Bulletin 3151 - July 12, 2024

Bulletin # 3151 - Week Ending July 12, 2024

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 in writing to Jorge L. Perez, Banking Commissioner, Department of Banking, 260 Constitution Plaza, Hartford, CT 06103-1800. Written comments will be considered only if they are received within ten business days from the date of this bulletin.

CONSUMER CREDIT DIVISION ACTIVITY

Order to Cease and Desist and Order Imposing Civil Penalty

On July 2, 2024, the Commissioner issued an Order to Cease and Desist and Order Imposing Civil Penalty ("Order") in the Matter of: COMPATTIA ROCCIA MANAGEMENT GROUP, LLC a/k/a CRMG, NMLS # 2292547 ("Respondent"), Tonawanda, New York. The basis of the Order was that: (1) Respondent 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 in effect at such time, which form the basis to issue an order to cease and desist against Respondent pursuant to Sections 36a-804(b) and 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty upon Respondent pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes; (2) Respondent failed to provide information requested during investigation or otherwise cooperate with the Commissioner, in violation of Section 36a-17(e) of the Connecticut General Statutes, which form the basis to issue an order to cease and desist against Respondent pursuant to Sections 36a-804(b) and 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty upon Respondent pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes; and 3) Respondent failed to establish a system for supervision and compliance under Section 36a-805(a)(15) of the Connecticut General Statutes, which forms the basis to issue an order to cease and desist pursuant to Sections 36a-804(b) and 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes. Respondent failed to request a hearing within the prescribed time period and the allegations were deemed admitted. As a result, the Commissioner ordered Respondent to cease and desist from violating Sections 36a-17(e), 36a 801(a) and 36a-805(a)(15) of the Connecticut General Statutes and imposed a civil penalty in the amount of $100,000 upon Respondent.

Order to Cease and Desist and Order Imposing Civil Penalty

On July 2, 2024, the Commissioner issued an Order to Cease and Desist and Order Imposing Civil Penalty ("Order") in the Matter of: CREDIT RECOVERY MANAGEMENT GROUP LLC d/b/a CR GROUP ("Respondent"), Tonawanda, New York. The basis of the Order was that: (1) Respondent 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 in effect at such time, which form the basis to issue an order to cease and desist against Respondent pursuant to Sections 36a-804(b) and 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty upon Respondent pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes; (2) Respondent failed to provide information requested during investigation or otherwise cooperate with the Commissioner, in violation of Section 36a-17(e) of the Connecticut General Statutes, which form the basis to issue an order to cease and desist against Respondent pursuant to Sections 36a 804(b) and 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty upon Respondent pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes; and 3) Respondent failed to establish a system for supervision and compliance under Section 36a 805(a)(15) of the Connecticut General Statutes, which forms the basis to issue an order to cease and desist pursuant to Sections 36a-804(b) and 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes. Respondent failed to request a hearing within the prescribed time period and the allegations were deemed admitted. As a result, the Commissioner ordered Respondent to cease and desist from violating Sections 36a-17(e), 36a 801(a) and 36a-805(a)(15) of the Connecticut General Statutes and imposed a civil penalty in the amount of $100,000 upon Respondent.

Order to Cease and Desist and Order Imposing Civil Penalty

On July 5, 2024, the Commissioner issued an Order to Cease and Desist and Order Imposing Civil Penalty ("Order") in the Matter of: Nelson Cruz & Associates LLC, NMLS # 1862472 ("Respondent"), Dallas, Texas. The basis of the Order was that: (1) Respondent 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 in effect at such time, which form the basis to issue an order to cease and desist against Respondent pursuant to Sections 36a-804(b) and 36a 52(a) of the Connecticut General Statutes, and to impose a civil penalty upon Respondent pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes; (2) Respondent failed to provide information requested during the investigation or otherwise cooperate with the Commissioner, in violation of Section 36a-17(e) of the Connecticut General Statutes, which form the basis to issue an order to cease and desist against Respondent pursuant to Sections 36a 804(b) and 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty upon Respondent pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes; 3) Respondent failed to establish a system for supervision and compliance under Section 36a 805(a)(15) of the Connecticut General Statutes, which forms the basis to issue an order to cease and desist pursuant to Sections 36a-804(b) and 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes; and (4) Respondent acted in a manner that failed to comply with 12 CFR Section 1006.14 of Regulation F, the Fair Debt Collection Practices Act, by the frequency of telephone calls Respondent made to the complainant in connection with the debt, and failed to comply with 12 CFR Section 1006.34 of Regulation F, by failing to provide the complainant with validation of the debt, in violation of Section 36a-812 of the Connecticut General Statutes, which form the basis to issue an order to cease and desist against Respondent pursuant to Sections 36a-804(b) and 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty upon Respondent pursuant to Sections 36a-804(b) and 36a-50(a) of the Connecticut General Statutes. Respondent failed to request a hearing within the prescribed time period and the allegations were deemed admitted. As a result, the Commissioner ordered Respondent to cease and desist from violating Sections 36a-17(e), 36a 801(a), 36a-805(a)(15) and 36a-812 of the Connecticut General Statutes and imposed a civil penalty in the amount of $100,000 upon Respondent.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

Consent Order

On July 8, 2024, the Banking Commissioner entered a Consent Order (No. CSF-23-2022-42-B) with respect to Vend Tech International, Inc. of 2475 George Urban Boulevard, Depew, New York 14043. The Respondent is in the business of offering vending machine business opportunities under the brand names "Naturals2GO" and "All4U." The Consent Order was preceded by a July 18, 2023 Notice of Intent to Issue Stop Order Denying Effectiveness to a Business Opportunity Postsale Registration, Order to Cease and Desist, Notice of Intent to Fine and Notice of Right to Hearing (No. CSF-23-2022-42-B). That action alleged that, commencing in 2014, the Respondent sold unregistered vending machine business opportunities to several Connecticut residents in violation of Sections 36b-62(a) and 36b-67(1) of the Connecticut Business Opportunity Investment Act. Seven years after the first sale, the Respondent filed to register the business opportunity after-the-fact. The action further alleged that, while that application was pending, the Respondent made yet another unregistered Connecticut sale which it did not disclose to the agency. Such nondisclosure, as well as the Respondent's failure to disclose business opportunity related sanctions levied against it by the states of Illinois, Washington and Maryland in 2021 and 2022 allegedly violated Section 36b-62(d) of the Act. The action also alleged that the Respondent violated Section 36b-63 of the Act by failing to provide prospective purchaser-investors with a disclosure document meeting the requirements of the Act. In addition, the action alleged that the Respondent used misleading materials in promoting its business opportunity to prospective purchasers in violation of Section 36b-67 of the Act.

The Consent Order fined Vend Tech International, Inc. $10,000 and directed it to cease and desist from regulatory violations. Pursuant to the Consent Order, Vend Tech International, Inc. agreed to extend a partial rebate offer to purchaser-investors with whom it had not previously settled and to make payment to those purchaser-investors electing to take the rebate. Vend Tech International, Inc.'s pending post-sale business opportunity registration became effective on July 8, 2024.

Dated: Wednesday, July 17, 2024

Jorge L. Perez
Banking Commissioner

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