On July 7, the Oregon Division of Financial Regulation entered a consent order with a Wisconsin-based debt collector over alleged unregistered collection activity. The Division alleged that the company violated Oregon Collection Agency Law, which requires collection agencies operating in the state to register with the Department of Consumer and Business Services.
The investigation began after the Division received a consumer complaint from the Oregon Department of Justice in April 2025. After reviewing the company’s licensing status and collection activity, the Division alleged that the company:
- Operated without an Oregon registration. An NMLS search allegedly showed that the company held collection agency approvals in other states but was not registered in Oregon.
- Collected debts from more than 1,500 Oregon consumers or accounts. The company disclosed that it had collected approximately $155,500 from 1,569 Oregon consumers or accounts since January 2023.
- Continued collection activity during the investigation. The company later identified another 243 Oregon consumers from whom it collected approximately $21,700 after responding to the Division’s initial request for information.
- Committed 1,812 alleged violations. The Division treated each instance of collection activity conducted without the required registration as a separate alleged violation of Oregon law.
The company stated that it believed it was exempt from Oregon’s registration requirement and obtained an Oregon collection agency registration in April 2026. Under the consent order, the company must cease and desist from further violations and pay $40,000 of a $181,500 civil penalty. The remaining $141,500 is suspended for three years and will be waived if the company complies with the order and commits no new violations of the Oregon Collection Agency Law.
Putting It Into Practice: State regulators continue to pursue licensing enforcement involving financial services activity conducted without proper licensing and registration (previously discussed here and here). The order demonstrates how a single consumer complaint may prompt a broader review of a company’s licensing status and historical activity. Debt collectors and other multistate financial services providers should confirm that their licenses and exemption analyses align with their activities in each jurisdiction and update compliance controls as necessary.