{"meta":{"key":"s_or--pass-04","task":"S_OR","title":"SOR bounded source-pinpoint and order-wording correction","parent_title":"Oregon debt and debt relief law","edition":"pass-04","path":"/research/s_or--pass-04/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-26","tables":10,"claims":9,"sources":8,"review_status":"accepted_with_limits","review_complete":true,"sha256":"9ccf578cf85de1d96cc3b873cc8ff10e7c68cc4604220229d120a99c3b89b833","headings":["1. Old → corrected patch index","S002 usages checked but not changed","2. Corrected affected source cells","S_OR-P3-S002 — replacement source cell","S_OR-P3-S001 — replacement source-status cell","S_OR-P3-S009 — replacement source/access cell","S_OR-P3-S011 — corrected subsection (2) usage","S_OR-P3-S013 — replacement source cell","S_OR-P3-S014 — replacement source cell","3. Corrected affected claim cells","4. Replacement for P3 §5.4 order wording","5. Minimum new source-usage rows","6. Coverage and gap disposition","7. Researcher self-check","Freshly read or visually inspected for PASS-04","Reused without rerunning","Access failures and provenance limits preserved","Not read or performed"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_OR/pass-04","facets":{"geography":["us","us-or"],"debt_type":[],"stage":[],"subject":[]},"scope":"BoundedP3printedpage/index/source-history/order-continuationwording corrections only; fullfunds/currentness/overlap/broaderholdsunchanged.","pending_corrections":0},"markdown":"# S_OR PASS-04 — bounded PASS-03 source-pinpoint and order-wording correction\n\n**Fresh targeted access date:** October 25, 2026, Pacific time.\n**Mode/model:** Regular Chat, GPT-5.6 Sol Pro, the highest verified authorized quality-first model available in this session.\n**Review character:** Researcher correction only. This is not an independent review, parent acceptance, full consumer-funds rerun, current-law certification, provider approval, or publication approval.\n\nPASS-01, PASS-02, and PASS-03 remain immutable except for the precise source, pinpoint, and wording replacements below. The saved arithmetic, prior Example 8 money-state distinction, fee holds, federal corrections, and all broader open dimensions remain unchanged.\n\n## 1. Old → corrected patch index\n\n| Original P3 ID / section | Old or incomplete treatment | Corrected treatment | Reason |\n| --- | --- | --- | --- |\n| **S_OR-P3-S002** | Mixed printed pages with zero-based PDF page indices, including §8 as “pp.9–10,” §11 as “pp.12–13,” and §15 as “p.16.” | Use both numbering systems expressly: §5 printed pp.5–8 / PDF indices 4–7; §6 printed pp.8–9 / indices 7–8; §7 printed pp.9–10 / indices 8–9; §8 printed pp.10–11 / indices 9–10; §11 printed pp.13–14 / indices 12–13; §§12–14 printed pp.14–17 / indices 13–16; §15 printed p.17 / index 16. Only the unbracketed operative 2009 enactment language is used; bracketed deleted text is not operative evidence. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled?utm_source=chatgpt.com) | Printed page 1 corresponds to PDF index 0; the earlier P3 row sometimes treated the zero-based PDF index as though it were the printed page. |\n| **S_OR-P3-C003** | S002 “§8, pp.9–10.” | S002 §8(1)–(2), **printed pp.10–11 / PDF indices 9–10**, particularly the separate-or-pooled-account language that begins on printed p.10 and continues on printed p.11. [Oregon Legislative Information System+1](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | Pinpoint correction only; claim substance is unchanged. |\n| **S_OR-P3-C004** | S002 “§11, p.13.” | S002 §11, enacted ORS 697.707(4)(e)–(f), **printed p.14 / PDF index 13**. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | The noncustodial account and no-custody/control/access clauses are on printed page 14. |\n| **S_OR-P3-C008** | S002 “§8, pp.9–10.” | S002 §8(3), **printed p.11 / PDF index 10**, requiring deposit of specified consumer funds into the trust and disbursement of consumer-behalf payments, including provider fees or charges, from the trust. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | Exact operative subsection is on printed page 11. |\n| **S_OR-P3-C011** | S002 “§8, p.10.” | S002 §8(5), **printed p.11 / PDF index 10**, containing the $250,000 single-consumer cap. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | The cap is not on printed page 10. |\n| **S_OR-P3-C023** | S002 “§15, p.16.” | S002 §15, enacted ORS 697.762(1), **printed p.17 / PDF index 16**, containing the court’s receiver-or-conservator authority. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | The earlier number was the zero-based PDF index, not the printed page. |\n| **S_OR-P3-C016** | S002 “§7,” without exact page/index. | Pinpoint completion only: S002 §7, **printed pp.9–10 / PDF indices 8–9**. The operative recordkeeping additions begin on printed p.9 and continue onto printed p.10. [Oregon Legislative Information System+1](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | No substantive change; exact locator supplied. |\n| **P3 §5.4 / S014** | Described the 2023 order as allowing a “bounded fee-free wind-down.” | Replace with **fee-free continuation of a fixed existing-contract population**: Order 18 permits continued servicing without fees only for Oregon contracts active as of the order’s effective date; Order 19 bars other Oregon money-transmission operations absent the stated license or opinion route; Order 24 expressly says those active contracts need not be terminated if no respondent fees are charged. No new customers, general operating right, expiry date, or current license is inferred. [Oregon Division of Financial Regulation+2](https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf) | “Wind-down” incorrectly suggests required termination or a defined expiration that the order does not state. |\n| **S013 / S014 relationship** | Presented as two agency-order examples without expressly identifying that the 2023 order involved the prior respondent’s renamed corporate history. | The 2023 caption identifies Set Forth, Inc. as formerly Forth, Inc. and Debt Pay Gateway, Inc.; paragraphs 2–3 expressly identify the September 29, 2022 order as the prior enforcement action involving the respondent. These are two successive orders in the same respondent history, not two independent provider examples. [Oregon Division of Financial Regulation+1](https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf) | Necessary provenance limitation for the weight assigned to C026. |\n| **S_OR-P3-C026** | Said DFR classified the conduct in “the Debt Pay Gateway and Set Forth orders,” without the same-respondent limitation. | Preserve the conduct classification, but state that DFR applied it in a 2022 order against Debt Pay Gateway and a 2023 successor order against Set Forth, formerly Debt Pay Gateway. Both are consent orders entered without admission or denial and are case-specific, not controlling judicial precedent or two independent market examples. [Oregon Division of Financial Regulation+4](https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf) | Corrects source independence and precedential-weight implications. |\n| **S_OR-P3-C027** | Correctly held the registered-DMSP/Chapter 717 overlap unresolved, but the order-source limitation was not fully explicit. | Assertion remains unresolved. Add that both orders concern the same administrator history and arrangements with debt-management entities stated in the orders to be unregistered; neither order announces a universal rule that every registered custodial DMSP needs a separate Chapter 717 license. [Oregon Division of Financial Regulation+3](https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf) | Preserves the existing hold and prevents overreading the consent orders. |\n| **S_OR-P3-S001** | Said the rule history showed the trust definition “effective January 1, 2012.” | The current display contains the operative OAR 441-910-0000(5) trust definition and lists FCS 12-2011 as filed December 15, 2011 and effective January 1, 2012, along with earlier history entries. That history list alone does **not** establish that the exact subsection (5) wording was first adopted on January 1, 2012 or identify what FCS 12-2011 changed. [Oregon Secretary of State](https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179) | No rulemaking-file comparison was performed. |\n| **S_OR-P3-S009 / P3 §5.5** | Correctly said an informal opinion is not a rule or order and does not bind courts or third parties, but omitted the separate Director/requester effect. | OAR 441-001-0040(5) says such responses do not constitute rules or orders and do not bind courts or third parties; subsection (5)(f) separately says they bind the Director and requester on the facts presented unless altered or set aside by a court. No request, opinion, approval, or provider-specific protection was obtained. [Oregon Secretary of State+1](https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112) | The two binding propositions operate together and should not be collapsed into “entirely nonbinding.” |\n| **P3 §5.5 / S_OR-P3-C025** | Paraphrased ORS 717.210(2) as allowing waiver where “another Oregon law or agency” supplies adequate regulation. | Use the actual formulation: the Director may modify or waive the identified Chapter 717 provisions if adequate regulation is provided **“by law or by another agency of this state.”** The phrase “by law” is not narrowed here to Oregon law. No individual waiver was established. [OregonLaws](https://oregon.public.law/statutes/ors_717.210) | Precision correction to the statutory paraphrase. |\n\n### S002 usages checked but not changed\n\n- **C012:** §5 agreement clauses at printed pp.5–6 were already correctly located.\n- **C020:** §5 cancellation language at printed pp.6–7 was already correctly located.\n- Neither claim is replaced in PASS-04.\n\n## 2. Corrected affected source cells\n\n### S_OR-P3-S002 — replacement source cell\n\n| Field | Corrected entry |\n| --- | --- |\n| **Source ID** | **S_OR-P3-S002** |\n| **Title / issuer** | Enrolled HB 2191-B, Oregon Laws 2009, chapter 604 — Oregon Legislative Assembly |\n| **Direct literal URL** | https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled |\n| **Supplemental official access route** | https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191 |\n| **Exact corrected pinpoints** | §5: printed pp.5–8 / PDF indices 4–7; §6: printed pp.8–9 / indices 7–8; §7: printed pp.9–10 / indices 8–9; §8: printed pp.10–11 / indices 9–10; §11: printed pp.13–14 / indices 12–13; §§12–14: printed pp.14–17 / indices 13–16; §15: printed p.17 / index 16. Specific corrected clauses: §8(2) printed pp.10–11 / indices 9–10; §8(3) and (5) printed p.11 / index 10; §11(4)(e)–(f) printed p.14 / index 13; §15/ORS 697.762(1) printed p.17 / index 16. [Oregon Legislative Information System+4](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) |\n| **Actual PASS-04 access** | **Fresh official PDF, targeted read.** The overview page and its Enrolled link were opened, and the affected printed-page footers and operative clauses were checked in parsed text and selected page images. The coordinator’s earlier initial direct-route failure remains part of the access history; it is not overwritten by the later successful route. [Oregon Legislative Information System+1](https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191) |\n| **Limits** | Selected clauses only; not all 28 pages, not every page image, and not a current Chapter 697 amendment chain. Bracketed deleted language in the enrolled amendment format is not used as operative enacted language. |\n\n### S_OR-P3-S001 — replacement source-status cell\n\n| Field | Corrected entry |\n| --- | --- |\n| **Source ID** | **S_OR-P3-S001** |\n| **Title / issuer** | OAR Chapter 441, Division 910 — Oregon Secretary of State |\n| **Direct literal URL** | https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179 |\n| **Exact material relevant to this correction** | Current OAR 441-910-0000(5) trust-account definition; history entries FCS 12-2011, filed December 15, 2011, certified effective January 1, 2012; FCS 13-2009, effective January 1, 2010; and earlier entries. Current operative OAR 441-910-0080 and 441-910-0200 support remains unchanged. [Oregon Secretary of State+2](https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179) |\n| **Actual PASS-04 access** | **Fresh official current-rule display, targeted reread.** |\n| **Corrected history qualification** | The displayed history establishes that FCS 12-2011 was an effective filing in the rule’s history. Without reading and comparing the filing, it does not establish that the precise current trust-account definition was first created—or wholly replaced—on that date. |\n| **Limits** | No all-rulemaking-file audit, filing comparison, or historical text reconstruction. P3’s current operative-definition support remains intact. |\n\n### S_OR-P3-S009 — replacement source/access cell\n\n| Field | Corrected entry |\n| --- | --- |\n| **Source ID** | **S_OR-P3-S009** |\n| **Title / issuer** | OAR 441-001-0040, Requests for Opinions and Interpretations — Oregon Secretary of State |\n| **Original direct literal URL** | https://secure.sos.state.or.us/oard/view.action?ruleNumber=441-001-0040 |\n| **Fresh successful supplemental locator** | https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112 |\n| **Exact material read** | OAR 441-001-0040(1)–(6), including request definition, submission requirements, permissible responses, revision/declination provisions, subsection (5)’s no-rule/no-order and court/third-party limitations, subsection (5)(f)’s Director/requester binding effect on the facts presented, declaratory-ruling option, and displayed history. [Oregon Secretary of State+2](https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112) |\n| **Access history** | The original P3 researcher-access statement remains preserved. The coordinator later reported that the rule-number route failed. A fresh PASS-04 attempt at that direct route also returned inaccessible, while the ordinary official Division 1 locator succeeded. These are distinct access events; none is retroactively substituted for another. (Invalid URL) |\n| **Limits** | No request was submitted; no informal opinion, exemption confirmation, Director approval, declaratory ruling, or provider-specific protection exists in this record. |\n\n### S_OR-P3-S011 — corrected subsection (2) usage\n\n| Field | Corrected entry |\n| --- | --- |\n| **Source ID** | **S_OR-P3-S011** |\n| **Title / issuer** | ORS 717.210, exemptions; waiver; rules — current-readable secondary section text |\n| **Direct literal URL** | https://oregon.public.law/statutes/ors_717.210 |\n| **Exact material used** | ORS 717.210(2): modification or waiver by rule or order where the Director determines adequate regulation is provided **by law or by another agency of this state**. ORS 717.210(3) separately addresses temporary suspension while an exemption is considered. [OregonLaws](https://oregon.public.law/statutes/ors_717.210) |\n| **Actual PASS-04 access** | **Fresh secondary read.** |\n| **Limits** | The official current Chapter 717 route and complete amendment chain remain held. No source-absence inference and no person-specific waiver finding. Current OAR 441-745-0010 independently permits waiver or modification of a particular rule only when not contrary to Chapter 717. [Oregon Secretary of State](https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2162) |\n\n### S_OR-P3-S013 — replacement source cell\n\n| Field | Corrected entry |\n| --- | --- |\n| **Source ID** | **S_OR-P3-S013** |\n| **Title / issuer** | Debt Pay Gateway, Inc., Case MT-21-0034 — Oregon Division of Financial Regulation |\n| **Direct literal URL** | https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf |\n| **Exact PASS-04 pinpoints** | Caption and no-admission/no-denial recital: printed p.1 / PDF index 0. Findings 3–4: printed p.2 / index 1. Findings 5–7, conclusions 8–10, and beginning of Order 12: printed p.3 / index 2. Order 14(C)–(F), including refund directions: printed pp.4–5 / indices 3–4. Final-order paragraph and September 29, 2022 date: printed p.6 / index 5. [Oregon Division of Financial Regulation+5](https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf) |\n| **Actual PASS-04 access** | **Fresh official order, targeted parsed-text and page-image review.** |\n| **Corrected limit** | The former “pp.1–5” source description did not encompass the printed p.6 order date and was imprecise regarding all refund clauses. PASS-04 does not claim those additional pages had already been read during P3. Consent order without admission or denial; case-specific; not controlling judicial precedent. |\n\n### S_OR-P3-S014 — replacement source cell\n\n| Field | Corrected entry |\n| --- | --- |\n| **Source ID** | **S_OR-P3-S014** |\n| **Title / issuer** | Set Forth, Inc. (formerly Forth, Inc. and Debt Pay Gateway, Inc.), Case MT-23-0037 — Oregon Division of Financial Regulation |\n| **Direct literal URL** | https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf |\n| **Exact PASS-04 pinpoints** | Caption, former names, and no-admission/no-denial recital: printed p.1 / PDF index 0. Prior-action paragraphs 2–3 and beginning of current findings: printed p.2 / index 1. Findings 5–9 and beginning of conclusions: printed p.3 / index 2. Order 18 begins on printed p.4 / index 3 and continues to printed p.5 / index 4; Order 19 is on printed p.5 / index 4. Orders 18–21 extend across printed pp.4–6 / indices 3–5. Order 21’s refund provisions continue through printed p.6 / index 5. Order 24’s no-required-termination condition is on printed p.8 / index 7. Final-order paragraph and December 28, 2023 date are on printed p.9 / index 8. [Oregon Division of Financial Regulation+7](https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf) |\n| **Actual PASS-04 access** | **Fresh official order, targeted parsed-text and page-image review.** |\n| **Corrected limit** | This is a later order in the same respondent history as S013, not a second independent provider example. The fee-free continuation applies only to active Oregon contracts as of the effective date; it does not establish a general operating right, new-customer right, expiry, current license, or universal registered-DMSP dual-license rule. Consent order without admission or denial; case-specific; not controlling judicial precedent. |\n\n## 3. Corrected affected claim cells\n\n| Existing claim ID | Full corrected assertion | Corrected sources and exact pinpoints | Conditions and confidence limits |\n| --- | --- | --- | --- |\n| **S_OR-P3-C003** | A custodial provider may establish either a separate trust account for each consumer or a single pooled trust account. If one pooled account is used, the provider must maintain a separate ledger or other receipt-and-disbursement record for each consumer whose funds are held. | S_OR-P3-S002, HB 2191 §8(1)–(2), printed pp.10–11 / PDF indices 9–10; current-readable ORS 697.682(1)–(2) remains the separate current-text support. [Oregon Legislative Information System+1](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | Substantive claim unchanged. Historical enactment is not a complete current amendment chain. |\n| **S_OR-P3-C004** | The statutory noncustodial branch requires the consumer to establish and maintain the specifically designated insured-institution account in the consumer’s own name; provider fee withdrawal requires specific authorization; and the provider must lack custody, control, separate access, or additional access. | S_OR-P3-S002, HB 2191 §11, enacted ORS 697.707(4)(e)–(f), printed p.14 / PDF index 13. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | Account title or “independent administrator” label alone remains insufficient. No actual account facts were supplied. |\n| **S_OR-P3-C008** | For the custodial branch, the 2009 enactment requires the specified consumer/property funds received by the provider to be deposited into the trust account and requires consumer-behalf payments, including provider fees or charges, to be disbursed from that account. | S_OR-P3-S002, HB 2191 §8(3), printed p.11 / PDF index 10. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | This does not decide whether, when, or how much of any provider fee is lawfully earned or collectible. |\n| **S_OR-P3-C011** | The 2009 enactment states that a provider may not deposit more than $250,000 in consumer funds in a trust account on behalf of one consumer. | S_OR-P3-S002, HB 2191 §8(5), printed p.11 / PDF index 10. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | No FDIC pass-through, aggregation, or current amendment-chain conclusion is added. |\n| **S_OR-P3-C016** | Providers must retain the specified per-consumer records, including accounting and disbursement records, subject to the established retention framework. | Historical support pinpoint completed as S_OR-P3-S002, HB 2191 §7, printed pp.9–10 / PDF indices 8–9; current OAR 441-910-0200 support remains unchanged. [Oregon Legislative Information System+2](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | Wording unchanged; pinpoint completion only. |\n| **S_OR-P3-C023** | In a Director enforcement suit, a court may appoint a receiver or conservator for the defendant or the defendant’s assets upon a proper showing; the reviewed provisions do not create an automatic insolvency receivership or distribution waterfall. | S_OR-P3-S002, HB 2191 §15, enacted ORS 697.762(1), printed p.17 / PDF index 16. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled) | Historical enactment pinpoint corrected; full current remedies and receivership law remain outside this pass. |\n| **S_OR-P3-C025** | Chapter 717 lists specified institutional, escrow, and authorized-delegate exemptions but no express registered-DMSP exemption in the text reviewed. ORS 717.210(2) authorizes the Director by rule or order to modify or waive the identified provisions where adequate regulation is provided **by law or by another agency of this state**. OAR 441-745-0010 separately permits waiver or modification of a particular rule only when not contrary to Chapter 717. | S_OR-P3-S011, ORS 717.210(1)–(2); S_OR-P3-S008, OAR 441-745-0010. [OregonLaws+1](https://oregon.public.law/statutes/ors_717.210) | Official current Chapter 717 authentication remains held. No individual waiver, rule, order, license, or authorized-delegate status was established. |\n| **S_OR-P3-C026** | DFR classified the described ACH collection, custodial deposit, creditor disbursement, designated-company fee payment, third-party payment, and payment-instruction conduct as money transmission in a September 29, 2022 consent order against Debt Pay Gateway and again in a December 28, 2023 successor consent order against Set Forth, formerly Debt Pay Gateway. | S013: findings 3–7 printed pp.2–3 / PDF indices 1–2; conclusions 8–10 printed p.3 / index 2; date printed p.6 / index 5. S014: caption printed p.1 / index 0; prior-action ¶¶2–3 printed p.2 / index 1; findings 4–9 printed pp.2–3 / indices 1–2; date printed p.9 / index 8. [Oregon Division of Financial Regulation+6](https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf) | Two successive orders in one respondent history, not two independent provider examples. Both were entered without admission or denial and are not controlling judicial precedent. |\n| **S_OR-P3-C027** | The reviewed authorities still do not resolve whether a properly registered custodial DMSP itself always needs a separate Chapter 717 license. | Chapter 697 custody architecture; Chapter 717 gateway; S013 and S014 as now limited. The 2023 order’s ¶¶2–3 connect it to the 2022 respondent history, and the orders’ footnotes state that the associated debt-management entities were unregistered. [Oregon Division of Financial Regulation+3](https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf) | **Unresolved.** The orders do not announce a universal registered-DMSP dual-license holding. No provider-specific current status was searched. |\n\n## 4. Replacement for P3 §5.4 order wording\n\nThe following replaces only the inaccurate “bounded fee-free wind-down” phrasing:\n\nThe December 28, 2023 Set Forth order permitted the respondent to continue servicing, without charging respondent fees, Oregon Consumer Contracts that were active as of the order’s effective date. Except for that fixed existing-contract population, Order 19 barred Oregon money-transmission operations unless the respondent first obtained an Oregon money-transmitter license or the identified OAR 441-001-0040 opinion. Order 24 expressly stated that the active contracts did not have to be terminated, provided no respondent fees were charged. The order therefore establishes a fee-free continuation exception for a defined existing population—not a mandatory wind-down, a right to add new Oregon consumers, a general operating authorization, a stated continuation expiry, or evidence of current licensure. [Oregon Division of Financial Regulation+2](https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf)\n\nThe 2023 caption and paragraphs 2–3 also establish that Set Forth was formerly Debt Pay Gateway and that the 2022 consent order was the prior enforcement action involving the same respondent history. [Oregon Division of Financial Regulation+1](https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf)\n\n## 5. Minimum new source-usage rows\n\nThese rows record newly used access routes. They do **not** increase the count of independent underlying authorities.\n\n| New usage ID | Nature | Literal URL | Exact use and limitation |\n| --- | --- | --- | --- |\n| **S_OR-P4-S001** | Supplemental official access-route record for existing S_OR-P3-S002 | https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191 | Freshly opened October 25, 2026. The official overview identifies HB 2191, Chapter 604, and supplies the Enrolled document link. It is an access/discovery route to S002, not a separate enactment authority. [Oregon Legislative Information System](https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191) |\n| **S_OR-P4-S002** | Supplemental official current-rule locator for existing S_OR-P3-S009 | https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112 | Freshly opened October 25, 2026. Complete OAR 441-001-0040(1)–(6) and displayed history were read through this Division 1 page after the direct rule-number route failed. It is the same underlying rule, not a new authority. [Oregon Secretary of State+1](https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112) |\n\n## 6. Coverage and gap disposition\n\n| Correction group | PASS-04 disposition | What is now resolved | What remains expressly held |\n| --- | --- | --- | --- |\n| **1. HB 2191 printed-page versus PDF-index pinpoints** | **Corrected** | S002 page mapping; C003, C004, C008, C011, and C023 exact pinpoints; C016 pinpoint completion. C012 and C020 confirmed unchanged. | Current official Chapter 697 authentication, complete amendment chain, all 28 HB pages, and every historical filing remain unreviewed. Bracketed deleted language is not operative evidence. |\n| **2. Set Forth / Debt Pay Gateway wording and provenance** | **Corrected with source-weight limitation** | “Wind-down” replaced by fee-free continuation for active contracts as of the effective date; no-termination clause surfaced; exact order/date pages supplied; same-respondent history made explicit. | No current license lookup, provider authorization, new-customer right, continuation expiry, universal dual-license holding, controlling precedent, or independent second-provider example. C027 remains unresolved. |\n| **3. Division 910 history and OAR 441-001-0040 access/binding effect** | **Corrected** | Current operative trust definition remains supported; history label narrowed; successful Division 1 locator supplied; Director/requester versus court/third-party binding distinction corrected. | No all-rulemaking-file audit, no proof of exact first-adoption date for the trust definition, and no opinion request, approval, exemption, or declaratory ruling. |\n| **4. ORS 717.210(2) paraphrase** | **Corrected** | The exact formulation is “provided by law or by another agency of this state”; OAR 441-745-0010’s anti-contradiction limitation remains supported. | Official current Chapter 717 route and amendment chain, individual waiver, provider license, authorized-delegate status, and registered-DMSP/Chapter 717 overlap remain held. |\n| **All other PASS-03 coverage and gaps** | **Unchanged** | None reopened. | Current ORS chain; CPI and nominal fee currentness; savings-discharge timing; credit-only and alternative-repayment issues; attorney/nonprofit scope; actual provider, bank, ACH, contract, insurance, interest, setoff, priority, shortage, reconciliation, closeout, insolvency, credit-union, exempt-actor, bond, remedies, collection, limitations, case-law, secured-debt, sector, local, tribal, federal-applicability, and parent-state dimensions all remain open exactly as previously recorded. |\n\n## 7. Researcher self-check\n\n### Freshly read or visually inspected for PASS-04\n\n- Official HB 2191 overview page and the Enrolled PDF.\n- Targeted HB 2191 section starts, printed-page footers, and affected operative clauses:§8 printed pp.10–11;§11(4)(e)–(f) printed p.14;§15 printed p.17;section-location text needed to map §§5–15.\n- Set Forth order:caption and former names;no-admission/no-denial recital;paragraphs 2–9;Orders 18–21;Order 24;final-order date.\n- Debt Pay Gateway order:caption and no-admission/no-denial recital;findings 3–7;conclusions 8–10;refund-related Order 14 provisions;final-order date.\n- Current displayed OAR 441-910-0000(5) and its displayed rule history.\n- Complete displayed OAR 441-001-0040(1)–(6) and history through the Division 1 locator.\n- ORS 717.210(2) through the same current-readable secondary route used in P3.\n- Current OAR 441-745-0010.\n\n### Reused without rerunning\n\n- All unaffected PASS-03 substantive consumer-funds findings.\n- All nine pooled-ledger cells and prior arithmetic.\n- PASS-02’s two distinct Example 8 money states.\n- Earlier fee, savings-discharge, credit-only, federal, provider, currentness, contract, and market-access holds.\n- C012 and C020’s already-correct HB 2191 printed-page ranges.\n\n### Access failures and provenance limits preserved\n\n- The original OAR rule-number URL for 441-001-0040 was inaccessible during the fresh PASS-04 attempt; the official Division 1 locator worked.\n- The earlier coordinator direct-route failure for HB 2191 is preserved; the subsequent overview-link route succeeded.\n- No direct-source failure was converted into evidence that an amendment, waiver, opinion, license, or exception does not exist.\n- No historical access date or secondary-codification label was retroactively upgraded.\n\n### Not read or performed\n\n- All 28 pages of HB 2191 as a complete fresh review.\n- A complete current Chapter 697 or 717 official amendment chain.\n- Every page and every clause of either consent order for unrelated issues.\n- Rulemaking filing packets for OAR 441-910-0000.\n- Any current named-provider, money-transmitter, NMLS, bank, administrator, or contract lookup.\n- Any application, filing, contact, purchase, account change, private-record access, Chrome control, other Chat, local write, site action, or publication action.\n\n**END S_OR PASS-04**\n\n","tables":[{"headers":["Original P3 ID / section","Old or incomplete treatment","Corrected treatment","Reason"],"index":0,"links":[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled?utm_source=chatgpt.com","text":"Oregon Legislative Information System"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+1"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+1"},{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+2"},{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+1"},{"href":"https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+4"},{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+3"},{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179","text":"Oregon Secretary of State"},{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112","text":"Oregon Secretary of State\n+1"},{"href":"https://oregon.public.law/statutes/ors_717.210","text":"OregonLaws"}],"row_links":[[],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled?utm_source=chatgpt.com","text":"Oregon Legislative Information System"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+1"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+1"}],[{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+2"}],[{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+1"}],[{"href":"https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+4"}],[{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+3"}],[{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179","text":"Oregon Secretary of State"}],[{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112","text":"Oregon Secretary of State\n+1"}],[{"href":"https://oregon.public.law/statutes/ors_717.210","text":"OregonLaws"}]],"rows":[["Original P3 ID / section","Old or incomplete treatment","Corrected treatment","Reason"],["S_OR-P3-S002","Mixed printed pages with zero-based PDF page indices, including §8 as “pp.9–10,” §11 as “pp.12–13,” and §15 as “p.16.”","Use both numbering systems expressly: §5 printed pp.5–8 / PDF indices 4–7; §6 printed pp.8–9 / indices 7–8; §7 printed pp.9–10 / indices 8–9; §8 printed pp.10–11 / indices 9–10; §11 printed pp.13–14 / indices 12–13; §§12–14 printed pp.14–17 / indices 13–16; §15 printed p.17 / index 16. Only the unbracketed operative 2009 enactment language is used; bracketed deleted text is not operative evidence. \nOregon Legislative Information System","Printed page 1 corresponds to PDF index 0; the earlier P3 row sometimes treated the zero-based PDF index as though it were the printed page."],["S_OR-P3-C003","S002 “§8, pp.9–10.”","S002 §8(1)–(2), printed pp.10–11 / PDF indices 9–10, particularly the separate-or-pooled-account language that begins on printed p.10 and continues on printed p.11. \nOregon Legislative Information System\n+1","Pinpoint correction only; claim substance is unchanged."],["S_OR-P3-C004","S002 “§11, p.13.”","S002 §11, enacted ORS 697.707(4)(e)–(f), printed p.14 / PDF index 13. \nOregon Legislative Information System","The noncustodial account and no-custody/control/access clauses are on printed page 14."],["S_OR-P3-C008","S002 “§8, pp.9–10.”","S002 §8(3), printed p.11 / PDF index 10, requiring deposit of specified consumer funds into the trust and disbursement of consumer-behalf payments, including provider fees or charges, from the trust. \nOregon Legislative Information System","Exact operative subsection is on printed page 11."],["S_OR-P3-C011","S002 “§8, p.10.”","S002 §8(5), printed p.11 / PDF index 10, containing the $250,000 single-consumer cap. \nOregon Legislative Information System","The cap is not on printed page 10."],["S_OR-P3-C023","S002 “§15, p.16.”","S002 §15, enacted ORS 697.762(1), printed p.17 / PDF index 16, containing the court’s receiver-or-conservator authority. \nOregon Legislative Information System","The earlier number was the zero-based PDF index, not the printed page."],["S_OR-P3-C016","S002 “§7,” without exact page/index.","Pinpoint completion only: S002 §7, printed pp.9–10 / PDF indices 8–9. The operative recordkeeping additions begin on printed p.9 and continue onto printed p.10. \nOregon Legislative Information System\n+1","No substantive change; exact locator supplied."],["P3 §5.4 / S014","Described the 2023 order as allowing a “bounded fee-free wind-down.”","Replace with fee-free continuation of a fixed existing-contract population: Order 18 permits continued servicing without fees only for Oregon contracts active as of the order’s effective date; Order 19 bars other Oregon money-transmission operations absent the stated license or opinion route; Order 24 expressly says those active contracts need not be terminated if no respondent fees are charged. No new customers, general operating right, expiry date, or current license is inferred. \nOregon Division of Financial Regulation\n+2","“Wind-down” incorrectly suggests required termination or a defined expiration that the order does not state."],["S013 / S014 relationship","Presented as two agency-order examples without expressly identifying that the 2023 order involved the prior respondent’s renamed corporate history.","The 2023 caption identifies Set Forth, Inc. as formerly Forth, Inc. and Debt Pay Gateway, Inc.; paragraphs 2–3 expressly identify the September 29, 2022 order as the prior enforcement action involving the respondent. These are two successive orders in the same respondent history, not two independent provider examples. \nOregon Division of Financial Regulation\n+1","Necessary provenance limitation for the weight assigned to C026."],["S_OR-P3-C026","Said DFR classified the conduct in “the Debt Pay Gateway and Set Forth orders,” without the same-respondent limitation.","Preserve the conduct classification, but state that DFR applied it in a 2022 order against Debt Pay Gateway and a 2023 successor order against Set Forth, formerly Debt Pay Gateway. Both are consent orders entered without admission or denial and are case-specific, not controlling judicial precedent or two independent market examples. \nOregon Division of Financial Regulation\n+4","Corrects source independence and precedential-weight implications."],["S_OR-P3-C027","Correctly held the registered-DMSP/Chapter 717 overlap unresolved, but the order-source limitation was not fully explicit.","Assertion remains unresolved. Add that both orders concern the same administrator history and arrangements with debt-management entities stated in the orders to be unregistered; neither order announces a universal rule that every registered custodial DMSP needs a separate Chapter 717 license. \nOregon Division of Financial Regulation\n+3","Preserves the existing hold and prevents overreading the consent orders."],["S_OR-P3-S001","Said the rule history showed the trust definition “effective January 1, 2012.”","The current display contains the operative OAR 441-910-0000(5) trust definition and lists FCS 12-2011 as filed December 15, 2011 and effective January 1, 2012, along with earlier history entries. That history list alone does not establish that the exact subsection (5) wording was first adopted on January 1, 2012 or identify what FCS 12-2011 changed. \nOregon Secretary of State","No rulemaking-file comparison was performed."],["S_OR-P3-S009 / P3 §5.5","Correctly said an informal opinion is not a rule or order and does not bind courts or third parties, but omitted the separate Director/requester effect.","OAR 441-001-0040(5) says such responses do not constitute rules or orders and do not bind courts or third parties; subsection (5)(f) separately says they bind the Director and requester on the facts presented unless altered or set aside by a court. No request, opinion, approval, or provider-specific protection was obtained. \nOregon Secretary of State\n+1","The two binding propositions operate together and should not be collapsed into “entirely nonbinding.”"],["P3 §5.5 / S_OR-P3-C025","Paraphrased ORS 717.210(2) as allowing waiver where “another Oregon law or agency” supplies adequate regulation.","Use the actual formulation: the Director may modify or waive the identified Chapter 717 provisions if adequate regulation is provided “by law or by another agency of this state.” The phrase “by law” is not narrowed here to Oregon law. No individual waiver was established. \nOregonLaws","Precision correction to the statutory paraphrase."]]},{"headers":["Field","Corrected entry"],"index":1,"links":[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+4"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191","text":"Oregon Legislative Information System\n+1"}],"row_links":[[],[],[],[],[],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+4"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191","text":"Oregon Legislative Information System\n+1"}],[]],"rows":[["Field","Corrected entry"],["Source ID","S_OR-P3-S002"],["Title / issuer","Enrolled HB 2191-B, Oregon Laws 2009, chapter 604 — Oregon Legislative Assembly"],["Direct literal URL","https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled"],["Supplemental official access route","https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191"],["Exact corrected pinpoints","§5: printed pp.5–8 / PDF indices 4–7; §6: printed pp.8–9 / indices 7–8; §7: printed pp.9–10 / indices 8–9; §8: printed pp.10–11 / indices 9–10; §11: printed pp.13–14 / indices 12–13; §§12–14: printed pp.14–17 / indices 13–16; §15: printed p.17 / index 16. Specific corrected clauses: §8(2) printed pp.10–11 / indices 9–10; §8(3) and (5) printed p.11 / index 10; §11(4)(e)–(f) printed p.14 / index 13; §15/ORS 697.762(1) printed p.17 / index 16. \nOregon Legislative Information System\n+4"],["Actual PASS-04 access","Fresh official PDF, targeted read. The overview page and its Enrolled link were opened, and the affected printed-page footers and operative clauses were checked in parsed text and selected page images. The coordinator’s earlier initial direct-route failure remains part of the access history; it is not overwritten by the later successful route. \nOregon Legislative Information System\n+1"],["Limits","Selected clauses only; not all 28 pages, not every page image, and not a current Chapter 697 amendment chain. Bracketed deleted language in the enrolled amendment format is not used as operative enacted language."]]},{"headers":["Field","Corrected entry"],"index":2,"links":[{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179","text":"Oregon Secretary of State\n+2"}],"row_links":[[],[],[],[],[{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179","text":"Oregon Secretary of State\n+2"}],[],[],[]],"rows":[["Field","Corrected entry"],["Source ID","S_OR-P3-S001"],["Title / issuer","OAR Chapter 441, Division 910 — Oregon Secretary of State"],["Direct literal URL","https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179"],["Exact material relevant to this correction","Current OAR 441-910-0000(5) trust-account definition; history entries FCS 12-2011, filed December 15, 2011, certified effective January 1, 2012; FCS 13-2009, effective January 1, 2010; and earlier entries. Current operative OAR 441-910-0080 and 441-910-0200 support remains unchanged. \nOregon Secretary of State\n+2"],["Actual PASS-04 access","Fresh official current-rule display, targeted reread."],["Corrected history qualification","The displayed history establishes that FCS 12-2011 was an effective filing in the rule’s history. Without reading and comparing the filing, it does not establish that the precise current trust-account definition was first created—or wholly replaced—on that date."],["Limits","No all-rulemaking-file audit, filing comparison, or historical text reconstruction. P3’s current operative-definition support remains intact."]]},{"headers":["Field","Corrected entry"],"index":3,"links":[{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112","text":"Oregon Secretary of State\n+2"}],"row_links":[[],[],[],[],[],[{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112","text":"Oregon Secretary of State\n+2"}],[],[]],"rows":[["Field","Corrected entry"],["Source ID","S_OR-P3-S009"],["Title / issuer","OAR 441-001-0040, Requests for Opinions and Interpretations — Oregon Secretary of State"],["Original direct literal URL","https://secure.sos.state.or.us/oard/view.action?ruleNumber=441-001-0040"],["Fresh successful supplemental locator","https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112"],["Exact material read","OAR 441-001-0040(1)–(6), including request definition, submission requirements, permissible responses, revision/declination provisions, subsection (5)’s no-rule/no-order and court/third-party limitations, subsection (5)(f)’s Director/requester binding effect on the facts presented, declaratory-ruling option, and displayed history. \nOregon Secretary of State\n+2"],["Access history","The original P3 researcher-access statement remains preserved. The coordinator later reported that the rule-number route failed. A fresh PASS-04 attempt at that direct route also returned inaccessible, while the ordinary official Division 1 locator succeeded. These are distinct access events; none is retroactively substituted for another. (Invalid URL)"],["Limits","No request was submitted; no informal opinion, exemption confirmation, Director approval, declaratory ruling, or provider-specific protection exists in this record."]]},{"headers":["Field","Corrected entry"],"index":4,"links":[{"href":"https://oregon.public.law/statutes/ors_717.210","text":"OregonLaws"},{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2162","text":"Oregon Secretary of State"}],"row_links":[[],[],[],[],[{"href":"https://oregon.public.law/statutes/ors_717.210","text":"OregonLaws"}],[],[{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2162","text":"Oregon Secretary of State"}]],"rows":[["Field","Corrected entry"],["Source ID","S_OR-P3-S011"],["Title / issuer","ORS 717.210, exemptions; waiver; rules — current-readable secondary section text"],["Direct literal URL","https://oregon.public.law/statutes/ors_717.210"],["Exact material used","ORS 717.210(2): modification or waiver by rule or order where the Director determines adequate regulation is provided by law or by another agency of this state. ORS 717.210(3) separately addresses temporary suspension while an exemption is considered. \nOregonLaws"],["Actual PASS-04 access","Fresh secondary read."],["Limits","The official current Chapter 717 route and complete amendment chain remain held. No source-absence inference and no person-specific waiver finding. Current OAR 441-745-0010 independently permits waiver or modification of a particular rule only when not contrary to Chapter 717. \nOregon Secretary of State"]]},{"headers":["Field","Corrected entry"],"index":5,"links":[{"href":"https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+5"}],"row_links":[[],[],[],[],[{"href":"https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+5"}],[],[]],"rows":[["Field","Corrected entry"],["Source ID","S_OR-P3-S013"],["Title / issuer","Debt Pay Gateway, Inc., Case MT-21-0034 — Oregon Division of Financial Regulation"],["Direct literal URL","https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf"],["Exact PASS-04 pinpoints","Caption and no-admission/no-denial recital: printed p.1 / PDF index 0. Findings 3–4: printed p.2 / index 1. Findings 5–7, conclusions 8–10, and beginning of Order 12: printed p.3 / index 2. Order 14(C)–(F), including refund directions: printed pp.4–5 / indices 3–4. Final-order paragraph and September 29, 2022 date: printed p.6 / index 5. \nOregon Division of Financial Regulation\n+5"],["Actual PASS-04 access","Fresh official order, targeted parsed-text and page-image review."],["Corrected limit","The former “pp.1–5” source description did not encompass the printed p.6 order date and was imprecise regarding all refund clauses. PASS-04 does not claim those additional pages had already been read during P3. Consent order without admission or denial; case-specific; not controlling judicial precedent."]]},{"headers":["Field","Corrected entry"],"index":6,"links":[{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+7"}],"row_links":[[],[],[],[],[{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+7"}],[],[]],"rows":[["Field","Corrected entry"],["Source ID","S_OR-P3-S014"],["Title / issuer","Set Forth, Inc. (formerly Forth, Inc. and Debt Pay Gateway, Inc.), Case MT-23-0037 — Oregon Division of Financial Regulation"],["Direct literal URL","https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf"],["Exact PASS-04 pinpoints","Caption, former names, and no-admission/no-denial recital: printed p.1 / PDF index 0. Prior-action paragraphs 2–3 and beginning of current findings: printed p.2 / index 1. Findings 5–9 and beginning of conclusions: printed p.3 / index 2. Order 18 begins on printed p.4 / index 3 and continues to printed p.5 / index 4; Order 19 is on printed p.5 / index 4. Orders 18–21 extend across printed pp.4–6 / indices 3–5. Order 21’s refund provisions continue through printed p.6 / index 5. Order 24’s no-required-termination condition is on printed p.8 / index 7. Final-order paragraph and December 28, 2023 date are on printed p.9 / index 8. \nOregon Division of Financial Regulation\n+7"],["Actual PASS-04 access","Fresh official order, targeted parsed-text and page-image review."],["Corrected limit","This is a later order in the same respondent history as S013, not a second independent provider example. The fee-free continuation applies only to active Oregon contracts as of the effective date; it does not establish a general operating right, new-customer right, expiry, current license, or universal registered-DMSP dual-license rule. Consent order without admission or denial; case-specific; not controlling judicial precedent."]]},{"headers":["Existing claim ID","Full corrected assertion","Corrected sources and exact pinpoints","Conditions and confidence limits"],"index":7,"links":[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+1"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+2"},{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"},{"href":"https://oregon.public.law/statutes/ors_717.210","text":"OregonLaws\n+1"},{"href":"https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+6"},{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+3"}],"row_links":[[],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+1"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System\n+2"}],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","text":"Oregon Legislative Information System"}],[{"href":"https://oregon.public.law/statutes/ors_717.210","text":"OregonLaws\n+1"}],[{"href":"https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+6"}],[{"href":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","text":"Oregon Division of Financial Regulation\n+3"}]],"rows":[["Existing claim ID","Full corrected assertion","Corrected sources and exact pinpoints","Conditions and confidence limits"],["S_OR-P3-C003","A custodial provider may establish either a separate trust account for each consumer or a single pooled trust account. If one pooled account is used, the provider must maintain a separate ledger or other receipt-and-disbursement record for each consumer whose funds are held.","S_OR-P3-S002, HB 2191 §8(1)–(2), printed pp.10–11 / PDF indices 9–10; current-readable ORS 697.682(1)–(2) remains the separate current-text support. \nOregon Legislative Information System\n+1","Substantive claim unchanged. Historical enactment is not a complete current amendment chain."],["S_OR-P3-C004","The statutory noncustodial branch requires the consumer to establish and maintain the specifically designated insured-institution account in the consumer’s own name; provider fee withdrawal requires specific authorization; and the provider must lack custody, control, separate access, or additional access.","S_OR-P3-S002, HB 2191 §11, enacted ORS 697.707(4)(e)–(f), printed p.14 / PDF index 13. \nOregon Legislative Information System","Account title or “independent administrator” label alone remains insufficient. No actual account facts were supplied."],["S_OR-P3-C008","For the custodial branch, the 2009 enactment requires the specified consumer/property funds received by the provider to be deposited into the trust account and requires consumer-behalf payments, including provider fees or charges, to be disbursed from that account.","S_OR-P3-S002, HB 2191 §8(3), printed p.11 / PDF index 10. \nOregon Legislative Information System","This does not decide whether, when, or how much of any provider fee is lawfully earned or collectible."],["S_OR-P3-C011","The 2009 enactment states that a provider may not deposit more than $250,000 in consumer funds in a trust account on behalf of one consumer.","S_OR-P3-S002, HB 2191 §8(5), printed p.11 / PDF index 10. \nOregon Legislative Information System","No FDIC pass-through, aggregation, or current amendment-chain conclusion is added."],["S_OR-P3-C016","Providers must retain the specified per-consumer records, including accounting and disbursement records, subject to the established retention framework.","Historical support pinpoint completed as S_OR-P3-S002, HB 2191 §7, printed pp.9–10 / PDF indices 8–9; current OAR 441-910-0200 support remains unchanged. \nOregon Legislative Information System\n+2","Wording unchanged; pinpoint completion only."],["S_OR-P3-C023","In a Director enforcement suit, a court may appoint a receiver or conservator for the defendant or the defendant’s assets upon a proper showing; the reviewed provisions do not create an automatic insolvency receivership or distribution waterfall.","S_OR-P3-S002, HB 2191 §15, enacted ORS 697.762(1), printed p.17 / PDF index 16. \nOregon Legislative Information System","Historical enactment pinpoint corrected; full current remedies and receivership law remain outside this pass."],["S_OR-P3-C025","Chapter 717 lists specified institutional, escrow, and authorized-delegate exemptions but no express registered-DMSP exemption in the text reviewed. ORS 717.210(2) authorizes the Director by rule or order to modify or waive the identified provisions where adequate regulation is provided by law or by another agency of this state. OAR 441-745-0010 separately permits waiver or modification of a particular rule only when not contrary to Chapter 717.","S_OR-P3-S011, ORS 717.210(1)–(2); S_OR-P3-S008, OAR 441-745-0010. \nOregonLaws\n+1","Official current Chapter 717 authentication remains held. No individual waiver, rule, order, license, or authorized-delegate status was established."],["S_OR-P3-C026","DFR classified the described ACH collection, custodial deposit, creditor disbursement, designated-company fee payment, third-party payment, and payment-instruction conduct as money transmission in a September 29, 2022 consent order against Debt Pay Gateway and again in a December 28, 2023 successor consent order against Set Forth, formerly Debt Pay Gateway.","S013: findings 3–7 printed pp.2–3 / PDF indices 1–2; conclusions 8–10 printed p.3 / index 2; date printed p.6 / index 5. S014: caption printed p.1 / index 0; prior-action ¶¶2–3 printed p.2 / index 1; findings 4–9 printed pp.2–3 / indices 1–2; date printed p.9 / index 8. \nOregon Division of Financial Regulation\n+6","Two successive orders in one respondent history, not two independent provider examples. Both were entered without admission or denial and are not controlling judicial precedent."],["S_OR-P3-C027","The reviewed authorities still do not resolve whether a properly registered custodial DMSP itself always needs a separate Chapter 717 license.","Chapter 697 custody architecture; Chapter 717 gateway; S013 and S014 as now limited. The 2023 order’s ¶¶2–3 connect it to the 2022 respondent history, and the orders’ footnotes state that the associated debt-management entities were unregistered. \nOregon Division of Financial Regulation\n+3","Unresolved. The orders do not announce a universal registered-DMSP dual-license holding. No provider-specific current status was searched."]]},{"headers":["New usage ID","Nature","Literal URL","Exact use and limitation"],"index":8,"links":[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191","text":"Oregon Legislative Information System"},{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112","text":"Oregon Secretary of State\n+1"}],"row_links":[[],[{"href":"https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191","text":"Oregon Legislative Information System"}],[{"href":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112","text":"Oregon Secretary of State\n+1"}]],"rows":[["New usage ID","Nature","Literal URL","Exact use and limitation"],["S_OR-P4-S001","Supplemental official access-route record for existing S_OR-P3-S002","https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191","Freshly opened October 25, 2026. The official overview identifies HB 2191, Chapter 604, and supplies the Enrolled document link. It is an access/discovery route to S002, not a separate enactment authority. \nOregon Legislative Information System"],["S_OR-P4-S002","Supplemental official current-rule locator for existing S_OR-P3-S009","https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112","Freshly opened October 25, 2026. Complete OAR 441-001-0040(1)–(6) and displayed history were read through this Division 1 page after the direct rule-number route failed. It is the same underlying rule, not a new authority. \nOregon Secretary of State\n+1"]]},{"headers":["Correction group","PASS-04 disposition","What is now resolved","What remains expressly held"],"index":9,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Correction group","PASS-04 disposition","What is now resolved","What remains expressly held"],["1. HB 2191 printed-page versus PDF-index pinpoints","Corrected","S002 page mapping; C003, C004, C008, C011, and C023 exact pinpoints; C016 pinpoint completion. C012 and C020 confirmed unchanged.","Current official Chapter 697 authentication, complete amendment chain, all 28 HB pages, and every historical filing remain unreviewed. Bracketed deleted language is not operative evidence."],["2. Set Forth / Debt Pay Gateway wording and provenance","Corrected with source-weight limitation","“Wind-down” replaced by fee-free continuation for active contracts as of the effective date; no-termination clause surfaced; exact order/date pages supplied; same-respondent history made explicit.","No current license lookup, provider authorization, new-customer right, continuation expiry, universal dual-license holding, controlling precedent, or independent second-provider example. C027 remains unresolved."],["3. Division 910 history and OAR 441-001-0040 access/binding effect","Corrected","Current operative trust definition remains supported; history label narrowed; successful Division 1 locator supplied; Director/requester versus court/third-party binding distinction corrected.","No all-rulemaking-file audit, no proof of exact first-adoption date for the trust definition, and no opinion request, approval, exemption, or declaratory ruling."],["4. ORS 717.210(2) paraphrase","Corrected","The exact formulation is “provided by law or by another agency of this state”; OAR 441-745-0010’s anti-contradiction limitation remains supported.","Official current Chapter 717 route and amendment chain, individual waiver, provider license, authorized-delegate status, and registered-DMSP/Chapter 717 overlap remain held."],["All other PASS-03 coverage and gaps","Unchanged","None reopened.","Current ORS chain; CPI and nominal fee currentness; savings-discharge timing; credit-only and alternative-repayment issues; attorney/nonprofit scope; actual provider, bank, ACH, contract, insurance, interest, setoff, priority, shortage, reconciliation, closeout, insolvency, credit-union, exempt-actor, bond, remedies, collection, limitations, case-law, secured-debt, sector, local, tribal, federal-applicability, and parent-state dimensions all remain open exactly as previously recorded."]]}],"claims":[{"claim_id":"S_OR-P3-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_OR-P3-C003","Full corrected assertion":"A custodial provider may establish either a separate trust account for each consumer or a single pooled trust account. If one pooled account is used, the provider must maintain a separate ledger or other receipt-and-disbursement record for each consumer whose funds are held.","Corrected sources and exact pinpoints":"S_OR-P3-S002, HB 2191 §8(1)–(2), printed pp.10–11 / PDF indices 9–10; current-readable ORS 697.682(1)–(2) remains the separate current-text support. \nOregon Legislative Information System\n+1","Conditions and confidence limits":"Substantive claim unchanged. Historical enactment is not a complete current amendment chain."},"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_OR-P3-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_OR-P3-C004","Full corrected assertion":"The statutory noncustodial branch requires the consumer to establish and maintain the specifically designated insured-institution account in the consumer’s own name; provider fee withdrawal requires specific authorization; and the provider must lack custody, control, separate access, or additional access.","Corrected sources and exact pinpoints":"S_OR-P3-S002, HB 2191 §11, enacted ORS 697.707(4)(e)–(f), printed p.14 / PDF index 13. \nOregon Legislative Information System","Conditions and confidence limits":"Account title or “independent administrator” label alone remains insufficient. No actual account facts were supplied."},"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_OR-P3-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_OR-P3-C008","Full corrected assertion":"For the custodial branch, the 2009 enactment requires the specified consumer/property funds received by the provider to be deposited into the trust account and requires consumer-behalf payments, including provider fees or charges, to be disbursed from that account.","Corrected sources and exact pinpoints":"S_OR-P3-S002, HB 2191 §8(3), printed p.11 / PDF index 10. \nOregon Legislative Information System","Conditions and confidence limits":"This does not decide whether, when, or how much of any provider fee is lawfully earned or collectible."},"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_OR-P3-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_OR-P3-C011","Full corrected assertion":"The 2009 enactment states that a provider may not deposit more than $250,000 in consumer funds in a trust account on behalf of one consumer.","Corrected sources and exact pinpoints":"S_OR-P3-S002, HB 2191 §8(5), printed p.11 / PDF index 10. \nOregon Legislative Information System","Conditions and confidence limits":"No FDIC pass-through, aggregation, or current amendment-chain conclusion is added."},"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_OR-P3-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_OR-P3-C016","Full corrected assertion":"Providers must retain the specified per-consumer records, including accounting and disbursement records, subject to the established retention framework.","Corrected sources and exact pinpoints":"Historical support pinpoint completed as S_OR-P3-S002, HB 2191 §7, printed pp.9–10 / PDF indices 8–9; current OAR 441-910-0200 support remains unchanged. \nOregon Legislative Information System\n+2","Conditions and confidence limits":"Wording unchanged; pinpoint completion only."},"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_OR-P3-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_OR-P3-C023","Full corrected assertion":"In a Director enforcement suit, a court may appoint a receiver or conservator for the defendant or the defendant’s assets upon a proper showing; the reviewed provisions do not create an automatic insolvency receivership or distribution waterfall.","Corrected sources and exact pinpoints":"S_OR-P3-S002, HB 2191 §15, enacted ORS 697.762(1), printed p.17 / PDF index 16. \nOregon Legislative Information System","Conditions and confidence limits":"Historical enactment pinpoint corrected; full current remedies and receivership law remain outside this pass."},"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_OR-P3-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_OR-P3-C025","Full corrected assertion":"Chapter 717 lists specified institutional, escrow, and authorized-delegate exemptions but no express registered-DMSP exemption in the text reviewed. ORS 717.210(2) authorizes the Director by rule or order to modify or waive the identified provisions where adequate regulation is provided by law or by another agency of this state. OAR 441-745-0010 separately permits waiver or modification of a particular rule only when not contrary to Chapter 717.","Corrected sources and exact pinpoints":"S_OR-P3-S011, ORS 717.210(1)–(2); S_OR-P3-S008, OAR 441-745-0010. \nOregonLaws\n+1","Conditions and confidence limits":"Official current Chapter 717 authentication remains held. No individual waiver, rule, order, license, or authorized-delegate status was established."},"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_OR-P3-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_OR-P3-C026","Full corrected assertion":"DFR classified the described ACH collection, custodial deposit, creditor disbursement, designated-company fee payment, third-party payment, and payment-instruction conduct as money transmission in a September 29, 2022 consent order against Debt Pay Gateway and again in a December 28, 2023 successor consent order against Set Forth, formerly Debt Pay Gateway.","Corrected sources and exact pinpoints":"S013: findings 3–7 printed pp.2–3 / PDF indices 1–2; conclusions 8–10 printed p.3 / index 2; date printed p.6 / index 5. S014: caption printed p.1 / index 0; prior-action ¶¶2–3 printed p.2 / index 1; findings 4–9 printed pp.2–3 / indices 1–2; date printed p.9 / index 8. \nOregon Division of Financial Regulation\n+6","Conditions and confidence limits":"Two successive orders in one respondent history, not two independent provider examples. Both were entered without admission or denial and are not controlling judicial precedent."},"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"claim_id":"S_OR-P3-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Existing claim ID":"S_OR-P3-C027","Full corrected assertion":"The reviewed authorities still do not resolve whether a properly registered custodial DMSP itself always needs a separate Chapter 717 license.","Corrected sources and exact pinpoints":"Chapter 697 custody architecture; Chapter 717 gateway; S013 and S014 as now limited. The 2023 order’s ¶¶2–3 connect it to the 2022 respondent history, and the orders’ footnotes state that the associated debt-management entities were unregistered. \nOregon Division of Financial Regulation\n+3","Conditions and confidence limits":"Unresolved. The orders do not announce a universal registered-DMSP dual-license holding. No provider-specific current status was searched."},"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false}],"sources":[{"source_id":"S_OR-P3-S002","urls":["https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191"],"researcher_record":{"Source ID":"S_OR-P3-S002","Title / issuer":"Enrolled HB 2191-B, Oregon Laws 2009, chapter 604 — Oregon Legislative Assembly","Direct literal URL":"https://olis.oregonlegislature.gov/liz/2009R1/Downloads/MeasureDocument/HB2191/Enrolled","Supplemental official access route":"https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191","Exact corrected pinpoints":"§5: printed pp.5–8 / PDF indices 4–7; §6: printed pp.8–9 / indices 7–8; §7: printed pp.9–10 / indices 8–9; §8: printed pp.10–11 / indices 9–10; §11: printed pp.13–14 / indices 12–13; §§12–14: printed pp.14–17 / indices 13–16; §15: printed p.17 / index 16. Specific corrected clauses: §8(2) printed pp.10–11 / indices 9–10; §8(3) and (5) printed p.11 / index 10; §11(4)(e)–(f) printed p.14 / index 13; §15/ORS 697.762(1) printed p.17 / index 16. \nOregon Legislative Information System\n+4","Actual PASS-04 access":"Fresh official PDF, targeted read. The overview page and its Enrolled link were opened, and the affected printed-page footers and operative clauses were checked in parsed text and selected page images. The coordinator’s earlier initial direct-route failure remains part of the access history; it is not overwritten by the later successful route. \nOregon Legislative Information System\n+1","Limits":"Selected clauses only; not all 28 pages, not every page image, and not a current Chapter 697 amendment chain. Bracketed deleted language in the enrolled amendment format is not used as operative enacted language."},"original_vertical_table_index":1,"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_OR-P3-S001","urls":["https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179"],"researcher_record":{"Source ID":"S_OR-P3-S001","Title / issuer":"OAR Chapter 441, Division 910 — Oregon Secretary of State","Direct literal URL":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2179","Exact material relevant to this correction":"Current OAR 441-910-0000(5) trust-account definition; history entries FCS 12-2011, filed December 15, 2011, certified effective January 1, 2012; FCS 13-2009, effective January 1, 2010; and earlier entries. Current operative OAR 441-910-0080 and 441-910-0200 support remains unchanged. \nOregon Secretary of State\n+2","Actual PASS-04 access":"Fresh official current-rule display, targeted reread.","Corrected history qualification":"The displayed history establishes that FCS 12-2011 was an effective filing in the rule’s history. Without reading and comparing the filing, it does not establish that the precise current trust-account definition was first created—or wholly replaced—on that date.","Limits":"No all-rulemaking-file audit, filing comparison, or historical text reconstruction. P3’s current operative-definition support remains intact."},"original_vertical_table_index":2,"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_OR-P3-S009","urls":["https://secure.sos.state.or.us/oard/view.action?ruleNumber=441-001-0040","https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112"],"researcher_record":{"Source ID":"S_OR-P3-S009","Title / issuer":"OAR 441-001-0040, Requests for Opinions and Interpretations — Oregon Secretary of State","Original direct literal URL":"https://secure.sos.state.or.us/oard/view.action?ruleNumber=441-001-0040","Fresh successful supplemental locator":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112","Exact material read":"OAR 441-001-0040(1)–(6), including request definition, submission requirements, permissible responses, revision/declination provisions, subsection (5)’s no-rule/no-order and court/third-party limitations, subsection (5)(f)’s Director/requester binding effect on the facts presented, declaratory-ruling option, and displayed history. \nOregon Secretary of State\n+2","Access history":"The original P3 researcher-access statement remains preserved. The coordinator later reported that the rule-number route failed. A fresh PASS-04 attempt at that direct route also returned inaccessible, while the ordinary official Division 1 locator succeeded. These are distinct access events; none is retroactively substituted for another. (Invalid URL)","Limits":"No request was submitted; no informal opinion, exemption confirmation, Director approval, declaratory ruling, or provider-specific protection exists in this record."},"original_vertical_table_index":3,"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_OR-P3-S011","urls":["https://oregon.public.law/statutes/ors_717.210"],"researcher_record":{"Source ID":"S_OR-P3-S011","Title / issuer":"ORS 717.210, exemptions; waiver; rules — current-readable secondary section text","Direct literal URL":"https://oregon.public.law/statutes/ors_717.210","Exact material used":"ORS 717.210(2): modification or waiver by rule or order where the Director determines adequate regulation is provided by law or by another agency of this state. ORS 717.210(3) separately addresses temporary suspension while an exemption is considered. \nOregonLaws","Actual PASS-04 access":"Fresh secondary read.","Limits":"The official current Chapter 717 route and complete amendment chain remain held. No source-absence inference and no person-specific waiver finding. Current OAR 441-745-0010 independently permits waiver or modification of a particular rule only when not contrary to Chapter 717. \nOregon Secretary of State"},"original_vertical_table_index":4,"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_OR-P3-S013","urls":["https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf"],"researcher_record":{"Source ID":"S_OR-P3-S013","Title / issuer":"Debt Pay Gateway, Inc., Case MT-21-0034 — Oregon Division of Financial Regulation","Direct literal URL":"https://dfr.oregon.gov/AdminOrders/Executed%20Consent%20Order%20-%20SIGG.pdf","Exact PASS-04 pinpoints":"Caption and no-admission/no-denial recital: printed p.1 / PDF index 0. Findings 3–4: printed p.2 / index 1. Findings 5–7, conclusions 8–10, and beginning of Order 12: printed p.3 / index 2. Order 14(C)–(F), including refund directions: printed pp.4–5 / indices 3–4. Final-order paragraph and September 29, 2022 date: printed p.6 / index 5. \nOregon Division of Financial Regulation\n+5","Actual PASS-04 access":"Fresh official order, targeted parsed-text and page-image review.","Corrected limit":"The former “pp.1–5” source description did not encompass the printed p.6 order date and was imprecise regarding all refund clauses. PASS-04 does not claim those additional pages had already been read during P3. Consent order without admission or denial; case-specific; not controlling judicial precedent."},"original_vertical_table_index":5,"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_OR-P3-S014","urls":["https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf"],"researcher_record":{"Source ID":"S_OR-P3-S014","Title / issuer":"Set Forth, Inc. (formerly Forth, Inc. and Debt Pay Gateway, Inc.), Case MT-23-0037 — Oregon Division of Financial Regulation","Direct literal URL":"https://dfr.oregon.gov/AdminOrders/Set%20Forth%20Inc._Consent%20Order%20-%20SIGG.pdf","Exact PASS-04 pinpoints":"Caption, former names, and no-admission/no-denial recital: printed p.1 / PDF index 0. Prior-action paragraphs 2–3 and beginning of current findings: printed p.2 / index 1. Findings 5–9 and beginning of conclusions: printed p.3 / index 2. Order 18 begins on printed p.4 / index 3 and continues to printed p.5 / index 4; Order 19 is on printed p.5 / index 4. Orders 18–21 extend across printed pp.4–6 / indices 3–5. Order 21’s refund provisions continue through printed p.6 / index 5. Order 24’s no-required-termination condition is on printed p.8 / index 7. Final-order paragraph and December 28, 2023 date are on printed p.9 / index 8. \nOregon Division of Financial Regulation\n+7","Actual PASS-04 access":"Fresh official order, targeted parsed-text and page-image review.","Corrected limit":"This is a later order in the same respondent history as S013, not a second independent provider example. The fee-free continuation applies only to active Oregon contracts as of the effective date; it does not establish a general operating right, new-customer right, expiry, current license, or universal registered-DMSP dual-license rule. Consent order without admission or denial; case-specific; not controlling judicial precedent."},"original_vertical_table_index":6,"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_OR-P4-S001","urls":["https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191"],"researcher_record":{"New usage ID":"S_OR-P4-S001","Nature":"Supplemental official access-route record for existing S_OR-P3-S002","Literal URL":"https://olis.oregonlegislature.gov/liz/2009R1/Measures/Overview/HB2191","Exact use and limitation":"Freshly opened October 25, 2026. The official overview identifies HB 2191, Chapter 604, and supplies the Enrolled document link. It is an access/discovery route to S002, not a separate enactment authority. \nOregon Legislative Information System"},"original_table_index":8,"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"source_id":"S_OR-P4-S002","urls":["https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112"],"researcher_record":{"New usage ID":"S_OR-P4-S002","Nature":"Supplemental official current-rule locator for existing S_OR-P3-S009","Literal URL":"https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=2112","Exact use and limitation":"Freshly opened October 25, 2026. Complete OAR 441-001-0040(1)–(6) and displayed history were read through this Division 1 page after the direct rule-number route failed. It is the same underlying rule, not a new authority. \nOregon Secretary of State\n+1"},"original_table_index":8,"coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false}],"coverage":[{"topic":"1. HB 2191 printed-page versus PDF-index pinpoints","researcher_record":{"Correction group":"1. HB 2191 printed-page versus PDF-index pinpoints","PASS-04 disposition":"Corrected","What is now resolved":"S002 page mapping; C003, C004, C008, C011, and C023 exact pinpoints; C016 pinpoint completion. C012 and C020 confirmed unchanged.","What remains expressly held":"Current official Chapter 697 authentication, complete amendment chain, all 28 HB pages, and every historical filing remain unreviewed. Bracketed deleted language is not operative evidence."},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"2. Set Forth / Debt Pay Gateway wording and provenance","researcher_record":{"Correction group":"2. Set Forth / Debt Pay Gateway wording and provenance","PASS-04 disposition":"Corrected with source-weight limitation","What is now resolved":"“Wind-down” replaced by fee-free continuation for active contracts as of the effective date; no-termination clause surfaced; exact order/date pages supplied; same-respondent history made explicit.","What remains expressly held":"No current license lookup, provider authorization, new-customer right, continuation expiry, universal dual-license holding, controlling precedent, or independent second-provider example. C027 remains unresolved."},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"3. Division 910 history and OAR 441-001-0040 access/binding effect","researcher_record":{"Correction group":"3. Division 910 history and OAR 441-001-0040 access/binding effect","PASS-04 disposition":"Corrected","What is now resolved":"Current operative trust definition remains supported; history label narrowed; successful Division 1 locator supplied; Director/requester versus court/third-party binding distinction corrected.","What remains expressly held":"No all-rulemaking-file audit, no proof of exact first-adoption date for the trust definition, and no opinion request, approval, exemption, or declaratory ruling."},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"4. ORS 717.210(2) paraphrase","researcher_record":{"Correction group":"4. ORS 717.210(2) paraphrase","PASS-04 disposition":"Corrected","What is now resolved":"The exact formulation is “provided by law or by another agency of this state”; OAR 441-745-0010’s anti-contradiction limitation remains supported.","What remains expressly held":"Official current Chapter 717 route and amendment chain, individual waiver, provider license, authorized-delegate status, and registered-DMSP/Chapter 717 overlap remain held."},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false},{"topic":"All other PASS-03 coverage and gaps","researcher_record":{"Correction group":"All other PASS-03 coverage and gaps","PASS-04 disposition":"Unchanged","What is now resolved":"None reopened.","What remains expressly held":"Current ORS chain; CPI and nominal fee currentness; savings-discharge timing; credit-only and alternative-repayment issues; attorney/nonprofit scope; actual provider, bank, ACH, contract, insurance, interest, setoff, priority, shortage, reconciliation, closeout, insolvency, credit-union, exempt-actor, bond, remedies, collection, limitations, case-law, secured-debt, sector, local, tribal, federal-applicability, and parent-state dimensions all remain open exactly as previously recorded."},"coordinator_acceptance":"not_yet_reviewed","coordinator_verification_status":"bounded_correction_checked_with_retained_limits","coordinator_review":"[internal evidence reference]","parent_assignment_complete":false}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}