Bulletin 3215 - October 3, 2025

State of Connecticut
Department of Banking

The Department of Banking News Bulletin

Bulletin # 3215 - Week Ending October 3, 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

FuturePay Holdings Inc. d/b/a FuturePay

On September 25, 2025, the Commissioner issued a Notice of Intent to Revoke and Refuse to Renew Small Loan License and Notice of Right to Hearing , (“Notice”), in the matter of FuturePay Holdings Inc. d/b/a FuturePay (NMLS # 2366387), (“Respondent”), New York, New York. The Notice was the result of an investigation by the Consumer Credit Division. The Commissioner alleges in the Notice that Respondent failed to submit the required financial statements for renewal of its small loan license pursuant to Section 36a-563 of the Connecticut General Statutes, rendering the Commissioner unable to determine that the financial responsibility of Respondent and constituting sufficient grounds for the Commissioner to deny an application for such license under Section 36a-563(a) of the Connecticut General Statutes, and in turn would be sufficient grounds for the Commissioner to revoke and refuse to renew Respondent’s small loan license in Connecticut pursuant to Section 36a-570(a) and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes. Respondent was afforded an opportunity to request a hearing with regard to the allegation set forth in the Notice.

Zions Debt Holdings, LLC, Christopher Thayne Carter and Brian Scott Fuller

On September 25, 2025, the Commissioner issued 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”), in the matter of Zions Debt Holdings, LLC (NMLS # 1906874), (“Zions”), Orem, Utah, and its control persons Christopher Thayne Carter (NMLS # 1888989) and Brian Scott Fuller (NMLS # 1887837) (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 Zions: (1) acted within this state as a consumer collection agency without a consumer collection agency license, in violation of Section 36a-801(a) of the Connecticut General Statutes and the Consent Order issued by the Connecticut Department of Banking against Zions on December 31, 2024 (“2024 Consent Order”); (2) contacted a Connecticut consumer via electronic mail in a harassing or abusive manner in connection with the collection of a debt in violation of Section 36a-809-10 of the Regulations of Connecticut State Agencies (“Regulations”); and (3) used false, deceptive or misleading representations in connection with the collection of a debt, including using a false representation or deceptive means to collect or attempt to collect a debt by holding itself out to Connecticut consumers as a consumer collection agency while unlicensed in Connecticut, in violation of subdivision (10) of Section 36a-809-11 of the Regulations and the 2024 Consent Order. Additionally, the Commissioner alleges that Respondents 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 consumer collection laws and regulations, in violation of Section 36a-805(a)(16) of the Connecticut General Statutes. The Commissioner found that the public welfare required immediate action to issue a Temporary Order to Cease and Desist against Zions. Respondents were afforded an opportunity to request a hearing with regard to the allegations set forth in the Order and Notice.

Allied Mortgage Group, Inc.

On September 29, 2025, the Commissioner entered into a Consent Order with Allied Mortgage Group, Inc.
(NMLS # 1067), (“Allied”), Bala Cynwyd, Pennsylvania. The Consent Order was based on an examination by the Consumer Credit Division. As result of such examination, the Commissioner alleged that from October 1, 2023 through February 12, 2025, Allied engaged the services of and purchased seven (7) Connecticut leads from an unlicensed lead generator, in violation of Section 36a-486(b)(1) of the Connecticut General Statues. As part of the Consent Order, Allied paid $5,000 as a civil penalty.

Debt Direct Portfolio Management, LLC

On October 2, 2025, the Commissioner entered into a Consent Order with Debt Direct Portfolio Management, LLC (NMLS # 1856637), (“Debt Direct”), Buffalo, New York. The Consent Order was based on an investigation by the Consumer Credit Division. As result of such investigation, the Commissioner alleged that from at least August 2019 to January 2025, Debt Direct: (1) engaged in small loan activity in Connecticut without a license, by purchasing, acquiring or receiving assignment of small loans made to Connecticut borrowers, in violation of Section 36a 556(a)(5) of the Connecticut General Statutes and (2) acted as a consumer collection agency in Connecticut without a license, by collecting on eight small loans made to Connecticut borrowers that were acquired from another person and were either delinquent or in default at the time acquired, in violation of Section 36a-801(a) of the Connecticut General Statutes. As part of the Consent Order, Debt Direct agreed to pay $20,000 as a civil penalty and $3,000 for back licensing fees.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

Horang Securities LLC (CRD No. 6004)

On October 3, 2025, the Banking Commissioner entered a Consent Order (No. CO-24-20249-S) with respect to Horang Securities, LLC , a Connecticut-registered broker-dealer having its principal office at 27 W 72nd Street, New York, New York 10023. The Consent Order had been preceded by an April 24, 2024 Notice of Intent to Revoke Registration as a Broker-dealer and Notice of Right to Hearing (No. NRC-24-20249-S). That action had alleged that the firm failed to maintain a broker-dealer agent registration in violation of Section 36b-31-6a(a) of the Regulations under the Connecticut Uniform Securities Act, and that the firm was not responsive to the Division’s requests that the problem be remedied.

The Consent Order fined the firm $2,500 and directed it to cease and desist from regulatory violations.

Dated: Tuesday, October 7, 2025

Jorge L. Perez
Banking Commissioner