Bulletin 3191 - April 18, 2025

State of Connecticut
Department of Banking

The Department of Banking News Bulletin

Bulletin # 3191 - Week Ending April 18, 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.

BANK ACTIVITY

Interstate Loan Production Office

On April 14, 2025,
Northpointe Bank
, a Michigan-chartered bank, filed an application pursuant to Section 36a-412(d) of the Connecticut General Statutes, seeking approval to establish a loan production office at 222 Old Boston Road in Old Saybrook, Connecticut. The proposed opening date for the location is May of 2025.

CONSUMER CREDIT DIVISION ACTIVITY

Woodbridge Mortgage LLC, Lionel Young Kim and George Guorong Wang

On April 9, 2025, the Commissioner issued a
Notice of Intent to Revoke Mortgage Broker License, Notice of Intent to Revoke Mortgage Loan Originator Licenses, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing in the matter of Woodbridge Mortgage LLC (NMLS # 72664), (“Woodbridge”), Glastonbury, Connecticut , Lionel Young Kim (NMLS # 229307) (“Kim”) and George Guorong Wang (NMLS # 111145) (“Wang”) (collectively, “Respondents”). The Order and Notice was the result of an investigation by the Consumer Credit Division.

The Commissioner alleges in the Order and Notice that Woodbridge: (1) engaged in an unfair or deceptive practice and received origination compensation based on the terms of mortgage transactions by issuing rebate checks for closing costs to at least seven Connecticut borrowers, which rebates were not reflected on the Closing Disclosures or otherwise disclosed to lenders, in violation of Section 36a-498e(a)(2) of the Connecticut General Statutes, in effect at such time, Section 36a 678(a) of the Connecticut General Statutes, and 12 C.F.R. Section 1026.36(d)(1) of Regulation Z (Truth in Lending Act); (2) failed to maintain complete loan files of at least 27 mortgage transactions by not maintaining various documents necessary to the mortgage transactions, including, but not limited to, copies of initial and final mortgage loan applications, income and asset verifications, Loan Estimates and Closing Disclosures, in violation of Section 36a 493(a) of the Connecticut General Statutes; (3) failed to file accurate Mortgage Call Reports on the Nationwide Multistate Licensing System and Registry (“NMLS”), in violation of Section 36a-534b(c) of the Connecticut General Statutes; (4) failed to provide an adverse action notice for at least one mortgage loan, in violation of 12 C.F.R. Section 1002.9(a)(1) of Regulation B (Equal Credit Opportunity Act) and Section 36a-498e(a)(7) of the Connecticut General Statutes, in effect at such time, and failed to maintain records of the adverse action notice for a mortgage loan, in violation of Section 36a 493(a) of the Connecticut General Statutes; (5) required consumers to submit documents to verify information prior to the issuance of a Loan Estimate, in violation of 12 C.F.R. Section 1026.19(e)(2)(iii) of Regulation Z (Truth in Lending Act), and Section 36a-678(a) of the Connecticut General Statutes; (6) failed to include its company NMLS unique identifier on business cards, in violation of Section 36a-498d(a)(2) of the Connecticut General Statutes; (7) made a false, deceptive or misleading statement on its website indicating that Woodbridge lends in Connecticut, when it is solely licensed in Connecticut as a mortgage broker, in violation of Section 36a-498d(b)(2) of the Connecticut General Statutes; (8) failed to retain records of mortgage loan application that had been withdrawn, in violation of 12 C.F.R. Section 1002.12(b)(3) of Regulation B (Equal Credit Opportunity Act) and Section 36a-493(a) of the Connecticut General Statutes; (9) failed to comply with Sections 36a-485 to 36a-498e, inclusive, 36a 498h, 36a 534a and 36a-534b of the Connecticut General Statutes, and failed to comply with provisions of Regulation Z (Truth in Lending Act) and Regulation B (Equal Credit Opportunity Act), in violation of Section 36a 498e(a)(8) of the Connecticut General Statutes, in effect at such time; and (10) failed to establish, enforce and maintain policies and procedures reasonably designed to achieve compliance with Section
36a-498e(a) of the Connecticut General Statues, in effect at such time, in violation of Section 36a 498e(b)(1) of the Connecticut General Statues, in effect at such time.

Additionally, the Commissioner alleges in the Order and Notice that Kim: (1) failed to include his NMLS unique identifier on business cards, in violation of Section 36a-498d(a)(3) of the Connecticut General Statutes; (2) failed to establish, enforce and maintain policies and procedures reasonably designed to achieve compliance with subsection (a) of Section 36a-498e of the Connecticut General Statutes, in effect at such time in violation of Section 36a 498e(b)(1) of the Connecticut General Statutes, in effect at such time; and (3) directly or indirectly, engaged in an unfair or deceptive practice by facilitating the issuance of rebate checks for closing costs to at least seven Connecticut borrowers, which rebates were not reflected on the Closing Disclosures or otherwise disclosed to lenders , in violation of Section 36a-498e(a)(2) of the Connecticut General Statutes, in effect at such time.

Lastly, the Commissioner alleges in the Order and Notice that Wang: (1) failed to include his NMLS unique identifier and Woodbridge’s NMLS unique identifier on business cards, in violation of Sections 36a-498d(a)(2) and 36a-498d(a)(3) of the Connecticut General Statutes; (2) directly or indirectly, engaged in an unfair or deceptive practice by facilitating the issuance of rebate checks for closing costs to at least seven Connecticut borrowers, which rebates were not reflected on the Closing Disclosures or otherwise disclosed to lenders, in violation of Section 36a-498e(a)(2) of the Connecticut General Statutes, in effect at such time; (3) solicited, advertised or entered into contracts for specific interest rates, points or other financing terms with borrowers that were not actually provided by the lenders, in violation of Section 36a-498e(a)(5) of the Connecticut General Statutes, in effect at such time; and (4) made false or deceptive statements or representations to borrowers with regard to the rates, points or other financing terms or conditions available for a residential mortgage loan or engaged in bait and switch advertising, in violation of Section 36a-498e(a)(9) of the Connecticut General Statutes, in effect at such time.

Respondents were afforded an opportunity to request a hearing with regard to the allegation set forth in the Order and Notice.

Accelerated Debt Settlement Inc. d/b/a Accelerated Debt Solutions, Financial Solutions Group LLC and Jeffrey A. Lakes

On April 15, 2025, the Commissioner entered into a Consent Order with Accelerated Debt Settlement Inc. d/b/a Accelerated Debt Solutions, NMLS # 2621854 (“ADS”), Cheyenne, Wyoming, Financial Solutions Group LLC (“FSG”) , Fishers, Indiana and Cheyenne, Wyomin g and Jeffrey A. Lakes (“Lakes”), (collectively, “Respondents”). The Consent Order was based on an investigation by the Consumer Credit Division. The Consent Order resolved allegations made by the Commissioner in a Temporary Order to Cease and Desist, Order to Make Restitution, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing (“Order and Notice”) against Respondents on December 9, 2024.

The Commissioner alleged in the Order and Notice that ADS: (1) engaged or offered to engage in debt negotiation services with at least 130 residents in Connecticut without obtaining the required license, in violation of Section 36a-671(b) of the Connecticut General Statutes; (2) entered into contracts with at least 2 Connecticut residents that did not include the “Debtor’s three-day right to cancel” disclosure required in Connecticut, in violation of Section 36a-671b(a) of the Connecticut General Statutes; (3) charged fees in excess of amounts permitted by the Schedule of Maximum Fees and prior to ADS fully performing any debt negotiation services, in violation of Section 36a 671b(b) of the Connecticut General Statutes; (4) engaged in an unfair or deceptive practice and obtained property by fraud or misrepresentation by enrolling customers in its debt negotiation services and receiving fees as a result of various false representations, in violation of subdivisions (2) and (3) of Section 36a-671f of the Connecticut General Statutes; (5) failed to comply with provisions of sections 36a 671 to 36a-671e, inclusive, or regulations adopted under said sections, or state or federal law, including the Telemarketing Sales Rule, in violation of Section 36a-671f(4) of the Connecticut General Statutes; (6) made false or deceptive statements or representations in connection with its debt negotiation program, in violation of Section 36a-671f(8) of the Connecticut General Statutes; and (7) failed to establish, enforce and maintain policies and procedures for supervising employees, agents and office operations that are reasonably designed to achieve compliance with applicable debt negotiation laws and regulations, in violation of Section 36a 671f(9) of the Connecticut General Statutes.

The Commissioner also alleged in the Order and Notice that FSG engaged or offered to engage in debt negotiation in Connecticut without obtaining the required license, in violation of Section 36a 671(b) of the Connecticut General Statutes; and that Lakes, directly or indirectly, failed to establish, enforce and maintain policies and procedures for supervising employees, agents and office operations that are reasonably designed to achieve compliance with applicable debt negotiation laws and regulations, in violation of Section 36a 671f(9) of the Connecticut General Statutes.

As part of the Consent Order, ADS and FSG agreed to provide refunds to Connecticut consumers of fees received for debt negotiation services in the total amount of $779,910. The Consent Order also barred ADS and FSG from, directly or indirectly, offering or engaging in debt negotiation in this state and Lakes from acting, directly or indirectly, as an owner, officer, director, or other control person of any person offering or engaging in debt negotiation in this state.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

Metric Financial, LLC (CRD No. 297325)

On April 17, 2025, the Banking Commissioner entered into a Stipulation and Agreement (No. ST-25-202412-S) with Metric Financial, LLC , a Connecticut-registered investment adviser located at 945 Hopmeadow Street, Simsbury, Connecticut 06070.

The Stipulation and Agreement alleged that, in 2023, the firm failed to meet the minimum capital requirements in Section 36b-31-9c of the Regulations under the Connecticut Uniform Securities Act. The firm has since taken curative steps to rectify the deficiency.

In resolution of the matter, the firm agreed to refrain from violative conduct and to pay a $2,500 fine to the agency.

Dated: Tuesday, April 22, 2025

Jorge L. Perez
Banking Commissioner