Salem – A new law going into effect June 5, House Bill (HB) 4116 (2026), closes a loophole that allowed internet lenders to charge interest rates in excess of Oregon’s limit of 36 percent for consumer finance loans.

Consumer finance loans are unsecured small dollar loans with a term of 60 days or more. Since 2007, consumer finance loans in Oregon have been limited to a 36 percent interest rate. This limit is intended to protect Oregonians from predatory lending practices.

However, in recent years, some lenders have sought to take advantage of a provision in federal law called the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA) enabling state-chartered banks from other states to export their home state’s interest rate to Oregon.

By partnering with a bank chartered in a state that allows higher interest rates, some lenders have charged Oregonians interest in some cases in excess of 100 percent APR. Since 2020, DFR found evidence of more than 31,000 loans totaling at least $61 million with interest rates that exceed Oregon’s cap.

In a recent enforcement action, DFR was successful in securing a settlement that required a lender to pay restitution of $900,000 for charging interest that exceeded the cap. However, the option to export other states’ interest rates still left Oregon consumers vulnerable to these practices.

DIDMCA allows states to opt out of permitting banks chartered in other states from importing another state’s interest rate. HB 4116, signed into law by Gov. Kotek on April 7, exercises Oregon’s opt-out right under federal law. The law also clarifies the applicability of Oregon law to internet-based lending and makes other technical updates. Now, lenders can no longer take advantage of DIDMCA interest rate exportation to evade Oregon’s interest rate caps.

Oregon consumers should know that if they are charged interest in excess of 36 percent for a consumer finance loan, it is likely in violation of the law. We would strongly encourage any consumers to contact the Oregon Division of Financial Regulation for information, assistance, and, if needed, regulatory action to ensure compliance. Our consumer advocates can be reached at 888-877-4894 (toll-free) or dfr.financialserviceshelp@dcbs.oregon.gov.

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About Oregon DFR: The Division of Financial Regulation protects consumers and regulates insurance, depository institutions, trust companies, securities, and consumer financial products and services. The division is part of the Department of Consumer and Business Services, Oregon’s largest consumer protection and business regulatory agency. Visit dfr.oregon.gov and dcbs.oregon.gov.

Salem – The Oregon Division of Financial Regulation (DFR) will begin its annual health insurance rate review process in June for the 2027 plan year, with state regulators warning that federal decisions could have a significant effect on what Oregonians pay for coverage next year.

Insurance companies submitting proposed 2027 rates are expected to cite several emerging federal factors in their filings.

“The loss of the federal Affordable Care Act (ACA) subsidies, impact of tariffs, and changing federal guidance have left more Oregonians vulnerable to health care costs generally,” said Oregon Insurance Commissioner TK Keen. “Oregonians who buy their own coverage or work for small businesses deserve to know about the rate filing process, what’s driving rates to increase or decrease, and how to share their perspective. This level of transparency and accountability is unprecedented for a rate review process, and one we take seriously as a regulator.”

The transparent, actuarial-driven process includes publication of planned rates and public hearings on the rate filings for the individual and small group markets. Each year, health insurance companies submit planned rates, which the division then reviews under strict actuarial standards to ensure the rates are sound and insurers remain solvent.

The division analyzes the rates to determine whether they are actuarially sound, a process that is a months-long review. Part of the analysis includes reviewing the rates to ensure they are not excessive, inadequate, or unfairly discriminatory, as well as whether the planned administrative expenses are reasonable. DFR does not create or establish rates but rather reviews the rate proposals of insurance companies and ensures that all statutory factors are considered.

Oregon also operates a reinsurance program that operates to offset costs in the individual market and reduces rates by 6 percent to 8 percent each year. That program, using a combination of federal and state funds, is particularly effective at offsetting high-dollar claims in the individual market. DFR is pursuing a renewal of this reinsurance program with support from Oregon Gov. Tina Kotek.

Who this process affects

This rate review process applies to Oregonians who purchase health coverage through the health insurance marketplace or directly from an insurance company, and to employees of small businesses with fewer than 50 employees.

As of December 2025, per DFR’s quarterly enrollment reports, the Oregon individual market covered 148,376 people (3.4 percent of Oregonians), while the small group market covered 137,485 people (3.2 percent). In total, these markets cover 285,861 people (roughly 6.6 percent). It does not affect people covered through Medicare, Medicaid/Oregon Health Plan, or large employer or self-insured plans.

DFR’s role in the process

Rate review is a technical, actuarially driven process designed to ensure that the rates insurance companies file are supported by relevant data. DFR’s review team examines each insurer filing in detail, scrutinizing projected medical costs, administrative expenses, utilization trends, and reserve adequacy. The question DFR is answering is not simply whether rates are high or low, but whether they accurately reflect the cost of providing coverage to Oregonians while keeping insurers financially stable.

DFR has authority under Oregon law to require insurers to justify every component of a rate request. If the division finds that projections are inflated or administrative costs are unreasonable, it will reduce rates accordingly. An insurer’s financial position and market stability are also key considerations that are analyzed throughout the process.

DFR has created a website to inform consumers of the process and provide key documents and a space for public comment.

What’s likely to drive rate requests this year

Historically, insurance companies have cited several factors for explaining the rates they are charging that centered on medical and pharmaceutical costs, utilization, and the existence of federal subsidies. For plan year 2027, Congress not extending the enhanced federal ACA subsidies, the impact of tariffs, and decreased enrollment numbers (shrinking the risk pool) are likely to be factors reflected in insurance companies’ filings. DFR’s actuaries will independently evaluate each of these justifications, rather than accepting them as submitted.

Anticipated key dates

• June 3: Rate filings due from health insurance companies
• July 13: First public hearing (virtual)
• July 31: Second public hearing (virtual, if needed)
• Early August: DFR issues preliminary rate decisions
• Early September: DFR issues final approval of rates

The June 3 filing date and July 13 public hearing date are set. The remaining dates may change based upon additional federal guidance. Last year, rates were delayed and not finalized until October due to delays from the federal government.

Public hearings and comments

DFR holds public hearings where insurance companies present their rate requests and respond to questions from DFR staff. The division encourages the public to attend and participate in this process. DFR accepts and reviews all public comments before final decisions are made. A link will be provided on www.oregonhealthrates.org for public comment closer to the hearing.

The most useful public input describes specific experiences with coverage, claims, network access, or plan changes. This type of input is context that helps DFR understand how rate decisions affect Oregonians and supplements the actuarial record.

The division will record the hearings and place them on the DFR rate review-specific website shortly after their conclusion.

DFR has a comprehensive overview of the rate review process, which can be found here.

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About Oregon DFR: The Division of Financial Regulation protects consumers and regulates insurance, depository institutions, trust companies, securities, and consumer financial products and services. The division is part of the Department of Consumer and Business Services, Oregon’s largest consumer protection and business regulatory agency. Visit dfr.oregon.gov and dcbs.oregon.gov.