Order to Cease and Desist and Imposing Civil Penalty on Students Loan Services LLC

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IN THE MATTER OF: * ORDER TO CEASE AND DESIST * STUDENTS LOAN SERVICES LLC * AND * (“Respondent”) * ORDER IMPOSING CIVIL PENALTY *

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I. PRELIMINARY STATEMENT WHEREAS, the Banking Commissioner (“Commissioner”) is charged with the administration of Sections 36a-671 to 36a-671f, inclusive, of Part II of Chapter 669 of the Connecticut General Statutes, “Debt Adjusters and Debt Negotiation”; WHEREAS, the Commissioner, through the Consumer Credit Division of the Department of Banking, conducted an investigation of the activities of Respondent, pursuant to the authority granted by Section 36a-17 of the Connecticut General Statutes, to determine if it had violated, was violating or was about to violate the provisions of the Connecticut General Statutes within the jurisdiction of the Commissioner; WHEREAS, as a result of such investigation, on February 24, 2021, the Commissioner issued an Order to Make Restitution (“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 (collectively “Order and Notice”) against Respondent, which Order and Notice is incorporated herein by reference; WHEREAS, on February 24, 2021, the Order and Notice was caused to be mailed by certified mail, return receipt requested, to Respondent (Certified Mail No. 70192970000078913012);

• 2 - WHEREAS, the Order and Notice provided Respondent with the opportunity for a hearing, and stated that if a hearing was not requested by Respondent within 14 days of its receipt or if Respondent failed to appear at any such hearing, the allegation would be deemed admitted, the Order to Make Restitution shall remain in effect and become permanent against Respondent, and the Commissioner would issue an order that Respondent cease and desist from violating Section 36a-671(b) of the Connecticut General Statutes, and may order a civil penalty in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation be imposed upon Respondent; WHEREAS, on February 27, 2021, Respondent received the Order and Notice; WHEREAS, Respondent failed to request a hearing within the prescribed time period; WHEREAS, the Commissioner alleged in the Order and Notice, with respect to the activity described therein, that Respondent’s engaging or offering to engage in debt negotiation in this state without obtaining the required license constitutes at least one violation of Section 36a-671(b) of the Connecticut General Statutes, in effect at such time. Such violation forms the basis to issue an order to cease and desist pursuant to Sections 36a-671a(b) and 36a-52(a) of the Connecticut General Statutes, to issue an order to make restitution pursuant to Sections 36a-671a(b) and 36a-50(c) of the Connecticut General Statutes, and impose a civil penalty pursuant to Sections 36a-671a(b) and 36a-50(a) of the Connecticut General Statutes; WHEREAS, also in the Order and Notice, the Commissioner ordered, pursuant to Section 36a-50(c) of the Connecticut General Statutes, that not later than 30 days from the date the Order to Make Restitution became permanent, Respondent shall repay to any Connecticut debtor who entered into an agreement for debt negotiation services with Respondent on and after October 1, 2009, any fees paid by such Connecticut debtor to Students Loan Services LLC, plus interest, and provide evidence of such repayments to the Director of the Consumer Credit Division; WHEREAS, Section 36a-52(a) of the Connecticut General Statutes provides, in pertinent part, that “[i]f the person does not request a hearing within the time specified in the notice or fails to appear at the

• 3 - hearing, the commissioner shall issue an order to cease and desist against the person. No such order shall be issued except in accordance with the provisions of chapter 54”; WHEREAS, Section 36a-50(a)(2) of the Connecticut General Statutes provides, in pertinent part, that “[i]f such person does not request a hearing within the time specified in the notice or fails to appear at the hearing, the commissioner may, as the facts require, order that a civil penalty not exceeding one hundred thousand dollars per violation be imposed upon such person”; WHEREAS, Section 36a-50(a)(3) of the Connecticut General Statutes provides that “[e]ach action undertaken by the commissioner under this subsection shall be in accordance with the provisions of chapter 54”; AND WHEREAS, Section 36a-1-31(a) of the Regulations of Connecticut State Agencies provides, in pertinent part, that “[w]hen a party fails to request a hearing within the time specified in the notice, the allegations against the party may be deemed admitted. Without further proceedings or notice to the party, the commissioner shall issue a final decision in accordance with section 4-180 of the Connecticut General Statutes and section 36a-1-52 of the Regulations of Connecticut State Agencies”. II. FINDINGS OF FACT AND CONCLUSIONS OF LAW

1. The Commissioner finds that the matters asserted, as set forth in paragraphs 7 through 13, inclusive, of Section II of the Order and Notice, shall constitute findings of fact within the meaning of Section 4-180(c) of the Connecticut General Statutes, and that the conclusions, as set forth in Section III of the Order and Notice, shall constitute conclusions of law within the meaning of Section 4-180(c) of the Connecticut General Statutes and Section 36a-1-52 of the Regulations of Connecticut State Agencies.
2. The Commissioner finds that Respondent has engaged in acts or conduct which, pursuant to Sections 36a-671a(b) and 36a-52(a) of the Connecticut General Statutes, forms the basis to issue an order to cease and desist against Respondent, and, pursuant to Sections 36a-671a(b) and 36a-50(a) of the Connecticut General Statutes, forms the basis to impose a civil penalty upon Respondent.

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3. The Commissioner finds that the Order and Notice was given in compliance with Sections 36a-52(a), 36a-50(a), 36a-50(c) and 4-177 of the Connecticut General Statutes. III. ORDER Having read the record, I HEREBY ORDER, pursuant to Sections 36a-671a(b), 36a-52(a) and 36a-50(a) of the Connecticut General Statutes, that:
4. Students Loan Services LLC CEASE AND DESIST from violating Section 36a-671(b) of the Connecticut General Statutes;
5. A CIVIL PENALTY of One Hundred Thousand Dollars ($100,000) be imposed upon Students Loan Services LLC, to be remitted to the Department of Banking by wire transfer, cashier’s check, certified check or money order, made payable to “Treasurer, State of Connecticut”, no later than thirty (30) days from the date this Order is mailed;
6. The ORDER TO MAKE RESTITUTION issued on February 24, 2021, remains in effect and became permanent against Students Loan Services LLC on March 13, 2021; and
7. This Order shall become effective when mailed. Dated at Hartford, Connecticut, this 29th day of April 2021. /s/_____________________________________ Jorge L. Perez Banking Commissioner This Order was sent by certified mail, return receipt requested, to Respondent on April 30, 2021. Students Loan Services LLC Certified Mail No. 7020 2450 0000 7026 7462 1905 E. 17th Street Santa Ana, CA 92705