Oregon Collection Agency License: Bond, Fees, and Trust Account Rules

To get an Oregon collection agency license, you register your business through the Nationwide Multistate Licensing System (NMLS), pay a $350 state fee, post a $10,000 surety bond, and clear criminal background and credit checks for every owner and manager. Oregon law technically calls this a registration rather than a license under ORS 697.015, but the Division of Financial Regulation (DFR) and NMLS use both terms, and the practical requirements are the same.

Who Has to Register

Oregon defines a collection agency broadly. Under ORS 697.005, it covers any person or business that collects or tries to collect debts owed to someone else, directly or indirectly, and anyone who solicits the right to collect for another party.¹ If your business purchases delinquent accounts, performs billing services, or does skip tracing for collection purposes, you most likely fall inside this definition.

One trap worth flagging: if you collect your own debts but use a trade name that suggests a third party is doing the collecting, Oregon treats you as a collection agency and requires registration.¹ The federal FDCPA has a nearly identical rule, so there is no safe harbor for using a shell name.²

Who Is Exempt

ORS 697.005(1)(b) carves out several categories:

Individual employees collecting on behalf of a registered agency.
In-house collectors who work for no more than three employers and always use the employer’s name.
Banks, savings and loan associations, credit unions, trust companies, consumer finance companies, and debt consolidation agencies.
Licensed attorneys performing ordinary legal duties. Attorneys running a dedicated collection business should check with the DFR about where the line falls.
Licensed real estate brokers handling collection activity tied to closing escrows, and property managers collecting rent or fees for landlords.

These exemptions are narrow. Step outside the specific scope and you need to register.

What You File

Everything goes through NMLS using the Company Form (MU1).³ Plan to supply:

Your legal entity name, trade names, and FEIN.
Contact information for all executive officers and any owner with 10 percent or more of the business.
Formation documents (articles of incorporation, partnership agreement, or equivalent).
Proof of current registration with the Oregon Secretary of State.
Recent financial statements showing the business can responsibly handle consumer funds.
Written explanations for any “yes” answer to the NMLS disclosure questions about prior legal, regulatory, or criminal history.

Background Checks

Every owner, partner, and manager must complete a Criminal Background and Credit Check Authorization Form uploaded through NMLS.³ Those same individuals complete an MU2 form, authorize a federal criminal background check, and schedule fingerprinting through the Fieldprint platform.⁴ The company has to submit its filing with payment before the background check process can move forward, so don’t hold this step.

Registered Agent

Every corporation must maintain a registered agent with a physical Oregon street address where legal documents can be served. Under ORS 60.111, the registered office cannot be a mail forwarding service, commercial mail receiving agency, or virtual office.⁵ Commercial registered agent services typically run $49 to $125 per year.

The $10,000 Surety Bond

Before the DFR will approve your registration you must post a $10,000 surety bond or an irrevocable letter of credit.⁶ Out-of-state agencies with no Oregon office or trust account must post $15,000 instead.³

The bond has to come from a surety company or financial institution authorized to do business in Oregon. It runs to the State of Oregon for the benefit of the state and of any consumer who later wins a judgment against the agency for violating ORS 697.005 through 697.095. A consumer with an uncollected judgment can pursue a claim against the bond in circuit court.⁶

The bond must stay continuously in force the entire time you hold your registration. A lapse is grounds for revocation. Annual premiums on a $10,000 bond generally run 1 to 15 percent of the bond amount, so expect roughly $100 to $1,500 per year depending on your credit profile. Your surety needs to be set up in NMLS, because the bond is submitted electronically through that system.

What It Costs to Apply

The upfront fees break down as follows:

Oregon registration fee: $350, paid through NMLS at submission.³
NMLS initial setup fee: $120 for the MU1 company filing.⁷
Credit card service fee of 2.5 percent if you pay by Visa or Mastercard. ACH payments avoid this charge.⁷

So minimum out-of-pocket is $470 before the surety bond premium, and none of it is refundable. After you submit, DFR reviews your materials and may follow up with questions or document requests. Respond promptly to keep the file moving. When DFR is satisfied it issues an electronic confirmation and you appear in the state’s public registry.

Out-of-State Agencies

If your agency sits outside Oregon but collects from Oregon consumers, you still have to register. ORS 697.031 includes reciprocity provisions that can shrink or eliminate the fee depending on how your home state treats Oregon-based agencies:⁶

If your home state charges no registration fee to out-of-state agencies collecting solely through interstate communications, Oregon waives its fee.
If your home state does charge a fee, Oregon will charge at least as much as your state would charge an Oregon-based agency collecting remotely into your state.
If your home state exempts Oregon-registered agencies from registering there, Oregon exempts agencies from your state entirely.

Out-of-state agencies without a physical Oregon location can request a waiver of the in-state office and trust account requirements by uploading a Request for Waiver form through NMLS.³ Keep in mind the $15,000 bond applies if you have no Oregon office or trust account.

Trust Account Rules

ORS 697.058 prohibits collection agencies from commingling customer money with their own funds.¹ In practice this means a separate Oregon trust account used exclusively for client funds. Money collected on behalf of creditors stays there until it is disbursed.

Agencies that take prepayments for services face an extra rule: those prepayments sit in a separate trust account for 180 days or until services are performed, whichever is first.¹ This one catches agencies off guard because most industries don’t require segregated prepayment accounts.

Out-of-state agencies can request an exemption from the in-state trust account requirement, but only by showing that DFR can examine their books without undue delay, that debtor payments will be remitted promptly, and that any additional bonding or audit conditions DFR imposes are met. The statute also prohibits false entries in agency records or intentional destruction of records within the retention period.

Renewal and Ongoing Compliance

Oregon registrations renew annually through NMLS. The renewal window runs November 1 through December 31, and you have to submit renewal and payment before the renewal date to stay active. The annual renewal fee is $120.⁸ Submit a current list of solicitors and their desk names with the renewal.

NMLS separately requires licensees to submit annual financial statements within 90 days of fiscal year end, uploaded as a searchable PDF.⁹ Whether DFR requires audited, reviewed, or compiled statements is set out in the NMLS License Requirements and Fees Chart for Oregon collection agencies. Your surety bond must also remain continuously in effect; if the surety cancels or declines to renew, DFR can revoke the registration.

What Can Get Your Registration Denied or Revoked

Under ORS 697.039, the DFR director can refuse, suspend, or revoke a registration for any of the following:¹

False or untruthful information in any filing submitted to DFR.
Violations of the director’s rules or of the trust account and record-keeping requirements in ORS 697.058.
Lapse of the required bond or letter of credit.
Dishonest, fraudulent, or illegal practices by the agency or its principals in any business or profession.
Conviction of a principal for a felony or misdemeanor where fraud was an essential element.
Death or incapacity of the registrant.

The “any business or profession” phrase matters. A fraud conviction or regulatory action in an unrelated industry can support denial or revocation of your Oregon collection agency registration.

Penalties for Collecting Without Registering

Operating without a valid registration carries layered consequences. Under ORS 697.095, each violation is subject to a civil penalty of up to $1,000.¹ Because “each offense” can mean each individual collection attempt, exposure accumulates quickly across an active portfolio.

ORS 697.990 classifies unregistered operation as a Class A violation for both individuals and business entities.¹ Corporate officers and agents who personally participate face the same individual penalty. Justice courts share jurisdiction with circuit courts for criminal prosecutions under ORS 697.015.

The provision most agencies miss is ORS 697.091: anyone who violates the registration requirement cannot legally charge or receive any fee or compensation on money collected while unregistered.¹ Every dollar in collection fees earned during the unregistered period can be subject to disgorgement, and for an agency that put off registering while collecting actively, that exposure dwarfs the civil penalties.

Federal Rules Still Apply

Holding an Oregon registration does not take you off the hook for federal law. Collection agencies in Oregon must simultaneously comply with the Fair Debt Collection Practices Act and its implementing regulation, Regulation F (12 CFR Part 1006), enforced by the Consumer Financial Protection Bureau.¹⁰ That includes sending a validation notice within five days of first contact with the required content under 12 CFR 1006.34,¹¹ honoring the seven-calls-in-seven-days safe harbor, calling only between 8 a.m. and 9 p.m. in the consumer’s local time, obtaining consent and providing opt-outs for electronic communications, and avoiding the prohibited tactics listed in the FDCPA.²

One Oregon-specific note on debt buyers: federal law treats a company collecting debts it owns differently from a third-party collector, but Oregon does not draw that distinction. Under ORS 697.005, debt buyers collecting purchased accounts are covered by the state registration requirement regardless of who owns the debt.

1
Oregon State Legislature. Oregon Code 697 – Collection Agencies; Check-Cashing Businesses; Debt Management Service Providers
2
Office of the Law Revision Counsel. 15 USC 1692a – Definitions
3
Division of Financial Regulation. Collection Agencies
4
NMLS Resource Center. Completing the CBC Process for MU2 Individuals
5
Oregon Public Law. Oregon Revised Statutes 60.111 – Registered Office and Registered Agent
6
Oregon Public Law. Oregon Code 697.031 – Registration Procedure; Bond or Letter of Credit; Fees; Procedures for Out-of-State Collection Agencies; Rules
7
NMLS Resource Center. NMLS Processing Fees
8
Oregon Secretary of State. Oregon Administrative Rules – Division 810
9
Nationwide Multistate Licensing System. Submitting Annual Financial Statements
10
eCFR. 12 CFR Part 1006 – Debt Collection Practices (Regulation F)
11
eCFR. 12 CFR 1006.34 – Notice for Validation of Debts