2025-01-01 | Bulletin 2025-9The Oregon Division of Financial Regulation issued Bulletin 2025-9 to clarify that state investment advisers and their representatives may not charge fees solely for availability if no advisory services are rendered. This guidance interprets Oregon Administrative Rule 441-205-0145, classifying such charges as unreasonable advisory fees and unethical business practices that breach fiduciary duties. The division emphasizes that reasonableness depends on whether fees are commensurate with documented services, regardless of how the fees are labeled.