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TEMPORARY ORDER TO |
I. LEGAL AUTHORITY AND JURISDICTION
The Banking Commissioner (“Commissioner”) is charged with the administration of Part V of Chapter 668, Sections 36a-595 to 36a-610, inclusive, of the Connecticut General Statutes, “Money Transmission Act”.
Pursuant to the authority granted by Sections 36a-608(a) and 36a-17(a) of the Connecticut General Statutes, the Commissioner, through the Consumer Credit Division (“Division”) of the Department of Banking, has investigated the activities of Respondents to determine if they have violated, are violating or are about to violate the provisions of the Connecticut General Statutes within the jurisdiction of the Commissioner.
Section 36a-608(a) of the Connecticut General Statutes provides, in pertinent part:
The commissioner shall make such investigations . . . as the commissioner considers necessary to determine whether any licensee or any other person has violated or is about to violate any of the provisions of sections 36a-595 to 36a-610, inclusive, or whether any licensee has acted in such manner as otherwise would justify the suspension or revocation of the license. The provisions of section 36a-17 shall apply to such investigation.
Section 36a-17(a) of the Connecticut General Statutes provides, in pertinent part:
The commissioner, in the commissioner’s discretion, may, . . . (1) make such public or private investigations or examinations within or outside this state, concerning any person subject to the jurisdiction of the commissioner, as the commissioner deems necessary to carry out the duties of the commissioner . . . .
Subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes provides, in pertinent part:
(a) The commissioner may . . . revoke . . . any license issued by the commissioner under any provision of the general statutes by sending a notice to the licensee by registered or certified mail, return receipt requested, or by any express delivery carrier that provides a dated delivery receipt. The notice shall be deemed received by the licensee on the earlier of the date of actual receipt or seven days after mailing or sending. Any such notice shall include: (1) A statement of the time, place, and nature of the hearing; (2) a statement of the legal authority and jurisdiction under which the hearing is to be held; (3) a reference to the particular sections of the general statutes . . . involved; (4) a short and plain statement of the matters asserted; and (5) a statement indicating that the licensee may file a written request for a hearing on the matters asserted within fourteen days of receipt of the notice. If the commissioner finds that public health, safety or welfare imperatively requires emergency action, and incorporates a finding to that effect in the notice, the commissioner may order summary suspension of a license in accordance with subsection (c) of section 4-182 and require the licensee to take or refrain from taking such action as in the opinion of the commissioner will effectuate the purposes of this section, pending proceedings for . . . revocation . . . .
(b) If a hearing is requested within the time specified in the notice, the commissioner shall hold a hearing upon the matters asserted in the notice unless the licensee fails to appear at the hearing. After the hearing, the commissioner shall . . . revoke . . . the license for any reason set forth in the applicable licensing provisions of the general statutes if the commissioner finds sufficient grounds exist for such . . . revocation . . . . If the licensee does not request a hearing within the time specified in the notice or fails to appear at the hearing, the commissioner shall . . . revoke . . . the license. No such license shall be . . . revoked except in accordance with the provisions of chapter 54.
Section 36a-52 of the Connecticut General Statutes provides, in pertinent part:
(a) Whenever it appears to the commissioner that any person has violated, is violating or is about to violate any provision of the general statutes within the jurisdiction of the commissioner, . . . the commissioner may send a notice to such person by registered or certified mail, return receipt requested, or by any express delivery carrier that provides a dated delivery receipt. The notice shall be deemed received by the person on the earlier of the date of actual receipt, or seven days after mailing or sending. Any such notice shall include: (1) A statement of the time, place, and nature of the hearing; (2) a statement of the legal authority and jurisdiction under which the hearing is to be held; (3) a reference to the particular sections of the general statutes . . . alleged to have been violated; (4) a short and plain statement of the matters asserted; and (5) a statement indicating that such person may file a written request for a hearing on the matters asserted within fourteen days of receipt of the notice. If a hearing is requested within the time specified in the notice, the commissioner shall hold a hearing upon the matters asserted in the notice, unless the person fails to appear at the hearing. After the hearing, the commissioner shall determine whether an order to cease and desist should be issued against the person named in the notice. If the person does not request a hearing within the time specified in the notice or fails to appear at the 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.
(b) If the commissioner finds that the public welfare requires immediate action, the commissioner may incorporate a finding to that effect in the notice sent in accordance with subsection (a) of this section and issue a temporary order requiring the person to cease and desist from the activity which constitutes such alleged violation and to take or refrain from taking such action as in the opinion of the commissioner will effectuate the purposes of this section. Such temporary order shall become effective on receipt and, unless set aside or modified by a court, shall remain in effect until the effective date of a permanent order or dismissal of the matters asserted in the notice.
Section 36a-50(a) of the Connecticut General Statutes provides, in pertinent part:
(1) Whenever the commissioner finds as the result of an investigation that any person has violated any provision of the general statutes within the jurisdiction of the commissioner, . . . the commissioner may send a notice to such person by registered or certified mail, return receipt requested, or by any express delivery carrier that provides a dated delivery receipt. The notice shall be deemed received by the person on the earlier of the date of actual receipt or seven days after mailing or sending. Any such notice shall include: (A) A statement of the time, place, and nature of the hearing; (B) a statement of the legal authority and jurisdiction under which the hearing is to be held; (C) a reference to the particular sections of the general statutes . . . alleged to have been violated; (D) a short and plain statement of the matters asserted; (E) the maximum penalty that may be imposed for such violation; and (F) a statement indicating that such person may file a written request for a hearing on the matters asserted within fourteen days of receipt of the notice.
(2) If a hearing is requested within the time specified in the notice, the commissioner shall hold a hearing upon the matters asserted in the notice unless such person fails to appear at the hearing. After the hearing, if the commissioner finds that the person has violated any such provision, . . . the commissioner may, in the commissioner’s discretion and in addition to any other remedy authorized by law, order that a civil penalty not exceeding one hundred thousand dollars per violation be imposed upon such person. If 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.
(3) Each action undertaken by the commissioner under this subsection shall be in accordance with the provisions of chapter 54.
Section 4-182(c) of the Connecticut General Statutes provides, in pertinent part, that:
If the agency finds that public health, safety or welfare imperatively requires emergency action, and incorporates a finding to that effect in its order, summary suspension of a license may be ordered pending proceedings for revocation or other action. These proceedings shall be promptly instituted and determined.
II. MATTERS ASSERTED
| 1. |
Global is a Florida corporation with an office at 25 SE 2nd Avenue, Suite 516, Miami, Florida, and currently maintains a license (No. 21029) to engage in the business of money transmission in Connecticut. At all relevant times hereto, Global had approximately 10 authorized agent locations in Connecticut. |
| 2. |
InterTransfers is a Florida corporation with an office at 25 SE 2nd Avenue, Miami, Florida, and currently maintains a license (No. 14274) to engage in the business of money transmission in Connecticut. At all relevant times hereto, InterTransfers had approximately 8 authorized agent locations in Connecticut. |
| 3. |
Both Respondents are wholly-owned by Iraci R. Oliveira. |
| 4. |
From approximately March 20, 2013 to the present, Global failed to transmit funds totaling approximately $147,773 to persons in Brazil on behalf of purchasers who remitted such funds to two Global agents located in Connecticut.
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| 5. |
On April 10, 2013, the Commonwealth of Massachusetts, Commissioner of Banks, issued a Findings of Fact and Temporary Order to Cease and Desist against Global alleging that InterTransfers, the parent company of Global, had failed to remit funds received by Global for transmission in Massachusetts to a foreign country within seven days of receipt and failed to demonstrate the financial responsibility, character, reputation, integrity and general fitness that would warrant the belief that its business would be operated honestly, fairly and soundly in the public interest, as required of Massachusetts licensees engaging in the business of a foreign transmittal agency (“Global Order”). |
| 6. | On April 10, 2013, the Commonwealth of Massachusetts, Commissioner of Banks, issued a Findings of Fact and Temporary Order to Cease and Desist against InterTransfers alleging that it had failed to remit funds received for transmission in Massachusetts to a foreign country within seven days of receipt and failed to demonstrate the financial responsibility, character, reputation, integrity and general fitness that would warrant the belief that its business would be operated honestly, fairly and soundly in the public interest, as required of Massachusetts licensees engaging in the business of a foreign transmittal agency (“InterTransfers Order”). |
| 7. | To date, Global has failed to notify the Commissioner of the Global Order. |
| 8. |
To date, InterTransfers has failed to notify the Commissioner of the InterTransfers Order. |
III. STATUTORY BASIS FOR REVOCATION OF LICENSE TO ENGAGE
IN THE BUSINESS OF MONEY TRANSMISSION, ORDER TO
CEASE AND DESIST AND IMPOSITION OF CIVIL PENALTY
Section 36a-598(e) of the Connecticut General Statutes provides, in pertinent part:
A licensee shall provide a written notice to the commissioner no later than one business day after the licensee has reason to know of the occurrence of any of the following events: . . .
(3) The commencement of a proceeding to revoke or suspend its license to engage in money transmission in another state or a foreign country, or other formal or informal regulatory action by any governmental agency against the licensee and the reasons therefor[.]
Section 36a-600 of the Connecticut General Statutes provides, in pertinent part:
(a) Upon the filing of an application for an original license, and the payment of the fees for investigation and license, the commissioner shall investigate the financial condition and responsibility, financial and business experience, character and general fitness of the applicant. The commissioner shall approve conditionally any application, if the commissioner finds that: . . .
(2) The applicant’s business will be conducted honestly, fairly, equitably, carefully and efficiently within the purposes and intent of sections 36a-595 to 36a-610, inclusive, and in a manner commanding the confidence and trust of the community . . . .
(b) . . . The commissioner shall not issue a license to any applicant unless the applicant is in compliance with all the requirements of subsection (a) of this section . . . .
Section 36a-608(b) of the Connecticut General Statutes provides, in pertinent part:
The commissioner may . . . revoke a license or take any other action, in accordance with section 36a-51, on any ground on which the commissioner might refuse to issue an original license, for any violation of sections 36a-595 to 36a-610, inclusive, . . . or for engaging in an unsafe and unsound practice.
Section 36a-608(c) of the Connecticut General Statutes provides, in pertinent part:
Whenever it appears to the commissioner that any person has violated, is violating or is about to violate any provision of sections 36a-595 to 36a-610, inclusive, . . . or any licensee has . . . engaged in an unsafe and unsound practice, the commissioner may take action against such person in accordance with sections 36a-50 and 36a-52.
Section 36a-596(16) of the Connecticut General Statutes defines “unsafe or unsound practice” to mean, in pertinent part:
[A] practice or conduct by a licensee . . . that is likely to . . . otherwise materially prejudice the interests of purchasers.
Section 36a-596(13) of the Connecticut General Statutes defines “purchaser” to mean, in pertinent part:
[A] person . . . who has given money or monetary value for current or future transmission.
| 1. |
Global’s failure to transmit money or monetary value received from purchasers, as more fully described in paragraph 4 of the Matters Asserted, constitutes conduct that is likely to otherwise materially prejudice the interests of purchasers, which constitutes an unsafe or unsound practice within the meaning of Section 36a-596(16) of the Connecticut General Statutes. Such conduct constitutes grounds for the Commissioner to revoke Global’s license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes, forms the basis to issue an order to cease and desist against Global pursuant to Sections 36a-608(c) and 36a-52(a) of the Connecticut General Statutes and impose a civil penalty against Global pursuant to Sections 36a-608(c) and 36a-50(a) of the Connecticut General Statutes. Section 36a-50(a) of the Connecticut General Statutes authorizes the Commissioner to impose a civil penalty upon Global in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation. |
| 2. |
Global’s failure to transmit money or monetary value received from purchasers and the similarity of the allegations made against Global in the Global Order, as more fully described in paragraphs 1, 4 and 5 of the Matters Asserted, inclusive, fails to demonstrate that Global’s business will be conducted honestly, fairly, equitably, carefully and efficiently within the purposes and intent of Sections 36a-595 to 36a-610, inclusive, and in a manner commanding the confidence and trust of the community. Such conduct constitutes grounds for the Commissioner to revoke Global’s license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes. |
| 3. |
InterTransfers’ common ownership with Global and the substance and similarity of the allegations made against InterTransfer in the InterTransfer Order, as more fully described in paragraphs 2 through 6, inclusive, of the Matters Asserted, fails to demonstrate that InterTransfers’ business will be conducted honestly, fairly, equitably, carefully and efficiently within the purposes and intent of Sections 36a-595 to 36a-610, inclusive, and in a manner commanding the confidence and trust of the community. Such conduct constitutes grounds for the Commissioner to revoke InterTransfers’ license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes. |
| 4. | Global’s failure to notify the Commissioner, in writing, no later than one business day after the issuance of the Global Order, as more fully described in paragraphs 5 and 7 of the Matters Asserted, in violation of Section 36a-598(e) of the Connecticut General Statutes, constitutes grounds to revoke Global’s license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes, and forms the basis to issue an order to cease and desist against Global pursuant to Sections 36a-608(c) and 36a-52(a) of the Connecticut General Statutes and impose a civil penalty against Global pursuant to Sections 36a-608(c) and 36a-50(a) of the Connecticut General Statutes. Section 36a-50(a) of the Connecticut General Statutes authorizes the Commissioner to impose a civil penalty upon Global in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation. |
| 5. |
InterTransfers’ failure to notify the Commissioner, in writing, no later than one business day after the issuance of the InterTransfers Order, as more fully described in paragraphs 6 and 8 of the Matters Asserted, in violation of Section 36a-598(e) of the Connecticut General Statutes, constitutes grounds to revoke InterTransfers’ license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes, and forms the basis to issue an order to cease and desist against InterTransfers pursuant to Sections 36a-608(c) and 36a-52(a) of the Connecticut General Statutes and impose a civil penalty against InterTransfers pursuant to Sections 36a-608(c) and 36a-50(a) of the Connecticut General Statutes. Section 36a-50(a) of the Connecticut General Statutes authorizes the Commissioner to impose a civil penalty upon InterTransfers in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation. |
IV. FINDINGS AND STATUTORY BASIS FOR TEMPORARY ORDER
TO CEASE AND DESIST AND ORDER OF SUMMARY SUSPENSION
The Commissioner finds that public safety and welfare imperatively require emergency action to summarily suspend each Respondent’s license to engage in the business of money transmission in this state under Section 4-182(c) of the Connecticut General Statutes and finds that public welfare requires immediate action to issue a temporary order requiring each Respondent to cease and desist from violating the laws cited herein, pursuant to Section 36a-52(b) of the Connecticut General Statutes, in that Global has failed to transmit money or monetary value received on behalf of purchasers in Connecticut, Global and InterTransfers are both wholly-owned by the same person and are both the subject of orders alleging the failure to transmit money on behalf of purchasers in Massachusetts, such that the continued operation by Global and InterTransfers to engage in the business of money transmission in Connecticut may materially prejudice Connecticut purchasers.
V. TEMPORARY ORDER TO CEASE AND DESIST, ORDER OF SUMMARY SUSPENSION,
NOTICE OF INTENT TO REVOKE MONEY TRANSMISSION LICENSE,
NOTICE OF INTENT TO ISSUE ORDER TO CEASE AND DESIST, NOTICE OF INTENT
TO IMPOSE CIVIL PENALTY AND NOTICE OF RIGHT TO HEARING
WHEREAS, the Commissioner has reason to believe that each Respondent has engaged in conduct which constitutes sufficient grounds for the Commissioner to revoke each Respondent’s license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes, and forms the basis to issue an order to cease and desist against each Respondent pursuant to Sections 36a-608(c) and Section 36a-52(a) of the Connecticut General Statutes and impose a civil penalty upon each Respondent pursuant to Sections 36a-608(c) and 36a-50(a) of the Connecticut General Statutes;
AND WHEREAS, the Commissioner has made the findings required under Sections 36a-51(a), 36a-52(b) and 4-182(c) of the Connecticut General Statutes.
THE COMMISSIONER THEREFORE ORDERS, pursuant to the authority granted in Section 36a-52(b) of the Connecticut General Statutes, that Global Money Remittance, Inc. immediately CEASE AND DESIST from engaging in an unsafe or unsound practice and violating Section 36a-598(e) of the Connecticut General Statutes. This Temporary Order to Cease and Desist shall become effective upon receipt by Global Money Remittance, Inc. and, unless set aside or modified by a court, shall remain in effect until the effective date of a permanent order or dismissal of the matters asserted in this Temporary Order to Cease and Desist.
THE COMMISSIONER FURTHER ORDERS, pursuant to the authority granted in Section 36a-52(b) of the Connecticut General Statutes, that InterTransfers, Inc. d/b/a InterTransfers immediately CEASE AND DESIST from violating Section 36a-598(e) of the Connecticut General Statutes. This Temporary Order to Cease and Desist shall become effective upon receipt by InterTransfers, Inc. d/b/a InterTransfers and, unless set aside or modified by a court, shall remain in effect until the effective date of a permanent order or dismissal of the matters asserted in this Temporary Order to Cease and Desist.
THE COMMISSIONER FURTHER ORDERS, pursuant to Sections 36a-51(a) and 36a-52(b) of the Connecticut General Statutes, that:
| 1. |
Upon receipt of this Temporary Order to Cease and Desist, each Respondent, and any and all officers, directors, trustees, principal employees, shareholders and agents acting on behalf of each Respondent, shall immediately cease and desist from engaging, directly or indirectly, in the business of money transmission in Connecticut, provided that each Respondent is permitted to perform the winding-down of its Connecticut money transmission activities as provided herein; |
| 2. |
Each Respondent shall submit to Carmine Costa, Director, Consumer Credit Division by e-mail at carmine.costa@ct.gov as soon as possible, but no later than seven (7) days after the effective date of this Temporary Order to Cease and Desist, a detailed report of the number and amount of all transactions affected by each Respondent’s suspension of money transmission service, including but not limited to, transactions that were cancelled, reissued through another licensed money transmitter or remain unresolved as a result of each Respondent’s suspension of service. The report shall include the names and addresses of all Connecticut purchasers from whom funds were collected for transmission, the amount of such funds and corresponding fees collected by each Respondent or each Respondent’s agents; |
| 3. |
Each Respondent shall submit to Carmine Costa, Director, Consumer Credit Division by e-mail at carmine.costa@ct.gov as soon as possible, but no later than seven (7) days after the effective date of this Temporary Order to Cease and Desist, a detailed accounting of any monetary damages caused to Connecticut purchasers or such Respondent’s Connecticut agents as a result of each Respondent’s suspension of service including, but not limited to, any late charges incurred or penalties imposed on accounts; |
| 4. |
Each Respondent shall immediately notify all agents of this Temporary Order to Cease and Desist and instruct such agents to immediately cease engaging in the business of money transmission in Connecticut on behalf of such Respondent; |
| 5. | Each Respondent shall immediately secure all records, files and documents relating to its money transmission business in Connecticut (collectively, “Records”). Further, each Respondent shall ensure that all agents acting on behalf of such Respondent in Connecticut are directed to preserve all Records pursuant to the provisions of this paragraph. The Records shall be available to the Commissioner in their entirety upon request; |
| 6. |
Each Respondent shall immediately process and remit all transmittal orders for funds received from Connecticut purchasers with no loss to the purchaser. “No loss to the purchaser” shall mean that if a Respondent is unable to remit funds collected for transmittal, the purchaser shall be entitled to a refund of all funds and fees collected by each Respondent, either directly or through Respondent’s agent. No later than seven (7) days after the effective date of this Temporary Order to Cease and Desist, each Respondent shall submit evidence of compliance with this paragraph to Carmine Costa, Director, Consumer Credit Division at carmine.costa@ct.gov, including but not limited to, receipts confirming the transmittal of funds, check number of payments issued and an accounting of the amount reimbursed to each individual; and |
| 7. |
Upon the effective date of this Temporary Order to Cease and Desist, each Respondent shall not pay or declare any dividend, salary or bonus, nor otherwise authorize any other material distribution of Respondent’s assets to any officer, director or owner of such Respondent without the prior written approval of the Commissioner. Each Respondent shall implement or revise its practices and procedures, as necessary, to ensure that each Respondent’s financial books and records are accurately maintained, in a manner illustrating compliance with the provisions of this paragraph, and available for review by the Division’s examiners upon request. |
THE COMMISSIONER FURTHER ORDERS, pursuant to the authority granted by Sections 36a-608(b), 36a-51(a) and 4-182(c) of the Connecticut General Statutes, that the license of Global Money Remittance, Inc. to engage in the business of money transmission in this state be and is hereby SUMMARILY SUSPENDED pending proceedings for revocation.
THE COMMISSIONER FURTHER ORDERS, pursuant to the authority granted by Sections 36a-608(b), 36a-51(a) and 4-182(c) of the Connecticut General Statutes, that the license of InterTransfers, Inc. d/b/a InterTransfers to engage in the business of money transmission in this state be and is hereby SUMMARILY SUSPENDED pending proceedings for revocation.
FURTHER, notice is hereby given to each Respondent that the Commissioner intends to REVOKE each Respondent’s license to engage in the business of money transmission in Connecticut, issue an order requiring each Respondent to CEASE AND DESIST from violating the laws cited herein, and impose a CIVIL PENALTY upon each Respondent as set forth herein, subject to each Respondent’s right to a hearing on the allegations set forth above.
A hearing will be granted to each Respondent if a written request for a hearing is received by the Department of Banking, Consumer Credit Division, 260 Constitution Plaza, Hartford, Connecticut 06103-1800 within fourteen (14) days following its receipt of this Temporary Order to Cease and Desist, Order of Summary Suspension, Notice of Intent to Revoke Money Transmission License, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing as set forth in subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes and Section 36a-52(a) and 36a-50(a) of the Connecticut General Statutes. This Temporary Order to Cease and Desist, Order of Summary Suspension, Notice of Intent to Revoke Money Transmission License, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing shall be deemed received on the earlier of the date of actual receipt, or seven days after mailing or sending. The enclosed Appearance and Request for Hearing Form must be completed and mailed to the above address. If any Respondent will not be represented by an attorney at the hearing, please complete the Appearance and Request for Hearing Form as “pro se”. Once a written request for a hearing is received, the Commissioner may issue a notification of hearing and designation of hearing officer that acknowledges receipt of a request for a hearing, designates a hearing officer and sets the date of the hearing in accordance with Section 4-177 of the Connecticut General Statutes and Section 36a-1-21 of the Regulations of Connecticut State Agencies. If a hearing is requested, the hearing will be held on June 19, 2013, at 10 a.m., at the Department of Banking, 260 Constitution Plaza, Hartford, Connecticut.
The hearing will be held in accordance with the provisions of Chapter 54 of the Connecticut General Statutes, unless each Respondent fails to appear at the requested hearing. At such hearing, each Respondent will have the right to appear and present evidence, rebuttal evidence and argument on all issues of fact and law to be considered by the Commissioner.
If Global does not request a hearing within the time prescribed, the Commissioner will issue an order revoking Global’s license to engage in the business of money transmission in Connecticut, issue an order that Global cease and desist from engaging in an unsafe or unsound practice and violating Section 36a-598(e) 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 Global.
If InterTransfers does not request a hearing within the time prescribed, the Commissioner will issue an order revoking InterTransfers’ license to engage in the business of money transmission in Connecticut, issue an order that InterTransfers cease and desist from violating Section 36a-598(e) 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 InterTransfers.
So ordered at Hartford, Connecticut
this 12th day of April 2013. ________/s/_________
Howard F. Pitkin
Banking Commissioner
CERTIFICATION
I hereby certify that on this 12th day of April 2013, the foregoing Temporary Order to Cease and Desist, Order of Summary Suspension, Notice of Intent to Revoke Money Transmission License, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing was sent by registered mail, return receipt requested to, Global Money Remittance, Inc., Attention: Erik Rodriguez, 25 SE 2nd Avenue, Miami, Florida 33131, certified mail no. 7011 0470 0002 2572 9694; and InterTransfers, Inc., d/b/a InterTransfers, Attention: Erik Rodriguez, 25 SE 2nd Avenue, Miami, Florida 33131, certified mail no. 7011 0470 0002 2572 9700.
________/s/_________
Stacey L. Serrano
Prosecuting Attorney