Which place’s debt rules apply—and who can help?

S_OR PASS-01 — Oregon provider market access and consumer fees

Current research date: October 24, 2026, Pacific time. Research mode actually used: Regular Chat, GPT-5.6 Sol Pro. GPT-6 Pro was not available in this session; the owner-authorized quality-first fallback was used. No Deep Research, Work, Chrome control, other Chat, API, purchase, account change, contact, private borrower data, application filing, or publication action was used.

Component boundary: This pass addresses Oregon provider classification, public market access, registration exemptions, consumer-fee limits, fee timing, current application/lookup procedure, and worked fee examples. It does not complete the remaining Oregon collection, contract, trust-account, bond, remedies, litigation, limitations, secured-debt, sector, local, tribal, or other state-law components, except where a narrow point was necessary to answer this pass. No Oregon-wide or A066 acceptance is implied.

Executive determination

1. Oregon has a broad debt-management registration regime, not a categorical ban on ordinary debt settlement. Paid principal-reduction negotiation, interest or fee concessions, custodial and noncustodial payment programs, loan modification, credit improvement, and some paid advice or brokering all can fall within the statutory system. A nonexempt person may not conduct covered business in Oregon without first registering with the Director of the Department of Consumer and Business Services. The current regulator page expressly includes debt settlement, consolidation, credit repair, home-loan modification, short-sale negotiation, and budget counseling. Oregon Public Law+2
2. For-profit, out-of-bankruptcy debt settlement has a supported registration pathway. Oregon’s 2009 legislation deliberately expanded the regulated category to include debt settlers and created settlement-oriented fees; current DFR materials and enforcement orders continue to apply the registration and fee provisions to debt-resolution businesses and law firms. Registration is necessary but does not, by itself, prove that a particular company or contract is lawful. Oregon Legislative Information System+2
3. ORS 697.612(2) creates an important boundary. Its literal text permits a registered provider to negotiate a “reasonable alternative repayment schedule” or reduce a bankruptcy claim described in 11 U.S.C. §502 only if the provider is a nonprofit budget and credit-counseling agency approved under 11 U.S.C. §111. In context, that is best read as a special condition on those described activities, not as a repeal of the broader registered debt-settlement pathway enacted in the same 2009 law. Still, no controlling appellate decision located in this pass squarely defines the outer boundary of “reasonable alternative repayment schedule.” A for-profit model built around negotiating a traditional repayment schedule, or reducing a bankruptcy claim, therefore remains a specific market-access hold pending a controlling interpretation or authoritative legislative-history review. Oregon Public Law+2
4. **The principal state fee routes are:**Initial fee: no more than $50.Actual-cost initial counseling or education: no more than $50.Custodial plan: 15% of funds received for creditor payments, capped at $65 per month.Noncustodial consumer-owned designated account: 15% of enrolled debt, collected in amounts or installments no greater than $65 per month.Principal-savings fee: 7.5% of actual principal savings.Qualifying credit-only service: no more than $50 per month, with the initial fee serving as the first month’s fee. Justia Law+1
5. Oregon’s ceiling is not federal advance-fee permission. State law generally requires disclosures before charging or receiving a listed fee. It does not supply the settlement-and-first-payment triggers required by the federal Telemarketing Sales Rule when that rule applies. Under the TSR, a covered debt-relief seller or telemarketer cannot request or receive any fee until at least one debt has been altered under a valid agreement, the customer has made at least one payment under that agreement, and the fee is allocated under one of the permitted methods. Oregon Public Law+1
6. No named-provider authorization was established. Oregon directs applicants and registrants to NMLS, and directs the public to NMLS Consumer Access for debt-management-provider status. This pass verified the official procedure and lookup route but did not search or certify SettleADebt.com or any other named entity. Oregon Division of Financial Regulation+1

A. Substantive findings

1. Current classification and definitions

1.1 Covered “consumer”

A “consumer” is an individual who is obligated or allegedly obligated to pay a debt and on whose behalf a provider performs or agrees to perform a debt-management service. Oregon’s definition does not expressly restrict the underlying obligation to personal, family, or household purposes. Oregon Public Law

Consequences:

• An obligation owed solely by an LLC, corporation, partnership, or other nonindividual entity does not by itself establish an Oregon “consumer.”
• A sole proprietor, individual co-obligor, or personal guarantor may satisfy the individual element, even where the proceeds or debt had a business purpose. That is a textual inference; this pass did not locate a controlling Oregon decision applying the statute to a purely business-purpose individual debt.
• DFR’s September 2, 2026 bulletin says the Act reaches all “debts and obligations,” secured or unsecured, and applies it to personal state and federal tax obligations. The bulletin supports breadth but does not squarely decide every business-purpose scenario. Oregon Division of Financial Regulation

1.2 Covered activities

Oregon defines “debt management service” by conduct performed for money, valuable consideration, or the expectation of consideration:

The statute is therefore function-based. Calling a program “legal services,” “financial wellness,” “advocacy,” “resolution,” “credit counseling,” or “consolidation” does not control classification. Oregon Public Law+2

1.3 Principal reduction versus ordinary concessions

A provider that obtains or attempts to obtain a creditor concession is covered even when the requested concession is only:

• reduced interest;
• waived late charges or penalties;
• waived collection fees;
• a term or payment modification; or
• another alteration that does not reduce principal.

That distinction matters because the 7.5% savings fee is narrower than statutory coverage: the service can be covered even though no savings fee is available. The savings fee requires an actual principal reduction. Oregon Public Law+1

1.4 Custodial and noncustodial models

Oregon expressly covers both:

• Custodial: the provider directly or indirectly holds consumer funds and distributes them.
• Noncustodial: the consumer maintains funds in the consumer’s own designated insured account and the provider does not hold the funds.
• Payment facilitation without custody: the definition reaches receiving or offering to receive funds for distribution “whether or not” the provider holds them.

Custody changes the permissible fee formula; it does not decide whether the activity is regulated. Oregon Public Law+1

1.5 Resident and remote-provider nexus

A provider is statutorily defined as one that resides or does business in Oregon and offers or performs the covered service for consideration. DFR’s current bulletin states that an out-of-state company offering tax-relief debt-management services to Oregon consumers must register. The Oregon Court of Appeals likewise upheld application of the registration requirement to a Maryland law firm serving Oregon consumers. Oregon Public Law+2

The best-supported operational rule is therefore:

A physical Oregon office is unnecessary. Offering or providing covered services to Oregon consumers can create the Oregon nexus.

This pass did not decide more remote edge cases such as passive national web content with no Oregon acceptance, geofenced exclusions, or a lead that never becomes an Oregon transaction.

2. Prohibited, registered, conditionally exempt, and unresolved models

2.1 Market-access matrix

The operative registration prohibition and exclusions are in ORS 697.612. The current administrative rule materially narrows the attorney, nonprofit, bankruptcy-education, HUD, and real-estate exceptions. Oregon Public Law+3

2.2 Why ORS 697.612(2) is not treated as a universal for-profit settlement prohibition

Three pieces must be read together:

1. The same 2009 enactment defined covered debt-management services to include paid creditor concessions, including principal reduction.
2. Its staff summary specifically described the regulated providers as including debt settlers and described settlement-oriented fee structures.
3. Current DFR materials and enforcement orders continue to regulate for-profit debt-settlement providers under the registration and fee provisions.

Accordingly, the best-supported construction is that ORS 697.612(2) specifically governs the described alternative-repayment and bankruptcy-claim work. It should not be silently expanded into a ban on every registered for-profit principal-reduction settlement. Nevertheless, a provider whose central service is a negotiated installment schedule should not assume that ordinary registration alone resolves subsection (2). Oregon Legislative Information System+3

2.3 Attorney exemption

The attorney exception is not firm-wide immunity. The rule requires, among other things:

• services only for an attorney’s client;
• acting as an attorney for that client;
• no debt-management brokering;
• no direct or indirect compensation for a third-party referral;
• no debt-management services to a third party on the client’s behalf; and
• compliant legal advertising.

In Persels, the Oregon Court of Appeals upheld the agency’s determination that a Maryland law firm whose primary service was debt settlement was not exempt. The court left open the possibility that a law firm could qualify where all covered activity is genuinely incidental work performed by individual attorneys, but it did not establish a general law-firm safe harbor. Oregon Secretary of State+2

2.4 Nonprofit status

A nonprofit label alone does not resolve registration:

• The bankruptcy-education exemption is limited to qualifying briefing or education and bars other debt-management or brokering activity.
• The generic nonprofit educational exemption bars statutory debt-management activity, brokering, and the formal budget analysis, and caps the cost-based fee at $25.
• The HUD exemption is limited to covered HUD-funded or contracted housing work and bars other debt-management or brokering activity.

A nonprofit conducting an ordinary payment plan or settlement program therefore must identify an affirmative registration exemption or register; tax status alone is insufficient. Oregon Secretary of State+1

3. Current Oregon fee structures

3.1 Controlling fee matrix

The current fee text is ORS 697.692, as amended by Oregon Laws 2017, chapter 465, operative January 1, 2018. Oregon Legislative Information System+2

The current statutory fee text and rules support these figures. Justia Law+3

3.2 Which fees can coexist

The text supports the following reconciliation:

• Paragraphs (c) and (d) are mutually exclusive for the same custody model: one requires provider custody; the other requires no provider custody.
• The savings formula in (e) expressly excludes provider fees paid under (a), (b), and (d) from the creditor-payment figure. That is strong textual evidence that a qualifying savings fee can coexist with those categories.
• Paragraph (e) does not similarly identify paragraph (c). This pass does not establish that a custodial (c) fee and an additional savings fee may always be stacked.
• Paragraph (f) is a standalone credit-only branch. It expressly disallows brokering or other debt-management activity within that agreement; the initial fee is the first month’s fee.
• DFR says an eligible credit-repair provider may also charge the actual-cost counseling or education fee, but its webpage is operational guidance rather than the controlling statutory text. Justia Law+2

3.3 No separate per-debt contract or duplicate joint-debt fees

OAR 441-910-0094 prohibits separate contracts for each debt. One contract may describe different services for different debts. Jointly held debts served for co-debtors receive one fee set; separate contracts and fee sets may be used for individually held spousal or domestic-partner debts only if the provider can establish the basis. Oregon Secretary of State+1

This means:

• Oregon does not authorize a separate setup or monthly fee merely because several debts are enrolled.
• A per-debt savings calculation can occur under the savings formula without creating separate per-debt contracts.
• Federal TSR allocation can require a debt-by-debt earned-fee calculation even though Oregon requires one consumer contract.

3.4 CPI adjustment authority and current amount verification

ORS 697.692(4) permits—but does not require—the Director to adjust fee amounts by rule using CPI-U and other-state fee information. The full current Division 910 rule text and current DFR fee page checked in this pass did not reveal a later CPI adjustment rule or bulletin. DFR still displays the statutory $50, $65, and 7.5% figures. Therefore:

• The verified current operational figures are the enacted nominal amounts above.
• No independent CPI calculation was performed or substituted for a rule.
• The conclusion is limited to the rules and agency materials actually checked; it is not a claim that no unpublished or misindexed agency document could exist. Oregon Public Law+1

3.5 Dated Appendix A and current DFR webpage

OAR 441-910-0099 incorporates a 2015 Appendix A for illustration. That appendix predates the 2017 amendment and treats custodial and dedicated-account calculations too generically. It cannot override the current distinction between:

• paragraph (c): 15% of monthly creditor-payment funds, and
• paragraph (d): 15% of enrolled debt, collected in installments no greater than $65 monthly.

Likewise, DFR’s current fee webpage summarizes the custodial monthly formula but omits the enrolled-debt base in paragraph (d). It is useful operational guidance, not a complete statement of current fee law. Oregon Secretary of State+2

4. When fees may be requested or received

4.1 Oregon state timing

The core state timing rule is that a provider may not charge or receive an ORS 697.692 fee until after making the required disclosures. A written agreement is required before performing services, and a separate budget analysis generally must be completed and delivered before agreement execution. Oregon Public Law+3

4.2 Credit-only budget-analysis conflict

There is a real text tension:

• ORS 697.692(1)(f) describes a credit-only agreement in which the provider “does not conduct” a budget analysis.
• ORS 697.652(2) requires a pre-agreement budget analysis.
• OAR 441-910-0145(2) prescribes a reduced budget-analysis content set specifically for credit-improvement agreements.
• DFR’s current webpage says a budget and written agreement are required for credit repair.
• A recent DFR final order enforced the pre-agreement budget-analysis requirement against a credit-related legal-services program.

A plausible reconciliation is that paragraph (f) means the provider does not offer budget analysis as an ongoing paid debt-management service, while the provider still must complete the mandatory precontract suitability analysis. No source reviewed expressly adopts that reconciliation. The precise credit-only pathway is therefore partially unresolved, and the $50 arithmetic should not be treated as conclusive market authorization without resolving this conflict. Oregon Public Law+3

4.3 Federal TSR timing — conditional overlay

The federal debt-relief provision applies when the program is a “debt relief service” concerning unsecured debt and is sold through a covered telemarketing plan, program, or campaign. It is not automatically applicable to every Oregon transaction. eCFR

When it applies, no fee or consideration may be requested or received until all three events occur:

1. At least one enrolled debt has been renegotiated, settled, reduced, or otherwise altered under a valid agreement executed by the customer.
2. The customer has made at least one payment under that creditor agreement or plan.
3. The fee for the altered debt is either:proportional to that debt’s share of total enrolled debt; orcalculated using a savings percentage that remains the same for every debt. eCFR+1

Thus, an Oregon paragraph (d) ceiling of 15% does not permit monthly advance collection before federal performance. Oregon answers “how much”; the TSR can independently answer “not yet.”

4.4 Federal dedicated account

A dedicated account does not itself authorize provider payment. For the TSR safe structure:

• funds must be at an insured institution;
• the customer owns the money and receives interest, if any;
• the account administrator cannot be owned, controlled, or affiliated with the debt-relief service;
• the administrator cannot pay or receive referral consideration; and
• the customer can withdraw without penalty and must receive all unearned account funds within seven business days after requesting withdrawal. eCFR

The common inbound-advertising exception does not remove debt-relief calls from the TSR; debt-relief advertisements are expressly carved back into coverage. Ordinary business-to-business calls have a separate general exemption, subject to the rule’s conditions. eCFR

4.5 Credit-repair federal overlap

Where the provider expressly or impliedly offers to improve an individual’s credit record, history, or rating:

• The TSR credit-improvement provision may bar payment until the represented performance period has expired and a consumer report issued more than six months after the achieved result documents performance.
• CROA may apply where interstate commerce or the mails are used. CROA prohibits payment before the agreed service is fully performed, requires a written contract, and bars service during the three-business-day post-signing period.
• CROA excludes qualifying §501(c)(3) nonprofits, a creditor helping restructure its own debt, and specified depository institutions and credit unions.

These are conditional federal classifications, not universal rules for every Oregon settlement program. eCFR+3

5. Regulator permission, application, and public lookup

5.1 Regulator and application channel

The issuing regulator is the Director of the Oregon Department of Consumer and Business Services, operationally through the Division of Financial Regulation. Application is through NMLS. Oregon Division of Financial Regulation+1

Current publicly stated application items include:

• $25,000 electronic surety bond;
• criminal-background and credit-check authorization for each owner or control person in NMLS;
• sample consumer agreement and disclosures;
• sample budget worksheet;
• Oregon business-registration evidence;
• proposed fee schedule;
• management/control-person résumés;
• GAAP financial statements not more than 12 months old;
• required litigation, bankruptcy, injunction, agency-order, arbitration, and fraud-conviction disclosures; and
• $350 initial state registration fee. Oregon Division of Financial Regulation+3

Current regulator charges—not consumer fees—include:

5.2 Term and renewal

Under the current rule:

• registration issued before November 1 expires at the end of that calendar year;
• registration issued on or after November 1 expires at the end of the following calendar year; and
• renewal must be submitted through NMLS and paid by December 1 of the expiration year. Oregon Secretary of State+1

5.3 Public lookup

Oregon’s “Check a license” page directs users looking for a debt-management service provider to NMLS Consumer Access. Despite the page’s generic use of “license,” the Oregon statutory authorization at issue is a registration. Oregon Division of Financial Regulation

Verified routes:

• Oregon application page: https://dfr.oregon.gov/business/licensing/financial/pages/debt-management.aspx
• Oregon-linked NMLS state resource/checklist landing: https://mortgage.nationwidelicensingsystem.org/knowledge/Products/nmls/stateresourcecenter/SitePages/Home.aspx?StateID=OR
• Public NMLS Consumer Access lookup: https://www.nmlsconsumeraccess.org/

The state-resource route produced no extractable checklist text in the public-web reader, and the direct NMLS Consumer Access text route returned no usable record page. The DFR page itself supplied the current application instructions. No named-provider lookup was performed, so this report does not establish the current status of SettleADebt.com or another entity.

5.4 Advertising

A registered provider must disclose its registration number in advertising, presentations, and promotional communications designed to promote its services. Oregon Secretary of State

6. Worked fee and boundary examples

Unless otherwise stated, dollar calculations round to the nearest cent. These are bounded illustrations of verified formulas, not a conclusion that the hypothetical provider or contract satisfies every registration, contract, bond, fund-handling, TSR, CROA, or other requirement.

Example 1 — Custodial monthly fee

Assumptions

• Registered provider.
• Provider holds funds.
• Amount received specifically for creditor payments in Month 1: $300.00.
• Required disclosures and agreement conditions satisfied.

Calculation

• Base: $300.00 creditor-payment funds.
• Operator: 15%.
• Intermediate: $300.00 × 0.15 = $45.00.
• Monthly cap comparison: min($45.00, $65.00).
• State ceiling: $45.00.

For a later month with $600.00 in creditor-payment funds:

• $600.00 × 0.15 = $90.00.
• min($90.00, $65.00) = $65.00.
• State ceiling: $65.00.

A $65 state ceiling does not authorize collection before federal TSR performance if the transaction is covered by the TSR. [C020, C031]

Example 2 — Noncustodial enrolled-debt fee

Inputs

• Enrolled debt at signing: $4,000.00.
• Consumer-owned designated insured account.
• Provider does not hold funds.

Calculation

• Base: $4,000.00.
• Operator: 15%.
• Aggregate state formula: $4,000.00 × 0.15 = $600.00.
• Monthly collection limit: no installment above $65.00.
• One arithmetically valid schedule: 9 × $65.00 = $585.00, followed by $15.00.
• Aggregate state ceiling: $600.00 over ten installments.

This is not 15% of each monthly deposit. If the TSR applies, the provider may not request or receive these installments before the federal settlement, customer-payment, and allocation conditions occur. [C021, C031]

Example 3 — Low-balance principal-savings fee

Inputs

• Principal when agreement signed: $300.00.
• Actual amount paid to creditor to settle: $240.00.
• Actual principal reduction obtained.

Calculation

• Principal savings: $300.00 − $240.00 = $60.00.
• Fee: $60.00 × 0.075 = $4.50.
• State savings-fee ceiling: $4.50.

If the creditor waived $60 of interest but principal remained $300, the service could still be a covered creditor concession, but paragraph (e)’s principal-savings fee would be $0.00. [C004, C022]

Example 4 — Same-method proportional allocation after partial settlement

Inputs

• Two debts enrolled under one agreement:Debt A: $6,000.00.Debt B: $4,000.00.
• Total enrolled debt: $10,000.00.
• Contract uses Oregon paragraph (d)’s 15%-of-enrolled-debt method.
• Total state formula: $10,000.00 × 0.15 = $1,500.00.
• Debt A is validly settled and the customer makes the first required creditor payment.
• Debt B remains unsettled.
• Federal TSR applies.

Federal allocation

• Debt A share: $6,000 ÷ $10,000 = 60%.
• Maximum fee allocated to Debt A under the proportional method: $1,500.00 × 60% = $900.00.
• Debt B currently earned allocation: $0.00.

Oregon collection ceiling

Although $900.00 is the federal proportional allocation attributable to Debt A, Oregon paragraph (d) still caps each amount or installment at $65.00 per month.

If the provider previously collected four $65 installments before any debt was settled and paid:

• Prior collection: 4 × $65.00 = $260.00.
• Later performance does not retroactively cure the earlier TSR timing violation.
• Numeric equality with a later earned amount is not lawful timing. [C021, C031]

Example 5 — Same savings method across debts

Inputs

• Debt A at enrollment: $6,000.00.
• Debt A creditor settlement payment: $3,600.00.
• Debt B at enrollment: $4,000.00.
• Debt B remains unsettled.
• Agreement uses a uniform 7.5% savings method.

Debt A

• Savings: $6,000.00 − $3,600.00 = $2,400.00.
• Fee: $2,400.00 × 7.5% = $180.00.

Debt B

• No completed principal reduction and no creditor payment.
• Savings fee currently: $0.00.

The provider cannot switch Debt B to a different savings percentage. This example does not assume a separate 15%-of-enrolled-debt fee for Debt B. [C022, C031]

Example 6 — Previous provider fees do not reduce creditor-payment input

Inputs

• Principal at agreement: $8,000.00.
• Creditor receives $5,000.00 in settlement.
• Consumer previously paid:$50.00 initial fee.$40.00 actual-cost counseling fee.

Calculation

• Principal savings base: $8,000.00 − $5,000.00 = $3,000.00.
• The calculation is not $8,000 − ($5,000 + $90).
• Savings fee: $3,000.00 × 7.5% = $225.00.

The initial and counseling charges are provider fees, not creditor settlement payments. No automatic contractual credit against another debt or fee method is assumed. If the TSR applies and those $90 were requested or received before qualifying performance, their Oregon labels do not remove the federal “any fee or consideration” prohibition. [C019, C022, C031]

Example 7 — Three-business-day cancellation

Inputs

• Consumer cancels before midnight of the second business day.
• Initial fee paid: $50.00.
• Counseling fee paid: $40.00.

Calculation

• Refund: $50.00 + $40.00 = $90.00.
• Required state fee refund: $90.00.

The provider does not retain the counseling charge merely because counseling already occurred; the early-cancellation branch requires all paid fees to be refunded. [C028]

Example 8 — Later custodial cancellation

Inputs

• Consumer gives the required ten-calendar-day written notice after the initial cancellation period.
• Provider holds $1,000.00 of consumer funds designated for creditor payments, after separately accounting for any lawful fee.
• $400.00 has already been expended to creditors.

Calculation

• Unexpended held funds: $1,000.00 − $400.00 = $600.00.
• State return amount: $600.00.

This later-cancellation provision does not by itself require blanket repayment of every previously earned provider fee. Separate overcharge, contract, TSR, or other remedies may produce a different result. [C028]

Example 9 — Overcharge remedy

Inputs

• Provider charges a $70.00 initial fee.
• State ceiling: $50.00.

Difference

• Excess amount: $70.00 − $50.00 = $20.00.

Remedy

The statutory remedy is not limited to the $20 excess. The consumer may void the contract, the provider must return all sums paid to the provider, and the consumer may recover reasonable attorney fees incurred to enforce the subsection. [C029]

Example 10 — Credit-only first month

Nominal Oregon arithmetic

• Initial fee in Month 1: $50.00.
• Paragraph (f) monthly fee in Month 1: $0.00 additional, because the initial fee is the first month’s fee.
• Month 2 fee ceiling: $50.00.
• Separate actual-cost counseling/education fee: up to $50.00, if its conditions are independently satisfied.

Legal hold

This arithmetic does not resolve:

• the conflict between paragraph (f)’s “does not conduct a budget analysis” language and the mandatory pre-agreement credit-work budget analysis;
• TSR credit-improvement timing; or
• CROA’s completed-performance rule.

The nominal $50 monthly ceiling is therefore not advance-fee permission. [C023, C033, C035]

Example 11 — Entity debt versus individual business debt

Scenario A: An LLC alone owes a $40,000 vendor account, and no individual is obligated or allegedly obligated.

• The Oregon statutory “consumer” is not established.
• No consumer-fee pathway is demonstrated by this pass.

Scenario B: A sole proprietor personally owes a $40,000 business credit-card balance.

• The debtor is an individual.
• Oregon’s definition contains no personal-purpose limitation.
• Coverage is textually plausible, but no controlling Oregon decision applying the Act to that exact business-purpose fact pattern was located.
• Disposition: classification hold, medium confidence—not an invented authorized scenario. [C008]

B. Source table

C. Claim table

D. Scope coverage and gap table

E. Researcher self-check

Actually read or inspected

• Current Chapter 697 operative text for the relevant definitions, registration, agreement, fee, disclosure, and cancellation provisions through the official chapter locator and current readable codifications.
• Official enrolled 2009 HB 2191 pages establishing the broadened debt-management regime.
• Both available official HB 2191 staff measure summaries.
• Official enrolled 2017 SB 722 amendment and chapter/operative-date record.
• Full current displayed OAR Division 910, including exemptions, registration, fees payable to the state, contract limits, fee treatment, loan modification, budget analysis, pass-through charges, and advertising.
• Appendix A incorporated by OAR 441-910-0099.
• Current Oregon DFR debt-management registration and fee page.
• Current Oregon DFR public lookup page.
• DFR Bulletin 2026-8.
• Persels & Associates, LLC v. DCBS.
• Capital Debt Relief, Gershfeld Law Group, and Daniel March/Litigation Practice Group agency orders used here.
• Official OLIS status pages for HB 3779 and HB 4141.
• Current eCFR TSR definitions, debt-relief advance-fee provision, dedicated-account terms, and relevant exemptions.
• Official GovInfo CROA text.
• Relevant PDF pages were visually inspected where the research depended on PDF text.

Not read, not completed, or expressly held

• No full review of HB 2191 committee audio, all archived exhibits, or every legislative-history document.
• No official OJD-hosted copy of Persels was located; the reproduced appellate opinion was read through Justia.
• The current NMLS Oregon checklist did not yield extractable content through the public route.
• The NMLS Consumer Access endpoint was not used to search any named company.
• No complete Oregon case-law search was performed for every fee, refund, business-purpose, subsection (2), contract, or remedy issue.
• No application was filed, no regulator or person was contacted, and no provider authorization was requested.
• No actual SettleADebt contract, website flow, telephone campaign, dedicated-account relationship, legal entity, or representations were evaluated.
• No local files were written or claimed.
• This is not labeled an independent review, qualified legal opinion, complete Oregon dossier, or publication-ready state acceptance.

Bottom-line operational disposition: Oregon ordinary nonbankruptcy debt settlement has a real registration pathway, but launch should remain blocked until the exact legal entity is registered and verified in NMLS; the service model is tested against ORS 697.612(2); the fee contract chooses and consistently applies a lawful state method; state disclosures, agreement, budget, and cancellation mechanics are implemented; and federal TSR/CROA timing is applied to the actual marketing and service flow.

END S_OR PASS-01.