due at that time; the date and basis for the claimed default; and the total amount currently due, with any post-default interest broken out separately. The complaint must also state the date and parties to the original contract or other source of the debt.
Rule 9.1(g) addresses the chain of ownership when a debt has changed hands. If the debt was assigned, the complaint must state the date and parties to the assignment; if it was assigned more than once, each assignment must be identified so the chain of ownership is unbroken from the original creditor to the current plaintiff. Each assignment or other transfer document must be alleged to contain at least the last four digits of the original account number and to show the debtor's name tied to that account number, which lets the court and the defendant confirm the plaintiff is suing on the right debt.
Frequently Asked Questions
What information must a credit card debt complaint include in Vermont?
Rule 9.1 requires the name of the original creditor and current debt owner, the last four digits of the original account number, the date and amount of the accountholder's last payment, the date and basis of the claimed default, the total amount currently due with post-default interest identified separately, and the date and parties to the original contract.
Why does Rule 9.1 require the original creditor's name and account details?
So the court can confirm the plaintiff has standing to collect the debt and can trace ownership back to the original account, rather than taking the plaintiff's claim of ownership on faith.
What if the credit card debt was sold more than once before the lawsuit was filed?
Rule 9.1(g) requires the complaint to identify the date and parties to each assignment, so the chain of ownership from the original creditor to the current plaintiff is unbroken, and each assignment document must show the last four digits of the account number and the debtor's name.
Does a Vermont credit card debt complaint need to address the statute of limitations?
The rule requires the date of the accountholder's last payment and the date the plaintiff claims the defendant defaulted, which gives the court the information needed to assess whether the statute of limitations has run, even though the rule does not require a separate statute-of-limitations statement.
Can a Vermont court excuse a plaintiff from including this information?
Yes. Rule 9.1 states that its list of required information applies "unless otherwise ordered by the court," so a court can modify what a specific complaint must include.
Source & verification. Rule text, official Reporter's Notes, and
amendment history are reproduced verbatim from the Vermont Rules of Civil Procedure,
adopted by the Vermont Supreme Court. Last verified July 14, 2026.
· Official source
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