On September 2nd, 2026, the Oregon Division of Financial Regulation issued Bulletin No. DFR 2026-8, taking the position that any company offering tax relief or tax help to Oregon consumers must register as a debt management service provider under the Oregon DMSP Act, ORS 697.602 to 697.842. The bulletin amends the Division’s earlier Bulletin No. DFR 2025-1 from January 10th, 2025, and it applies to companies regardless of whether they are located in Oregon or elsewhere. Registration is handled through NMLS, and the bulletin took effect immediately upon publication.

The Division’s reasoning is straightforward, which is that a debt is simply something owed, and the Act reaches all debts and obligations whether secured or unsecured. Personal state and federal tax obligations are sums a consumer owes to the government, and Oregon law itself treats unpaid income tax as a personal debt due the State. The Division also points to United States v. Rodgers, where the Supreme Court explained that the government can sue for unpaid taxes and enforce a judgment like any other creditor, as well as the recent enforcement action in FTC and State of Nevada v. American Tax Service.

The practical takeaway is that helping Oregon consumers with tax obligations is now considered a debt management service activity under ORS 697.602(2), and performing that activity without registering exposes a company to the full range of remedies available under the DMSP Act. Companies in this industry that market or enroll Oregon consumers should evaluate their registration status now rather than waiting for an inquiry from the Division. Out of state companies are squarely covered, so physical presence in Oregon is not the test.

Oregon is not likely to be the last state to take this approach. State regulators are increasingly reading tax obligations into existing debt management and debt adjusting statutes, and companies operating nationally should expect similar interpretations elsewhere.