| 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 | 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.
Oregon Legislative Information System
+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.
Oregon 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.
Oregon 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.
Oregon 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.
Oregon 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.
Oregon Legislative Information System
+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.
Oregon Division of Financial Regulation
+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.
Oregon Division of Financial Regulation
+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.
Oregon Division of Financial Regulation
+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.
Oregon Division of Financial Regulation
+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.
Oregon 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.
Oregon Secretary of State
+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.
OregonLaws | Precision correction to the statutory paraphrase. |