Bulletin 3177 - January 10, 2025

State of Connecticut
Department of Banking

The Department of Banking News Bulletin

Bulletin # 3177 - Week Ending January 10, 2025

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 directed to Jorge L. Perez, Banking Commissioner. Written comments will be considered only if they are received within ten business days from the date of this bulletin.

CREDIT UNION ACTIVITY

Field of Membership Change

On January 9, 2025, the Commissioner approved the application of Nutmeg State Financial Credit Union (Rocky Hill, CT) to amend its bylaws pursuant to section 36a-437a(h)(3) of the Connecticut General Statutes to remove from its field of membership members and employees of AAA Club Alliance.

CONSUMER CREDIT DIVISION ACTIVITY

Consent Order

On January 8, 2025, the Commissioner entered into a Consent Order with Betrlink, LLC (NMLS # 1979645) (“Betrlink”), New York, New York. The Consent Order was based on an investigation by the Consumer Credit Division. As a result of such investigation, the Commissioner alleged that since at least June 27, 2022, Betrlink engaged in the business of money transmission in this state without the required license by providing dedicated accounts to, and transmitting funds on behalf of, approximately 20 Connecticut residents, in violation of Section 36a-597(a) of the Connecticut General Statutes, in effect at such time. As part of the Consent Order, Betrlink paid $5,000 as a civil penalty, $3,750 as back licensing fees and agreed to not process fees for debt negotiation services in excess of the amounts permitted by the Commissioner’s Schedule of Maximum Fees established pursuant to Section 36a-671b(b) of the Connecticut General Statutes for Connecticut residents.

Consent Order

On January 6, 2025, the Commissioner entered into a Consent Order with MTAG Services, LLC d/b/a Station 31 Partners d/b/a Tax Lien Support (NMLS # 1489687) (“MTAG”), Mount Pleasant, South Carolina. The Consent Order was based on an investigation by the Consumer Credit Division. As a result of such investigation, the Commissioner alleged that MTAG acted as a consumer collection agency in this state without the required license since at least January 2022, in violation of Section 36a-801(a) of the Connecticut General Statutes. As part of the Consent Order, MTAG paid $10,000 as a civil penalty and $800 as back licensing fees.

Settlement Agreement and Consent Order

On December 31, 2024, the Commissioner, along with 50 state mortgage regulators (“Participating States”), entered into a Settlement Agreement and Consent Order (“Consent Order”) with Lakeview Loan Servicing, LLC , (NMLS # 391521) Coral Gables, Florida, Pingora Loan Servicing, LLC (NMLS # 129911) Denver, Colorado, Community Loan Servicing, LLC (NMLS # 2469), Coral Gables, Florida, Bayview Asset Management, LLC (NMLS # 102563), Coral Gables, Florida, (collectively “Respondents”). The Consent Order was based on a multi-state cybersecurity examination. The Commissioner, together with the Participating States, alleged that Respondents had deficient information technology (“IT”) and cybersecurity practices including, but not limited to, insufficient IT patch management, insufficient centralized IT vulnerability remediation monitoring and enterprise reporting, insufficient IT inventory tracking, and failure to appropriately encrypt certain personally identifiable information when that data was at rest As part of the Consent Order, Respondents among other items, agreed to: (1) maintain a comprehensive Risk Management Program and a Third-Party Service Provider Risk Management Program; (2) report regularly to a state mortgage regulators executive committee to ensure both the adequacy of the risk management programs; (3) agreed to pay $20 million in administrative costs and penalties.

Consent Order

On January 9, 2025, the Commissioner entered into a Consent Order with ARS Portfolio Services, LLC (NMLS # 197476) (“ARS”), Williamsville, New York. The Consent Order was based on an investigation by the Consumer Credit Division. As a result of such investigation, the Commissioner alleged that since at least December 2022 ARS engaged in the business of a sales finance company in Connecticut without a license, in violation of Section 36a-536 of the Connecticut General Statutes, by receiving payments of principal and interest from Connecticut retail buyers under retail installment contracts or installment loan contracts as a servicer on behalf of holders of those contracts As part of the Consent Order, ARS paid $10,000 as a civil penalty and $800 as back licensing fees.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

Edward D. Jones & Co., L.P. (CRD No. 250)

On December 20, 2024, the Banking Commissioner entered a Consent Order (No. CO-23-11056-S) with respect to Edward D. Jones & Co., L.P.
, a Connecticut-registered broker-dealer located at 12555 Manchester Road, St. Louis, Missouri, 63131-3710.

The action was an outgrowth of a $17 million multi-state enforcement settlement. That investigation focused on the firm charging front-load commissions for investments in Class A mutual fund shares in situations where the customer sold or moved the mutual fund shares sooner than originally anticipated. The multi-state investigation found that the firm failed to implement sufficient supervisory procedures to detect the irregularities. By the same token, the Banking Commissioner alleged that the firm violated Section 36b-31-6f(b) of the Regulations under the Connecticut Uniform Securities by failing to establish and maintain reasonably designed supervisory procedures.

The Connecticut Consent Order directed the firm to pay $335,754.72 to the state, $320,754.72 of which constituted an administrative fine and $15,000 of which constituted Connecticut’s allocated share of the investigative costs involved in the multistate settlement.

Dated: Tuesday, January 14, 2025

Jorge L. Perez
Banking Commissioner