Per the definitions made in ORS 646A.274 - Definitions for ORS 646A.276 and 646A.278, one could make the argument that the same applies to TriMet transfers. A TriMet transfer is "a
prefunded record evidencing a promise that the issuer will provide
goods or services to the owner of the record in the amount shown in the
Additionally, TriMet transfers do not fit the excluded definitions, as those very specifically outline "prepaid telephone calling cards, prepaid commercial mobile radio services" ... and "...usable with more than one seller of goods or services."