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

S_OR PASS-05 — Oregon debt-management bond/security and consumer-recovery component

Fresh research-access date: October 25, 2026, Pacific time. Mode/model actually used: Regular Chat, GPT-5.6 Sol Pro, the highest verified authorized quality-first model available in this session. Review character: Focused researcher work on the previously excluded bond gap. This is not an independent review, a review of PASS-04, an Oregon-wide currentness certification, provider approval, operational approval, or publication acceptance.

PASS-01 through PASS-03 remain preserved. PASS-04 remains outside this pass and is not accepted or rejected here. No fee, trust-account, money-transmission, federal, named-provider, or full-remedies rerun was performed.

Currentness and source limitation

The current official OAR Division 910 and current DFR operational pages were freshly read. The official 2009 enrolled enactment was freshly checked for the bond, recovery, enforcement, repeal, and operative-date provisions. The ordinary official current ORS Chapter 697 route remained inaccessible; it was not repeatedly hammered or circumvented. Current-readable secondary section reproductions were used with their explicit limitation: they identify the official chapter as their source but do not substitute for a freshly authenticated official 2025-edition chapter and complete post-2009 amendment chain. The 2025 HB 3779 text surfaced only as proposed session material and is not treated as enacted law. Oregon Secretary of State+3

Executive findings

1. The currently displayed Oregon requirement is a $25,000 electronic corporate surety bond. ORS 697.642 states a statutory minimum of $10,000 or a higher amount specified by rule. Current OAR 441-910-0010 sets the amount at $25,000, and DFR’s current application page likewise calls for a $25,000 electronic surety bond through NMLS. OregonLaws+2
2. The examined operative law authorizes a corporate surety bond—not a cash deposit, letter of credit, trust-account balance, fidelity bond, or self-insurance substitute. ORS 697.732 still contains a public-record reference to a collection on a “deposit or bond,” but that isolated wording does not itself authorize a current deposit substitute under ORS 697.642. No substitute-security provision was located in current Division 910 or the current DFR debt-management instructions. OregonLaws+2
3. The bond is tied to registration, not to consumer-fund custody. A covered applicant must furnish it whether the registered model is custodial or genuinely noncustodial. A trust account protects consumer money actually held; the bond is separate security for specified legal duties. The $350 application charge, consumer service fees, trust funds, and civil penalties are also separate categories. Oregon Secretary of State+2
4. The bond is payable to the Director and is conditioned on payment, following a Director’s order or court order, of amounts due for violations of duties under ORS 697.652 through 697.702. Separately, ORS 697.718 gives a consumer with an ascertainable loss connected to listed violations a right of action against the provider and against the bond. OregonLaws+1
5. There is a genuine coverage-text mismatch. The bond condition reaches ORS 697.652 through 697.702, while the private-loss statute lists ORS 697.652, 697.662, 697.682, 697.692, and 697.707. ORS 697.707 itself requires disclosure that a consumer may sue on the bond. Thus, 697.707 is included in the consumer-action provisions but lies outside the literal 697.652–697.702 bond-condition range. Conversely, records provisions within the bond-condition range are not all listed in the private-loss statute. No controlling decision or complete current bond form was located resolving that mismatch. OregonLaws+2
6. The checked law does not establish guaranteed reimbursement, unlimited coverage, claimant priority, pro rata sharing, first-filed priority, a replenishing penal sum, or a state guaranty. The public amount is $25,000, but the complete Oregon-specific bond form was not recovered, so aggregate-versus-per-claim operation, prior-payment erosion, cancellation-tail coverage, and multiple-bond-period treatment remain unresolved.
7. A DFR complaint is not itself a surety claim or court order. DFR offers a general financial-services complaint route and can investigate compliance, but expressly states that it does not act as the complainant’s attorney. No separate public debt-management bond-claim form or consumer claim instructions were found on the checked official forms and complaint pages. Oregon Division of Financial Regulation+1

1. Required security, amount, form, beneficiary, and affected business models

1.1 Who must furnish the bond

ORS 697.642 applies to an applicant for registration as a debt-management service provider. The applicant files the bond with the Director at the time of application. Current OAR 441-910-0010 requires the application and bond submission through NMLS. OregonLaws+1

A genuine registration-exempt person ordinarily is not an applicant under that provision. But:

• A label such as “attorney,” “nonprofit,” “education,” or “credit counseling” does not establish the underlying exemption.
• A person that is actually required to register remains subject to the bond requirement even if operating without registration.
• Recent and historical DFR orders commonly treat providing covered services without the required bond as an additional violation, but those orders do not create bond coverage where no bond was ever issued.

The full attorney, nonprofit, institutional, and activity exemptions remain preserved from PASS-01 and are not reanalyzed here.

1.2 Current amount

The authority chain is:

1. ORS 697.642(1)(a): at least $10,000, or the amount the Director specifies by rule.
2. OAR 441-910-0010(2)(a): $25,000.
3. Current DFR instructions: electronic surety bond in the amount of $25,000. OregonLaws+2

Therefore, $25,000 is the current amount displayed in the actually checked current rule and agency instructions.

This finding is not:

• an inflation calculation;
• a finding that each consumer has $25,000 of dedicated protection;
• proof that an actual provider has a valid $25,000 bond;
• proof that the full penal sum remains unexhausted;
• proof that $25,000 is available per claim; or
• certification of every unindexed rule filing or later statutory change.

1.3 Issuer and form

The statute requires one or more corporate sureties authorized to do business in Oregon. The current rule says the bond copy must be in a form and on terms approved by the Director. OregonLaws+1

The examined operative text does not authorize:

• an individual surety;
• a provider’s unsecured promise;
• self-insurance;
• a consumer trust-account balance;
• a cash deposit;
• an irrevocable letter of credit;
• a bank guarantee;
• errors-and-omissions insurance; or
• a provider fidelity policy

as a substitute for the ORS 697.642 bond.

The official 2009 enrolled amendment displays deleted historical text concerning the former regime. That bracketed deleted wording is not operative evidence of a current alternative. The enacted 2009 replacement requires the corporate surety bond described above. Oregon Legislative Information System

1.4 Payee and protected interests

The bond must be payable to the order of the Director of the Department of Consumer and Business Services. That makes the Director the named statutory obligee/payee, while ORS 697.642(4) and 697.718(3) give qualifying consumers a statutory right of action against the bond. OregonLaws+1

This is not equivalent to saying:

• each consumer is individually named as obligee;
• the Director must pay every complainant;
• the state guarantees the surety’s solvency;
• the bond is a pooled public recovery fund; or
• the Director’s receipt of a complaint establishes a covered loss.

1.5 Security and money categories must remain separate

2. Claimants, covered duties, orders, and remedies

2.1 Bond condition

ORS 697.642(2)(b) conditions the bond so that the corporate surety or provider, upon a Director’s order or court order, pays all amounts due for violations of provider duties and obligations to consumers under ORS 697.652 through 697.702. OregonLaws

That range includes:

• ORS 697.652 — agreement and budget-analysis requirements;
• ORS 697.662 — prohibited practices;
• ORS 697.672 — records;
• ORS 697.682 — trust accounts;
• ORS 697.692 — fees; and
• ORS 697.702 — interference with records.

It does not literally include ORS 697.707 because 697.707 falls after 697.702.

2.2 Consumer private liability and bond action

ORS 697.718(1) makes the provider—or a person required to register—liable to a consumer who suffers an ascertainable loss of money or property connected to a violation of:

• ORS 697.652;
• ORS 697.662;
• ORS 697.682;
• ORS 697.692; or
• ORS 697.707.

Subsection (3) then gives a consumer with that right against the provider a right of action against the ORS 697.642 bond. OregonLaws

This requires more than showing a technical violation. The text requires:

1. A provider or person required to register;
2. A listed statutory violation;
3. An ascertainable loss of money or property;
4. A connection between the violation and the loss;
5. A timely action; and
6. For bond payment, satisfaction of the statutory and actual bond conditions.

2.3 The 697.707 mismatch remains unresolved

Three provisions pull in different directions:

• ORS 697.642(2)(b) describes the bond condition by reference to ORS 697.652–697.702.
• ORS 697.718 expressly includes an ascertainable loss connected to ORS 697.707 and gives the consumer a bond action.
• ORS 697.707(2)(e) requires the provider to tell the consumer that the consumer may bring an action against the bond and disclose the surety’s name and address. OregonLaws+2

The best bounded conclusion is:

A consumer has an express statutory bond-action provision for a qualifying 697.707-connected loss, but the literal bond-condition range stops at 697.702. The complete Oregon bond form or a controlling interpretation is needed to resolve the scope cleanly.

No inference is made that every disclosure violation is covered, that disclosure violations can never be covered, or that the mismatch is merely a drafting error.

2.4 Records violations present the opposite boundary

ORS 697.672 and 697.702 fall within the bond-condition range, but neither is among the five provisions listed in ORS 697.718(1). Thus:

• A Director’s or court’s authority to order “amounts due” for a records-related duty may exist under the bond condition.
• A consumer’s private ascertainable-loss action under ORS 697.718 is not expressly based on those records provisions.
• A consumer could potentially have another statutory or common-law theory, because ORS 697.822 says the remedy is nonexclusive, but that broader litigation analysis remains outside this pass. OregonLaws+2

2.5 Court order, Director order, and exhaustion

The bond condition speaks of payment following a Director’s order or court order. ORS 697.642(4) and 697.718(3), however, expressly create a right of action against the bond. OregonLaws+1

No language in the reviewed statutes expressly requires the consumer to:

• first obtain and unsuccessfully execute a separate judgment against the provider;
• prove the provider is insolvent;
• exhaust trust assets;
• exhaust a complaint process;
• first obtain a Director’s administrative order;
• first demand payment from the provider; or
• first pursue another recovery fund

before naming or proceeding against the bond.

But the absence of an express exhaustion clause is not a procedural ruling. The complete bond form and controlling case law were not recovered, so this pass does not establish:

• required parties or joinder;
• service on the surety;
• whether the provider and surety may be sued in one action;
• the form of a Director bond-payment order;
• proof-of-loss requirements;
• surety defenses;
• venue;
• pleading standards; or
• judgment-enforcement procedure.

2.6 Attorney fees

ORS 697.718(4) says a court may award reasonable attorney fees to the prevailing party. That is:

• discretionary rather than automatic;
• available to the prevailing party, not solely the consumer; and
• associated with an action under ORS 697.718. OregonLaws

The checked law does not resolve whether an attorney-fee award:

• is itself an “amount due” under the bond;
• is payable by the surety;
• counts against the bond’s penal sum;
• is available where only the surety, rather than the provider, is sued; or
• can exceed the remaining bond amount.

Those questions remain held.

2.7 Director enforcement and damages for consumers

The Director may bring a state circuit-court action to enjoin covered violations. Upon a proper showing, the court may grant injunctive relief and appoint a receiver or conservator. The Director may include a damages claim for an injured person where private enforcement would be so burdensome or expensive as to be impracticable. Oregon Legislative Information System+1

That public-enforcement route is distinct from:

• a consumer’s ORS 697.718 action against the provider;
• a consumer’s action against the bond;
• an administrative complaint;
• a civil penalty; and
• a receiver’s later distribution of assets.

A Director suit is not automatic merely because a consumer complains or a provider fails.

2.8 Restitution versus civil penalty: RH Law Group

In a July 21, 2011 final order entered by default, DFR concluded that RH Law Group was liable under ORS 697.718(1) for ascertainable consumer loss and ordered it to pay $3,000 to the harmed consumer. The same order separately imposed a $20,000 civil penalty payable to the state. The order did not adjudicate a claim against an issued bond or surety. Oregon Division of Financial Regulation+2

The order therefore supports only these bounded propositions:

• DFR has treated ORS 697.718 ascertainable loss as a basis for consumer payment in an administrative order.
• Consumer payment and public civil penalty are separate.
• A provider payment order is not necessarily a surety payment order.

It is a default administrative order, not controlling appellate precedent, and its later judicial-review history was not established.

2.9 No universal treble damages or automatic penalty transfer

Nothing in ORS 697.718 creates universal treble damages. ORS 697.832 authorizes civil penalties, but the 2009 enacted text directs recovered penalties to the State Treasury for the General Fund. They are not automatically consumer compensation or bond loss. Oregon Legislative Information System+1

Other statutory or common-law remedies may exist because ORS 697.822 makes the remedy nonexclusive, but those theories and their elements remain later litigation scope. OregonLaws

Security / claimant / remedy / condition matrix

3. Cancellation, replacement, claims timing, aggregate liability, priority, cessation, and insolvency

3.1 Surety cancellation and loss-payment notice

The bond must require the surety to notify the Director by registered or certified mail:

• at least 30 days before the surety cancels or revokes the bond; and
• whenever the surety pays for a loss under the bond. OregonLaws+1

The reviewed statute does not prescribe:

• a 30-day advance notice specifically for a reduction;
• notice directly to each consumer;
• notice to known claimants;
• publication notice;
• a specific loss-payment notice form;
• a deadline expressed in days after payment; or
• restoration of the penal sum after payment.

The actual form may contain additional terms, but it was not recovered.

3.2 Provider replacement or cessation

If the surety cancels, revokes, or otherwise terminates the bond—or if the bond amount is reduced below the required amount—the provider must immediately:

1. file a replacement bond; or
2. surrender registration and cease operating or providing debt-management services. OregonLaws

The statute does not create a post-termination grace period. The surety’s 30-day advance notice provides an opportunity to arrange replacement; it does not authorize continued operation after termination without the required bond.

3.3 Change in bonding company

Current OAR 441-910-0050 separately requires the provider to notify the Director in writing through NMLS at least ten days before changing the bonding company. Oregon Secretary of State

These are distinct obligations:

• Surety: 30-day statutory cancellation/revocation notice.
• Provider: 10-day advance NMLS notice before a bonding-company change.
• Provider after termination/reduction: immediate replacement or surrender and cessation.

The 10-day rule does not extend the replacement deadline.

3.4 Bond lapse and enforcement

Reducing the bond or allowing it to lapse is an express ground for denying, conditioning, suspending, revoking, or refusing to renew registration. ORS 697.825 also allows the Director to order a person to remedy a failure to maintain the bond. OregonLaws+2

Those provisions support regulatory action. They do not establish that:

• a lapsed bond retroactively covers later acts;
• a replacement bond assumes every prior obligation;
• a consumer has a claim against the state;
• the Director must obtain replacement security for the consumer; or
• the provider’s registration status proves that the bond remained continuously valid.

3.5 Record retention

OAR 441-910-0200 requires the registrant to retain the “original surety bond” certified as correct and true under the registration rule, with records generally retained for three years after the last entry. Oregon Secretary of State

There is a procedural-era tension:

• Current DFR instructions call for an electronic surety bond through NMLS.
• Current OAR retains the wording “original surety bond.”

This pass does not decide whether the NMLS-executed electronic record is treated as the “original,” whether a separately rendered copy must be retained, or which record controls in a discrepancy.

3.6 Claims timing

ORS 697.718(2) contains two timing formulations:

1. Except as otherwise provided in the subsection, an action may not be commenced more than three years after the provider enters into the debt-management agreement with the consumer, or more than three years after the provider performs a debt-management service that violates ORS 697.652.
2. The subsection then says an action may be commenced within three years after the transaction at issue or within two years after the underlying facts were or should have been discovered, but not more than five years after the transaction.
3. Untimeliness is an affirmative defense. OregonLaws+1

No controlling decision was located harmonizing those clauses for:

• non-697.652 violations;
• continuing programs;
• repeated fee withdrawals;
• delayed discovery;
• multiple transactions;
• bond cancellation;
• replacement bonds; or
• a claim first presented to DFR rather than filed in court.

Because the bond action is granted within ORS 697.718, that subsection is materially relevant to bond claims. But this pass does not establish that filing a DFR complaint tolls the period, satisfies commencement, or preserves a surety claim.

3.7 Former administrative bond-claim statutes were repealed

The 2009 enactment expressly repealed ORS 697.772, 697.782, 697.792, 697.802, and 697.812, with the repeal operative January 1, 2010. Those former provisions cannot be imported as the current debt-management claim filing, priority, or distribution system. Oregon Legislative Information System+1

The current checked provisions do not recreate an equivalent public administrative queue specifying:

• first-filed priority;
• pro rata distribution;
• a Director-controlled claim deadline;
• notice to all potential claimants;
• an administrative proof-of-claim form;
• a single proceeding consolidating claims; or
• a required waiting period before payment.

3.8 Aggregate limit and multiple claimants

The publicly verified current amount is $25,000. But neither the examined statute nor current Division 910 expressly states whether that amount is:

• the surety’s aggregate liability for all consumers;
• a per-consumer limit;
• a per-occurrence limit;
• an annual limit;
• separately available for each registration period;
• replenished after payment;
• cumulative across replacement bonds; or
• shared across all claims from the same underlying conduct.

A conventional bond often has a penal sum limiting aggregate liability, but this pass does not substitute general surety practice for the missing Oregon-specific form.

Similarly, no current verified provision establishes:

• first judgment priority;
• first claim filed priority;
• first loss paid priority;
• pro rata allocation;
• Director allocation;
• court interpleader allocation;
• special priority for trust-account losses;
• priority for consumers over government penalties; or
• priority between pre- and post-cancellation losses.

Those questions remain unresolved.

3.9 Public record of bond collection

ORS 697.732(4)(c) directs the Director to maintain as a public record notice or information indicating that a collection on a deposit or the ORS 697.642 bond has occurred. OregonLaws

That clause supports public recordkeeping after a collection. It does not itself:

• authorize a current deposit alternative;
• identify how to file a claim;
• establish claimant priority;
• require publication before payment;
• prove that any current provider’s bond has been collected; or
• disclose remaining bond capacity without an actual record.

3.10 Insolvency and cessation

Provider insolvency or inability to operate safely for consumers is a ground for regulatory action. The Director may seek a receiver or conservator in a judicial enforcement action. OregonLaws+1

But insolvency does not automatically:

• trigger bond payment;
• establish a statutory violation and ascertainable loss;
• establish the amount due;
• waive claim timing;
• transfer every consumer contract to a successor;
• convert civil penalties into restitution;
• establish priority over bankruptcy creditors;
• remove surety defenses; or
• guarantee that the surety is solvent.

No Oregon debt-management bond guaranty fund or state backstop was identified in the examined authorities.

4. Current public form, NMLS electronic procedure, complaint route, and lookup limits

4.1 Electronic surety procedure

Current DFR instructions require a $25,000 electronic surety bond through NMLS. The March 31, 2026 NMLS Policy Guidebook explains the general electronic process:

• the regulator creates the bond form;
• NMLS renders it;
• a surety company or surety bond producer creates the bond;
• the surety signs electronically;
• the licensee countersigns electronically; and
• execution occurs after both have signed. Oregon Division of Financial Regulation+2

The guidebook repeatedly states that it is guidance only and does not supersede state law, rules, or state-specific requirements. Nationwide Licensing System

4.2 Complete Oregon-specific form not recovered

The current DFR applications/forms page lists no public debt-management surety-bond PDF under its debt-management section; that section lists only a public-records form and Oregon licensing notice. The DFR application page points applicants to NMLS and a dynamic state checklist. The complete rendered Oregon bond text was not publicly extracted through the checked routes. Oregon Division of Financial Regulation+1

Therefore, this pass does not establish the form’s actual clauses on:

• penal sum;
• aggregate liability;
• continuation or renewal;
• retroactivity;
• occurrence date;
• acts committed before cancellation;
• claims made after cancellation;
• replacement-bond overlap;
• surety defenses;
• notice of claim;
• suit against the surety;
• subrogation;
• assignment;
• attorney fees;
• interpleader;
• venue;
• governing law;
• rider amendments; or
• surety discharge.

This is a not-recovered result, not a claim that the form is unavailable.

4.3 Consumer disclosure identifies the surety

ORS 697.707(2)(e) requires the consumer disclosure to state that the consumer may bring an action against the bond and to list the issuing surety’s name and address. OregonLaws

Consequently, an actual consumer agreement/disclosure should be a material source for identifying the alleged bond issuer. No consumer disclosure, bond number, surety address, or policy record was supplied here.

4.4 Public registration lookup

DFR directs the public to NMLS Consumer Access to look up debt-management service providers. Oregon Division of Financial Regulation

A registration entry, by itself, would not necessarily prove:

• that a particular loss date fell within bond coverage;
• the bond remained in force;
• the identity of every surety;
• the remaining penal sum;
• the claim history;
• the bond form version; or
• the surety’s current financial condition.

No SettleADebt.com or other assumed entity was searched.

4.5 Complaint directions

DFR provides an online and printable financial-services complaint route. It may send the complaint to the company and assess compliance with Oregon laws and rules, but it states that it does not act as the consumer’s attorney. Oregon Division of Financial Regulation

No official page checked here said that a financial-services complaint:

• commences an ORS 697.718 civil action;
• tolls the limitation period;
• constitutes notice to the surety;
• is a proof of loss;
• exhausts an administrative remedy;
• creates priority among claimants; or
• compels payment from the bond.

A consumer may use the complaint process to alert DFR, but the legal bond-action route remains separate unless an exact authority or form says otherwise.

5. Controlling decisions and formal interpretations

5.1 Oregon appellate decisions

Targeted searches were conducted for published Oregon decisions addressing:

• ORS 697.642;
• ORS 697.718;
• debt-management bond actions;
• ascertainable loss against a DMSP bond;
• multiple claimants;
• aggregate liability;
• cancellation tail;
• exhaustion;
• successor or replacement bonds; and
• priority or allocation.

No controlling published Oregon appellate decision squarely addressing those questions was located. This is a bounded search result, not proof that no unpublished, unindexed, trial-court, administrative, or later authority exists.

5.2 RH Law Group formal agency application

The RH Law Group default order is materially relevant only to the provider-liability and remedy distinction:

• DFR found ascertainable consumer loss under ORS 697.718.
• It ordered $3,000 paid to the harmed consumer.
• It separately ordered a $20,000 civil penalty.
• It did not identify or adjudicate an issued bond, surety liability, aggregate limit, priority, or claim procedure. Oregon Division of Financial Regulation+1

It should not be treated as a universal bond-payment interpretation.

5.3 Other DFR enforcement orders

Official DFR orders exist finding that unregistered covered providers violated ORS 697.642 by operating without furnishing a bond. Those orders support the regulator’s treatment of the bond as a distinct registration duty. They do not answer how an issued bond pays a consumer, and no additional provider order is needed to resolve this component.

The previously reviewed Debt Pay Gateway/Set Forth orders concerned money transmission and the same respondent history. They were not used as bond-recovery authorities here.

6. Bounded consumer-recovery examples

Each example uses dollars and cents and assumes no rounding beyond cents. These are arithmetic boundaries—not findings that a bond exists, coverage applies, liability is admitted, a claim is timely, or a surety must pay.

Example 1 — Single covered loss below the displayed bond amount

Assumptions

• An actual $25,000 Oregon bond was valid and applicable on the loss date.
• A court or Director determines that the provider violated ORS 697.682.
• The consumer’s gross ascertainable loss was $12,000.00.
• The consumer already received $3,000.00 back from the provider or trust account.
• That $3,000.00 is credited once against the loss.
• No prior bond payments, competing claims, attorney fees, interest, or surety defenses.
• The action is timely.

Calculation

Gross established loss:

$12,000.00

Less money already returned:

$12,000.00 − $3,000.00 = $9,000.00

Comparison with displayed bond amount:

min($9,000.00, $25,000.00) = $9,000.00

Result

Arithmetic bond-recovery ceiling on these assumptions: $9,000.00.

This is not a guaranteed payout. The consumer still needs actual coverage, an enforceable order, an issued and available bond, and satisfaction of procedural and form conditions.

Civil penalties are not added. The $3,000 already returned is not counted twice.

Example 2 — Single loss larger than the displayed bond amount

Assumptions

• Same legal assumptions as Example 1.
• Gross established covered loss: $40,000.00.
• Prior return or credit: $5,000.00.
• The actual form treats $25,000 as the maximum penal sum available for this claim and no prior payment has reduced it.
• No attorney-fee or interest amount is included.

Calculation

Net established loss:

$40,000.00 − $5,000.00 = $35,000.00

Conditional face-amount comparison:

min($35,000.00, $25,000.00) = $25,000.00

Loss remaining after the assumed maximum bond payment:

$35,000.00 − $25,000.00 = $10,000.00

Result

Conditional bond boundary: $25,000.00. Remaining established provider-side loss after that assumed payment: $10,000.00.

The $25,000 result depends on a form term making the penal sum the relevant maximum. Because the Oregon form was not recovered, this example does not certify that $25,000 is legally available per claim, aggregate, or at all. The remaining $10,000 is not declared uncollectible; it simply would not be paid from the assumed $25,000 bond capacity in this illustration.

Example 3 — Multiple consumers and unresolved aggregate allocation

Assumptions

• Consumer A has an established covered net loss of $18,000.00.
• Consumer B has an established covered net loss of $14,000.00.
• Both actions are timely.
• One $25,000 bond is alleged.
• No reliable bond form, prior-payment history, priority rule, or allocation order is available.

Arithmetic

Combined losses:

$18,000.00 + $14,000.00 = $32,000.00

Difference above the displayed bond amount:

$32,000.00 − $25,000.00 = $7,000.00

Supported conclusion

The claims exceed the displayed bond amount by $7,000.00.

Unsupported allocations that must not be invented

The checked sources do not establish whether:

• Consumer A receives $18,000 and Consumer B receives $7,000;
• Consumer B receives $14,000 and Consumer A receives $11,000;
• both recover pro rata;
• the first filed claim has priority;
• the first judgment has priority;
• the Director allocates the bond;
• a court requires interpleader; or
• each consumer has a separate $25,000 limit.

Therefore, no claimant-specific payout can be calculated lawfully from the verified evidence.

Prior-payment variable

Suppose the surety had previously paid P dollars and the actual form says prior payments reduce a $25,000 aggregate penal sum. The remaining amount would be:

Remaining assumed capacity = max($0.00, $25,000.00 − P)

For illustration only, if P = $5,000.00:

$25,000.00 − $5,000.00 = $20,000.00

Combined shortfall:

$32,000.00 − $20,000.00 = $12,000.00

That result remains conditional because this pass did not verify that the Oregon form uses a payment-eroding aggregate limit.

B. Source table

C. Claim table

D. Component coverage and gap table

E. Researcher self-check

Freshly read or inspected

• Current complete displayed OAR Division 910 provisions governing:$25,000 bond submission;bonding-company change notice;government application/renewal/exam charges;bond-record retention.
• Current DFR:debt-management application instructions;applications/forms inventory;financial-services complaint page;license lookup page.
• Current-readable secondary text of:ORS 697.642;ORS 697.707;ORS 697.718;ORS 697.732;ORS 697.752;ORS 697.762;ORS 697.822;ORS 697.825;ORS 697.832.
• Official 2009 HB 2191:§4 bond amendment, printed pp.4–5 / PDF indices 3–4;§15 Director suit, printed p.17 / index 16;§§16–20 recovery/enforcement, printed pp.17–19 / indices 16–18;§§27–28 repeal/operative date, printed p.27 / index 26.
• Selected HB 2191 pages were visually inspected; not merely search-snippet read.
• March 31, 2026 NMLS guide:guidance limitation;electronic bond-creation/execution process;selected glossary concepts.
• Selected NMLS PDF pages were visually inspected.
• RH Law Group final default order:liability;consumer payment;separate civil penalty;date and procedural posture.
• Relevant RH Law PDF pages were visually inspected.
• Targeted searches for controlling Oregon decisions and formal interpretations addressing bond recovery, aggregate liability, priority, cancellation, exhaustion, and successor security.

Explicit reuse

• PASS-01 registration and exemption boundaries.
• PASS-03’s distinction between trust funds and bond security.
• Prior current OAR/DFR access history supplied by the coordinator.
• No prior fee arithmetic, trust ledger, federal, or money-transmission analysis was recalculated.

Failed or incomplete source routes

• Official current ORS Chapter 697 HTML remained inaccessible.
• No usable complete current official Chapter 697 PDF was recovered.
• The dynamic NMLS Oregon checklist did not yield the complete rendered bond form.
• No public DFR DMSP bond-claim form was found on the checked forms page.
• No actual bond, rider, cancellation notice, loss-payment notice, public bond-collection record, or surety claim file was supplied.

These failures were not treated as proof that a form, claim, amendment, or record does not exist.

Not read or not established

• A complete official post-2009 amendment chain for all affected Chapter 697 sections.
• Every rulemaking filing behind OAR 441-910-0010.
• Complete Oregon-specific bond terms.
• Trial-court dockets, unpublished decisions, PACER cases, or every administrative order.
• Actual SettleADebt or other provider identity, registration, bond, surety, bond number, effective dates, cancellation, claims, payments, or remaining capacity.
• Surety financial condition or guaranty-association treatment.
• Bankruptcy-estate, bank setoff, garnishment, tracing, subrogation, unclaimed property, receiver distribution, and claimant-priority law.
• Full civil procedure, limitations, UTPA, contract, tort, collection, secured-debt, sector, local, tribal, or federal analysis.
• Any application, complaint, claim, filing, contact, opinion request, purchase, account change, private-record access, Chrome control, other Chat, local write, site action, or publication action.

This is a bounded researcher record of the Oregon debt-management bond and necessary consumer-recovery component. It does not establish a current valid bond, coverage, claim priority, payout, provider authorization, or completion of the Oregon dossier.

END S_OR PASS-05