Bulletin 3179 - January 24, 2025

State of Connecticut
Department of Banking

The Department of Banking News Bulletin

Bulletin # 3179 - Week Ending January 24, 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.

CONSUMER CREDIT DIVISION ACTIVITY

Block, Inc.

On January 15, 2025, the Commissioner, along with 48 state money transmission regulators (“Participating States”), entered into a Settlement Agreement and Consent Order (“Consent Order”) with Block, Inc. f/k/a Square, Inc.
(NMLS # 942933), (“Block”), Oakland, California. The Consent Order was based on a multi-state examination, identified issues related to the adequacy of Block’s Bank Secrecy Act/Anti-Money Laundering Program (“BSA/AML”), including certain anti-money laundering matters that have allegedly occurred. As part of the Consent Order, Block among other items, agreed to: (1) take corrective action to improve their internal processes and controls in compliance with BSA/AML regulations; (2) retain an independent consultant to review and report on the comprehensiveness and effectiveness of Block’s BSA/AML program; (3) correct additional deficiencies identified by the independent consultant; and (4) agreed to pay $80 million in administrative costs and penalties.

US CLAIMS CAPITAL, LLC d/b/a US Claims, US CLAIMS OPCO LLC and Collectio I Lockbox SPV, LLC

On January 21, 2025, the Commissioner entered into a Consent Order (“Consent Order”) with US CLAIMS CAPITAL, LLC d/b/a US Claims (NMLS # 2530828), (“US Claims Capital”), Boca Raton, Florida, US CLAIMS OPCO LLC (NMLS # 1598227), (“US Claims Opoc”), Boca Raton, Florida, and Collectio I Lockbox SPV, LLC (NMLS # 2552557), (“Collectio”), Boca Raton, Florida, (collectively “US Claims Entities”). The Consent Order was based on an investigation by the Consumer Credit Division. As result of such investigation, the Commissioner alleged that: 1) from July 1, 2016 to September 10, 2023, US Claims Opco made small loans to Connecticut consumers without the required small loan license, in violation of Section 36a 556(a)(1) of the Connecticut General Statutes, in effect at such time; 2) from July 1, 2016 to November 2, 2023, US Claims Capital engaged in servicing and collection functions in connection with small loans made to Connecticut consumers on or after July 1, 2016, to at least September 2022, without the required small loan license, in violation of Section 36a-556(a)(4) of the Connecticut General Statutes, in effect at such time; and 3) from July 1, 2016 to December 4, 2023, Collectio received payments of principal and interest in connection with small loans made to Connecticut consumers on or after July 1, 2016, to at least September 2022, without the required small loan license, in violation of Section 36a-556(a)(4) of the Connecticut General Statutes, in effect at such time. As part of the Consent Order, US Claim Entities paid $10,000 as a civil penalty and $2,400 as back licensing fees. Also, as part of the Consent Order, US Claim Entities shall refund monies in the amount of $219,161 to identified Connecticut consumers.

FIRST PORTFOLIO VENTURES II, LLC

On January 21, 2025, the Commissioner entered into a Consent Order with FIRST PORTFOLIO VENTURES II, LLC (NMLS # 2268275) (“FPVII”), Peachtree Corners, Georgia. The Consent Order was based on an investigation by the Consumer Credit Division. As a result of such investigation, the Commissioner alleged that FPVII acted as a consumer collection agency in this state without the required license since at least February 2022 in violation of Section 36a-801(a) of the Connecticut General Statutes. As part of the Consent Order, FPVII paid $10,000 as a civil penalty and $400 as back licensing fees.

Oasis Legal Finance, LLC d/b/a Oasis Financial

On January 24, 2025, the Commissioner entered into a Consent Order (“Consent Order”) with Oasis Legal Finance, LLC d/b/a Oasis Financia l (NMLS # 1512432), (“Oasis Financial”), Rosemont, Illinois. The Consent Order was based on an investigation by the Consumer Credit Division. As result of such investigation, the Commissioner alleged that from October 2016 to October 2022, Oasis Financial: (1) made at least 2,613 small loans to Connecticut borrowers without the required small loan license, in violation of Section 36a-556(a)(1) of the Connecticut General Statutes, in effect at such time; (2) offered small loans to prospective Connecticut borrowers or solicited Connecticut residents for small loans without the required license, in violation of Section 36a-556(a)(2) of the Connecticut General Statutes, in effect at such time; and (3) advertised or caused to be advertised in this state small loans without the required license, in violation of Section 36a-556(a)(6) of the Connecticut General Statutes, in effect at such time. The Commissioner also alleged that from November 2016 to at least January 2024, Oasis Financial received payments of principal and interest in connection with small loans made to Connecticut borrowers without the required small loan license, in violation of Section 36a-556(a)(4) of the Connecticut General Statutes, in effect at such time. As part of the Consent Order, Oasis Financial paid $10,000 as a civil penalty and $1,200 as back licensing fees. Also, as part of the Consent Order, Oasis Financial shall refund monies in the total amount of $1,086,487 to identified Connecticut consumers.

Dated: Tuesday, January 28, 2025

Jorge L. Perez
Banking Commissioner