Consent Order: Imperial Multisolutions LLC d/b/a Imperial Envios

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IN THE MATTER OF: *
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IMPERIAL MULTISOLUTIONS LLC * CONSENT ORDER d/b/a IMPERIAL ENVIOS 03/21/2022 * NMLS # 2339198 * * (“IMPERIAL”) * *

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WHEREAS, the Banking Commissioner (“Commissioner”) is charged with the administration of
Part IV of Chapter 668, Sections 36a-580 to 36a-589, inclusive, of the Connecticut General Statutes,
“Check Cashing Services”, and Sections 36a-585-1, 36a-588-1, 36a-588-3 and 36a-588-4 of the Regulations of Connecticut State Agencies (“Regulations”); WHEREAS, IMPERIAL is a Connecticut limited liability company with a business address of 365 Westport Avenue, Suite 5, Norwalk, Connecticut; WHEREAS, IMPERIAL is not currently, nor has it ever been, licensed to engage in the business of cashing checks, drafts or money orders for consideration in Connecticut; WHEREAS, on April 3, 2022, IMPERIAL submitted an application to obtain a check cashing license, which application is currently pending; WHEREAS, the Commissioner, through the Consumer Credit Division of the Department of Banking, conducted an investigation pursuant to Section 36a-17 of the 2022 Supplement to the General Statutes into the activities of IMPERIAL to determine if it had violated, was violating or was about to violate the provisions of the Connecticut General Statutes and Regulations within the jurisdiction of the Commissioner;

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  WHEREAS, as a result of such investigation, the Commissioner alleges that IMPERIAL, in or about April 2022, engaged in the business of cashing checks, drafts or money orders for consideration in Connecticut without licensure at its primary business address, in violation of Section 36a-581(a) of the Connecticut General Statutes; WHEREAS, the Commissioner believes that such allegation would support initiation of enforcement proceedings against IMPERIAL, including proceedings to issue a cease and desist order against IMPERIAL pursuant to Section 36a-587(b) of the Connecticut General Statutes and Section 36a-52(a) of the 2022 Supplement to the General Statutes, and impose a civil penalty of up to one hundred thousand dollars ($100,000) per violation on IMPERIAL pursuant to Section 36a-587(b) of the Connecticut General Statutes and Section 36a-50(a) of the 2022 Supplement to the General Statutes; WHEREAS, initiation of such enforcement proceedings may constitute a “contested case” within the meaning of Section 4-166(4) of the Connecticut General Statutes; WHEREAS, Section 4-177(c) of the Connecticut General Statutes and Section 36a-1-55(a) of the Regulations of Connecticut State Agencies provide that a contested case may be resolved by consent order, unless precluded by law; WHEREAS, IMPERIAL herein represents that it ceased cashing checks for customers in May of 2022 when the Division notified it of the licensure requirements and further represents that it shall not do so without licensure in the future; WHEREAS, both the Commissioner and IMPERIAL acknowledge the possible consequences of formal administrative proceedings, and IMPERIAL voluntarily agrees to consent to the entry of the sanctions imposed below without admitting or denying the allegation contained herein, and solely for the purpose of obviating the need for further formal administrative proceedings concerning the allegation contained herein; WHEREAS, the Commissioner and IMPERIAL now desire to resolve the matters set forth herein;

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  WHEREAS, IMPERIAL specifically assures the Commissioner that the violation described herein shall not occur in the future; WHEREAS, IMPERIAL acknowledges that this Consent Order is a public record and is a reportable event for purposes of the regulatory disclosure questions on the Nationwide Multistate Licensing System and Registry (“NMLS”), as applicable; AND WHEREAS, IMPERIAL, through its execution of this Consent Order, voluntarily agrees to waive its procedural rights, including a right to notice and an opportunity for hearing as it pertains to the allegation set forth herein, and voluntarily waives its right to seek judicial review or otherwise challenge or contest the validity of this Consent Order. CONSENT TO ENTRY OF SANCTIONS WHEREAS, IMPERIAL, through its execution of this Consent Order, consents to the Commissioner’s entry of a Consent Order imposing the following sanctions:
  1. No later than the date this Consent Order is executed by IMPERIAL, it shall remit to the
  Department of Banking by electronic funds transfer, cashier’s check, certified check or money order made payable to “Treasurer, State of Connecticut”, the sum of One Thousand Dollars ($1,000) as a civil penalty; and
  2. Imperial shall not engage in the business of cashing checks, drafts or money orders for
  consideration without obtaining a license to operate a check cashing general facility or limited facility for each location where such business is to be conducted, in violation of
  Section 36a-581(a) of the Connecticut General Statutes.
  CONSENT ORDER
  NOW THEREFORE, the Commissioner enters the following:
  1. The Sanctions set forth above be and are hereby entered;
  2. Upon issuance of this Consent Order by the Commissioner, this matter will be resolved and the
  Commissioner will not take any future enforcement action against IMPERIAL based upon the allegation set forth herein; provided that issuance of this Consent Order is without prejudice to the right of the Commissioner to take enforcement action against IMPERIAL based upon a violation of this Consent Order or the matters underlying its entry, if the Commissioner determines that compliance with the terms herein is not being observed or if any representation made by IMPERIAL and reflected herein is subsequently discovered to be untrue;

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3. IMPERIAL shall not take any action or make or permit to be made any public statement,
   including in regulatory filings or otherwise, denying, directly or indirectly, any allegation referenced in this Consent Order or create the impression that this Consent Order is without factual basis;
4. Subject to the foregoing, and so long as this Consent Order is promptly disclosed by
   IMPERIAL and its control persons on NMLS, as applicable, nothing in the issuance of this Consent Order shall adversely affect the ability of IMPERIAL to apply for or obtain an initial license or renewal license under Part IV of Chapter 668, Sections 36a-580 to 36a-589, inclusive, of the Connecticut General Statutes, provided all applicable legal requirements for such license are satisfied and the terms of this Consent Order are followed;
5. This Consent Order shall be binding upon IMPERIAL and its successors and assigns; and
6. This Consent Order shall become final when issued.
   /s/____________________________
   Issued at Hartford, Connecticut Jorge Perez this 24th day of October 2022. Banking Commissioner

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  I, Tatiana C. Rodriguez, state that I have read the foregoing Consent Order; that I know and fully understand its contents; that I agree freely and without threat or coercion of any kind to comply with the sanctions entered and terms and conditions ordered herein; and that I voluntarily agree to enter into this Consent Order, expressly waiving the procedural rights set forth herein as to the matters described herein. By: /s/____________________________ Name: Tatiana C. Rodriguez Title: Owner IMPERIAL MULTISOLUTIONS LLC d/b/a IMPERIAL ENVIOS 03/21/2022 State of: Connecticut County of: Fairfield On this the 27th day of September 2022, before me, Bryan Martinez , the undersigned officer, personally appeared Tatiana C. Rodgriguez, who acknowledged himself/herself to be the Owner of IMPERIAL MULTISOLUTIONS LLC d/b/a IMPERIAL ENVIOS 03/21/2022, a member managed/manager managed limited liability company, and that he/she as such Owner, being authorized so to do, executed the foregoing instrument for the purposes therein contained, by signing the name of the limited liability company by himself/herself as Owner. In witness whereof I hereunto set my hand. /s/____________________________ Notary Public Date Commission Expires: 06/30/2026