Bulletin 2961 - November 20, 2020

State of Connecticut
Department of Banking

The Department of Banking News Bulletin

Bulletin # 2961 - Week Ending November 20, 2020

This bulletin constitutes the only official notification you will receive from this office concerning any of the following applications. Any observations you may have are solicited. Any comments should be in writing to Jorge L. Perez, Banking Commissioner, Department of Banking, 260 Constitution Plaza, Hartford, CT 06103-1800. Written comments will be considered only if they are received within ten business days from the date of this bulletin.

CONSUMER CREDIT DIVISION ACTIVITY

Order to Cease and Desist and Order Imposing Civil Penalty

On November 10, 2020, the Commissioner issued an Order to Cease and Desist and Order Imposing Civil Penalty (“Order”) in the Matter of:
Samantha S. Flores d/b/a Premier Legal and Financial Services a/k/a Premier Legal & Financial Group , Apple Valley, California (“Respondent”). The basis of the Order was that Respondent’s acting within this state as a consumer collection agency without a consumer collection agency license constitutes a violation of 36a-801(a) of the Connecticut General Statutes, and Respondent’s use of false, deceptive or misleading representations or means in connection with the collection of debt from a Connecticut resident, including representing that the debt was valid and a lawsuit would be filed imminently, constitutes a violation of Section 36a-809-11 of the Regulations of Connecticut State Agencies (“Regulations”). The Commissioner ordered Respondent to cease and desist from violating Section 36a-801(a) of the Connecticut General Statutes and Section 36a-809-11 of the Regulations, and imposed a civil penalty in the amount of $200,000 upon Respondent.

Notice of Automatic Suspension, Amended and Restated Notice of Intent to Revoke Consumer Collection Agency Licenses, Amended and Restated Notice of Intent to Issue Order to Cease and Desist, Amended and Restated Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing

On November 13, 2020, the Commissioner issued a Notice of Automatic Suspension, Amended and Restated Notice of Intent to Revoke Consumer Collection Agency Licenses, Amended and Restated Notice of Intent to Issue Order to Cease and Desist, Amended and Restated Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing (collectively, “Amended Notice”) in the Matter of:
Credit Protection Association, L. P. d/b/a Credit Protection Association, Limited Partnership , NMLS # 933191, Plano, Texas (“Respondent”). In addition to those allegations included in the original Notice of Intent to Revoke Consumer Collection Agency Licenses, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing issued by the Commissioner on November 14, 2019, the Amended Notice alleges that Respondent’s failure to maintain a surety bond that runs concurrently with the period of its consumer collection agency licenses constitutes sufficient grounds for the Commissioner to deny an application for such license under Section 36a-802(a) of the Connecticut General Statutes and constitutes sufficient grounds for the Commissioner to revoke Respondent’s licenses to act as a consumer collection agency in Connecticut from its main office and branch office pursuant to Section 36a-804(a) of the Connecticut General Statutes and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes.

Consent Order

On November 12, 2020, the Commissioner entered into a Consent Order with ReallyGreatRate, Inc. d/b/a RateDeal.com (NMLS # 2721) (“RGR”), El Segundo, California. The Consent Order was based on an examination and investigation by the Consumer Credit Division. As a result of such examination and investigation, the Commissioner alleged that between January 1, 2018 and March 4, 2020, RGR acted as a mortgage broker in Connecticut without a mortgage broker license, in violation of Section 36a-486(b)(5) of the Connecticut General Statutes in effect at such time. As part of the Consent Order, RGR paid $10,000 as a civil penalty and $1,500 for back licensing fees.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

The Hansbury Group, LLC (CD No. 127205)

On November 16, 2020, the Banking Commissioner entered a Consent Order (No. CO-20-14431-S) with respect to The Hansbury Group, LLC of 1105 Sienna Drive, Danbury, Connecticut 068111. The firm, which was previously registered as an investment adviser under the Connecticut Uniform Securities Act, was staffed by two individuals, only one of whom was based in the U.S. The Consent Order alleged that by failing to qualify the domestic individual and to retain an outside consultant as agreed in a prior letter of understanding with the department, the firm violated Section 36b-23 of the Act. The Consent Order also alleged that the firm violated Section 36b-31-6f(b) of the Regulations under the Act by failing to establish, enforce and maintain an adequate supervisory system.

The firm has since provided the agency with the agreed-upon compliance audits prepared by an outside consultant.

The Consent Order directed the firm to cease and desist from regulatory violations and fined the firm $5,000.

Dated: Tuesday, November 24, 2020

Jorge L. Perez
Banking Commissioner