TITLE: Oregon Division of Financial Regulation Issues Final Order Against United Advocacy Counseling for Unlicensed Debt Management Services BODY: On March 17, 2026, the Oregon Division of Financial Regulation, acting on behalf of the Director of the Department of Consumer and Business Services, issued a final order against United Advocacy Counseling (operating as United Booking Services) for conducting unlicensed debt management services in violation of Oregon law. The Division found that United Advocacy, operating through websites www.united-advocacy.com and www.united-advocacy.org, offered to modify home mortgages and other loan terms for Oregon consumers without being registered as a debt management service provider (DMSP) or holding a required surety bond. Between January 2021 and November 2024, United Advocacy solicited at least four Oregon consumers, offering mortgage modifications at 2 percent interest rates. The consumers collectively paid approximately $5,735 in fees but received no loan modifications or received services with significant errors. One consumer received a foreclosure notice after paying United Advocacy $1,975. The Division initiated its investigation following a consumer complaint filed on November 14, 2024, and discovered that United Advocacy operated from a UPS Store mailbox in Signal Hill, California, under the name of Susan Bustamante. The Director concluded that United Advocacy violated Oregon Revised Statutes sections 697.612(1)(a) (operating without registration), 697.642 (operating without surety bond), 697.692(1)(a) (charging excessive initial fees), and 697.707 (failing to provide required disclosures). The Division issued a cease and desist order and assessed civil penalties totalling $40,000. United Advocacy may request judicial review by filing a petition with the Oregon Court of Appeals within 60 days of service of the order.

CRITICAL BEHAVIORAL RULES (these override all other instructions): - Always generate an update. Never refuse, never ask for more information, and never say you cannot produce output. - If the source content is in a non-English language, translate and summarise it into English. - If the source content is sparse, administrative, procedural, or lacks expected regulatory elements, extract and present whatever information is available. This includes personnel appointments, cabinet changes, institutional restructures, and any official government action. - Never include disclaimers or meta-commentary about source quality, translation limitations, or content gaps. - If you cannot determine a piece of information, simply omit it rather than noting its absence. - Content scope is broad: generate updates for all government and official publications including regulatory changes, legislation, consultations, decrees, personnel appointments, institutional announcements, administrative decisions, and any other government or authority action. Do not filter by topic relevance. You are an AI assistant generating Horizon scanning updates for government, regulatory, and institutional content. GROUND RULES FOR HORIZON SCANNING UPDATES: Title Requirements: - The jurisdiction must appear in the update title - For PC/FS updates, use title case - Titles must be declarative statements (not questions) Body Text Requirements: - Target 200-250 words, but shorter is acceptable when source material is limited - Include as many of the following as the source material supports: jurisdiction, authority, brief description of the development or action, relevant dates (effective dates, announcement dates, enforcement dates) - Include links to relevant legislation where applicable - Reference all initialisms in full on first use (e.g., "Financial Conduct Authority (FCA)") - Must be factual only - no speculation or sweeping statements - When information is unavailable, simply omit it rather than noting its absence Format your response as: TITLE: [Your declarative title with jurisdiction] BODY: [Your factual summary with all required elements]

Horizon Scanning Outline. Purpose of Analyst writing Horizon Scanning Updates Distil the key points of the development for clients to quickly see what is changing without reading the whole source. Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes. Simplify complex updates and sources so that they’re succinct, concise and clear to read. Consistently structure and write updates in the same format. Structure of Horizon Scanning Updates Always think about: Who (Authority) is publishing/enforcing the content/regulation? Where (Jurisdiction)? What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed? Who is this update applicable to (credit, e-money institutions, etc.)? Why is this update noteworthy? What is its significance? When is the update applicable? Title Describe what the update is about. Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what). All titles should be written in present tense. Avoid using acronyms Approx 10 - 20 words Example Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance Paragraph 1 Open with the date of the update (When) Name the authority that released the update (Who) Summarise the release (What) Example On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets. Paragraph 2 Summarise key points. The change/amendment aiming to achieve (what) What is its objective, why is it happening? Why is it significant? (why) Who does it impact or concern? (Who) The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document. Example SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to: Study Indian and global best practices. Prepare the guidelines. Address the concerns and issues arising from AI/ML usage. SEBI is consulting on the following principles to develop the guidelines: Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models. Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information. Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results. Fairness and bias: AI/ML models should not favour or discriminate against any group of clients. Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security. Paragraph 3 Acts as a “Call To Action”. Provide forward looking context: What actions need to be taken? Who needs to take action? Next steps to the development. Include any relevant dates (When) Response dates - should always be provided for consultations Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted. Example The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026. References Should always be included, and should come from a primary source, i.e., an authority, not a news source. General Style Notes: 200-250 words Active voice Authorities and companies referenced as a single entity (“It”, not “they”) Titles in title case Internal Vixio vocabulary guide Content Style Guide Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content. A Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA). Act - when just referring to “the act”, it does not need a capital a. Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell). - advice (noun) - give formal suggestions (for example, I gave them advice). Advisor NOT adviser Affect - verb - “have an effect on something, make a difference” Alternate/Alternative - Alternate (adjective) - means every other - Alternative (noun) - strictly one out of two - Alternative (adjective) - the other of two things. Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”. AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT Among/while NOT Amongst/whilst API - application programming interface Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act. Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”. B Between - should always appear with “and” NOT “to” - for example, between this summer and next summer. Big tech - two words, breaks convention of other tech words Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522). Brackets - square brackets should be used to denote deletions or additions in quotes. Buy now, pay later - no hyphens Bullet points - see Lists C Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a) Cardrooms not card rooms Cases - legal cases should appear in italics, with a v for versus. Casino-resorts NOT casino resorts or resort-casinos Chief executive NOT chief executive officer Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes) Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000) Comparisons - compare with (highlighting differences) - compare to (highlighting similarities) Companies/organisations - singular entities (it NOT they) should be followed by “which/that” rather than “who” Ltd, not Limited Complement - to accompany something/add value Compliment - give praise (complimentary = free) Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings) Comprise/comprising - should NOT be followed with “of”, as it means to “consist of” Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,) Continually - if something occurs repeatedly/regularly in the same way Continuously - if something occurs without interruption or gaps Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone) Contrast - by contrast - when comparing one thing to another - in contrast - simply noting a difference Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting Court of Justice of the European Union (CJEU) rather than ECJ Cryptocurrency - one word, not hyphenated. Crypto-assets - hyphenated Cybersecurity - one word, not hyphenated CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar) m for million, bn for billion, trn for trillion. D Date format - Month, Day, Year (e.g., March 7, 2019) For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…” For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...” For NIBs: always use dates rather than days. Department for Digital, Culture, Media & Sport - ampersand Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2) - try to use widely known titles rather than just numbers to ensure the directives are more easily recognised. DLT - distributed ledger technology E Effect - noun - “cause something to happen”. Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–). Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”. esports NOT eSports or e-sports Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”. F fintech NOT FinTech Footnotes - avoid where possible, if necessary write them into the text or add links. G GGR - “gross gaming revenues” Government - does not need a capital g. Governor - should be written out in full, NOT Gov. Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines) H Headlines - all words should begin with a capital Horseracing NOT horse racing Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money - DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper I Impact - should be used as a noun - i.e. the new act will have an impact on… - verb means “come into forcible contact with something else”. - using “affect” as a verb is more accurate. J Judgment - legal decision Judgement - one’s own opinion Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters. Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive. OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur DON’T need capitals unless a figure of importance (i.e., Prime Minister, President) Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be. Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team). K KYC - know your customer L Legislature - does not need a capital l. Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables. Licence - noun (UK), i.e. a driver’s licence License - verb/noun (US) Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent). M MONEYVAL NOT Moneyval More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players. N Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive. Names - should be written in full in first instance and then the surname used throughout. Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences. Non-fungible tokens - all lowercase (non-fungible tokens) O Offence - noun (UK), i.e. commit an offence Offense - noun (US) Organisations/companies - singular entities (it NOT they) should be followed by “which/that” rather than “who” Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears). Over - should not be used as a replacement for “more than”. P Parliament - does not need a capital p. Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”. - passed is the past tense of “to pass” - “the law was passed in government”. Prepaid, not pre-paid Percentages - numbers should always be written as figures percent NOT per cent or % Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent) Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to” Principal - main, most important Principle - a fundamental source or basis of something Programme (UK) Program (US, UK - for computer program, Australian English) Q Quotes - speaker should be referenced in the past tense (said NOT says) Quote marks - double quote marks should be used for speech - single quote marks should only be used for titles and within quotes. (See Quote reference sheet for more information on how to use quotes.) R regtech NOT RegTech Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines) Racetracks not race tracks S Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018. Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act. Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.) Sports betting NOT sportsbetting Sports team names Storey (pl. storeys) - level of a building (UK English) (story/stories - US English) T That defines, which informs Third person - “you” - avoid where possible. Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a) Tenses - content should generally be written in past tense - present tense should be used for something that has just happened and will be continuing into the future. U United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”) U.S. Department of Justice - Justice Department (with capitals as requested) V Vixio GamblingCompliance / Vixio PaymentsCompliance Vixio (to be used on its own after first instance) W Which informs, that defines While/among NOT Whilst/amongst While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”. X Y Year quarters - Q1, Q2, H1, H2, etc. Z Acronyms AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT API - application programming interface DLT - distributed ledger technology --- Now, given the above instructions and style guide, please generate a horizon scanning update based on the following webpage content. Generate the update regardless of the source language, content type, or level of detail available — this includes administrative decrees, personnel appointments, institutional changes, and any other official content. Use whatever information is present. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page 1 of 7 – DEFAULT ORDER United Advocacy Counseling – DM-25-0060 noitalugeR laicnaniF fo noisiviD gnidliuB seirtsudnI dna robaL 014 etiuS ,EN teertS retniW 053 1883-10379 RO ,melaS 7834-873 )305( :enohpeleT STATE OF OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES DIVISION OF FINANCIAL REGULATION In the Matter of: Case No. DM-25-0060 United Advocacy Counseling, FINAL ORDER TO CEASE AND DESIST AND ASSESSING CIVIL Respondent. PENALTY, ENTERED BY DEFAULT On February 5, 2026, the Division of Financial Regulation (“Division”), acting on behalf of the Director of the Department of Consumer and Business Services for the State of Oregon (“Director”), served an Order to Cease and Desist, Proposed Order Assessing Civil Penalties, and Notice of Right to an Administrative Hearing (“Notice”) on United Advocacy Counseling (“United Advocacy”) via regular and certified United States mail at its business address and via email to unitedbookingservices@gmail.com. The Notice offered United Advocacy an opportunity for a hearing if requested within 20 days of the Notice. The Notice further informed United Advocacy that if a hearing were not conducted because United Advocacy did not timely request a hearing or otherwise defaulted, then the designated portion of the Division’s file and all materials submitted by United Advocacy in this case would automatically become part of the contested case record for the purpose of proving a prima facie case. The Director did not receive a request for a hearing from United Advocacy and did not conduct a hearing. The Director finds that the record of this proceeding proves a prima facie case. Now, therefore, after considering the relevant portions of the Division’s file relating to this matter, the Director finds and orders as follows: /// /// 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page 2 of 7 – DEFAULT ORDER United Advocacy Counseling – DM-25-0060 noitalugeR laicnaniF fo noisiviD gnidliuB seirtsudnI dna robaL 014 etiuS ,EN teertS retniW 053 1883-10379 RO ,melaS 7834-873 )305( :enohpeleT FINDINGS OF FACT The Director FINDS that: 1. At all times material, United Advocacy is an assumed business name for a business that operated the website www.united-advocacy.com and www.united- advocacy.org. 2. As of the date of this order, the websites are no longer active. According to the website, United Advocacy’s office and mailing address was 2520 Cherry Ave. Ste #344, Signal Hill, CA 90755 (“Signal Hill address”), however, United Advocacy is not registered with the California Secretary of State. 3. United Advocacy advertised on its website that they “work directly with your lender to amend your loan terms” and that they were “mortgage restructuring experts.” 4. United Advocacy has never been registered with the Oregon Secretary of State to conduct business in Oregon and has never been registered with the Director through the Division as a debt management service provider (“DMSP”). 5. United Advocacy Counseling has not obtained a surety bond that is required for licensed DMSPs in Oregon. 6. On or about November 14, 2024, Oregon consumer MP1 filed a complaint with the Division concerning United Advocacy. According to the complaint, MP was solicited by United Advocacy which offered to modify MP’s home mortgage at a 2% interest rate. Although MP did not enter into a written agreement, MP paid United Advocacy a total of $1,875 to try to obtain the modification and received no loan modification. 7. On November 15, 2024, after receiving MP’s complaint, the Division sent a letter to United Advocacy requesting information (“Request for Information”) concerning all Oregon consumers that had entered into debt management service agreements with 1 Complainant’s initials are used to protect their privacy. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page 3 of 7 – DEFAULT ORDER United Advocacy Counseling – DM-25-0060 noitalugeR laicnaniF fo noisiviD gnidliuB seirtsudnI dna robaL 014 etiuS ,EN teertS retniW 053 1883-10379 RO ,melaS 7834-873 )305( :enohpeleT United Advocacy from January 1, 2021, through the date of the letter, and required that United Advocacy provide a written response by December 2, 2024. The Request for Information also advised United Advocacy that it “must immediately stop such activity in Oregon until they are correctly registered and/or licensed.” 8. The Request for Information was sent via email to the email address identified on its website, info@united-advocacy.com, and by first class and certified mail to the Signal Hill Address. 9. During its investigation, the Division discovered that the Signal Hill Address was a UPS Store and so, on November 15, 2024, the Division issued a Subpoena Duces Tecum to UPS Store #7198 seeking “[c]opies of tenant/box holder information relating to a current and/or prior tenant named United Advocacy Counseling located at 2520 Cherry Ave., PMB 344, Signal Hill, CA 90755.” 10. On November 19, 2024, the UPS Store provided documents responsive to the Subpoena Duces Tecum, including a copy of the USPS Form 1583 “Application of Delivery for Mail Through Agent” and a Mailbox Service Agreement. The name of the applicant for mailbox 344 was Susan Bustamante (“Bustamante”) for a business called United Booking Services. 11. Bustamante’s residential information listed on the application was for an address in Huntington Beach, California (“Huntington Beach Address”). The tenant information also included an email address of unitedbookingservices@gmail.com. 12. On November 19, 2024, the Division sent the Request for Information to Bustamante at the email address, unitedbookingservices@gmail.com. The email also informed Bustamante that “[i]f you are not the correct person to address this matter onto, please let me know who is responsible” for United Advocacy. The Division did not receive a response to the email from Bustamante. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page 4 of 7 – DEFAULT ORDER United Advocacy Counseling – DM-25-0060 noitalugeR laicnaniF fo noisiviD gnidliuB seirtsudnI dna robaL 014 etiuS ,EN teertS retniW 053 1883-10379 RO ,melaS 7834-873 )305( :enohpeleT 13. By November 2024, the Division had recently finished an investigation of a business called United Intake Center (“United Intake”), which was located at the same Signal Hill Address and whose website, www.united-intake.org, was virtually identical to United Advocacy’s website. 14. According to the investigation of United Intake, the complainant GY had been solicited by United Intake, which offered to modify GY’s home mortgage at a 2% interest rate. In response to the Division’s request for information, United Intake stated that a “mortgage notice was send [sic] by accident” to GY and then they shut down their website and the investigation into United Intake was closed. 15. As part of its investigation into United Advocacy, the Division obtained information from the Better Business Bureau concerning consumer complaints it had received against the business. In response, the Better Business Bureau provided complaints and reviews concerning United Advocacy from three additional Oregon consumers – SH, LB, and AM. 16. The Division thereafter reached out to SH, LB, and AM to obtain additional information about their complaints involving United Advocacy. 17. According to SH, United Advocacy offered to modify SH’s home mortgage at a 2% interest rate with monthly payments that were $1,000 cheaper each month. SH made two payments to United Advocacy totaling $1,975 and stopped when SH received a foreclosure notice from the mortgage loan servicer. 18. According to LB, United Advocacy offered to modify LB’s home mortgage at a 2% interest rate. LB made one $985 payment to United Advocacy before realizing that the United Advocacy would not be able to provide the promised modification. 19. According to AM, United Advocacy sent a letter stating that AM was qualified for a loan modification under the CARES Act and that they could help AM obtain the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page 5 of 7 – DEFAULT ORDER United Advocacy Counseling – DM-25-0060 noitalugeR laicnaniF fo noisiviD gnidliuB seirtsudnI dna robaL 014 etiuS ,EN teertS retniW 053 1883-10379 RO ,melaS 7834-873 )305( :enohpeleT modification. AM made two payments to United Advocacy totaling $1,900 and was provided with a financial report and instructed to submit the report to AM’s mortgage lender. The report, however, was full of errors that misstated AM’s income and United Advocacy was not willing to correct. 20. On December 2, 2024, the Division received a response to its Request for Information that had been sent to United Advocacy. The response was dated November 26, 2024, with United Intake letterhead and states that “[w]e appreciate you bringing to our attention about the regulation requirements and discontinued the website.” The response further states that “with regard to your other request, we have passed this on to the legal department and they will provide a written response in 30 days.” 21. To date, the Division has not received any further response(s) from United Advocacy. CONCLUSIONS OF LAW The Director CONCLUDES that: 22. By offering to provide to an Oregon consumer the services described in paragraphs 3, 6, 17-19 of this Order, United Advocacy offered to modify the terms and conditions of an existing loan from, or obligation to, a third party. In doing so, United Advocacy performed a debt management service as defined in ORS 697.602(2)(c). 23. By offering to perform a debt management service to four Oregon consumers without being registered with the Division, United Advocacy committed four violations of ORS 697.612(1)(a) . 24. By offering to perform four debt management services in Oregon without having the surety bond required, United Advocacy committed four violations of ORS 697.642. 25. By offering to perform a debt management service to four Oregon consumers 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page 6 of 7 – DEFAULT ORDER United Advocacy Counseling – DM-25-0060 noitalugeR laicnaniF fo noisiviD gnidliuB seirtsudnI dna robaL 014 etiuS ,EN teertS retniW 053 1883-10379 RO ,melaS 7834-873 )305( :enohpeleT before providing all necessary disclosures, United Advocacy committed four violations of ORS 697.707(2). 26. By charging fees to four Oregon consumers before providing all of the disclosures required by ORS 697.707(2), United Advocacy committed four violations of ORS 697.707(1) and by charging an initial fee greater than $50.00, United Advocacy violated ORS 697.692(1)(a). 27. ORS 697.832(1) authorizes the Director to assess a civil penalty against United Advocacy of up to $5,000.00 per violation of the Oregon Debt Management Service Provider Law. 28. Because the Director has reason to believe that United Advocacy violated ORS 697.612(1), the Director is authorized under ORS 697.825(1)(a) to order the company to cease and desist from violating these statutes. ORDERS Now therefore, the Director issues the following ORDERS: Order to Cease and Desist 29. As authorized by ORS 697.825(1)(a), the Director ORDERS United Advocacy to CEASE AND DESIST from violating ORS 697.612(1), ORS 697.642, and ORS 697.692(1)(a), and ORS 697.707. Order Assessing Civil Penalties 30. As authorized by ORS 697.832(1), the Director ORDERS United Advocacy to pay $40,000.00 in CIVIL PENALTIES, allocated as follows: A. $10,000.00 for violating ORS 697.612(1)(a); B. $5,000.00 for violating ORS 697.642; C. $20,000.00 for violating ORS 697.692(1); and D. $5,000.00 for violating ORS 697.707. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page 7 of 7 – DEFAULT ORDER United Advocacy Counseling – DM-25-0060 noitalugeR laicnaniF fo noisiviD gnidliuB seirtsudnI dna robaL 014 etiuS ,EN teertS retniW 053 1883-10379 RO ,melaS 7834-873 )305( :enohpeleT FINAL ORDER 31. This Order is a “Final Order” under ORS 183.310(6)(b). Subject to that provision, the entry of this Order does not limit other remedies that are available to the Director under Oregon law. SO ORDERED this ___1_7t_h_ __ day of March, 2026 SEAN E. O’DAY, Director Department of Consumer and Business Services /s/ Doro t h y Bea n Dorothy Bean, Chief of Enforcement Division of Financial Regulation NOTICE OF RIGHT TO JUDICIAL APPEAL You may be entitled to judicial review of this Order under ORS 183.482. You may request judicial review by filing a petition with the Court of Appeals in Salem, Oregon, within 60 days from the date of this Order is served. [The remainder of this page intentionally left blank]

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