WHEREAS, 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”;

WHEREAS, the Commissioner, through the Consumer Credit Division of the Department of Banking, conducted an investigation of the activities of Respondents, pursuant to the authority granted by Sections 36a-608(a) and 36a-17(a) of the Connecticut General Statutes, to determine if Respondents had violated, were violating or were about to violate the provisions of the Connecticut General Statutes within the jurisdiction of the Commissioner;

WHEREAS, on April 12, 2013, the Commissioner, acting pursuant to Sections 36a-52(b), 36a-50(a) and 4-182(c), subsections (b) and (c) of Section 36a-608, Section 36a-52(a) and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes, issued a 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 (collectively “Notice”) against Respondents, which Notice is incorporated herein by reference;

WHEREAS, on April 12, 2013, the Notice was sent by certified mail, return receipt requested, to Global (Certified Mail No. 70110470000225729694);

WHEREAS, on April 12, 2013, the Notice was sent by certified mail, return receipt requested, to InterTransfers (Certified Mail No. 70110470000225729700);

WHEREAS, the Notice provided Global with the opportunity for a hearing and stated that if a hearing was not requested within 14 days of its receipt, the Commissioner would 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;

WHEREAS, the Notice provided InterTransfers with the opportunity for a hearing and stated that if a hearing was not requested within 14 days of its receipt, the Commissioner would 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;

WHEREAS, on April 16, 2013, InterTransfers received the Notice, and no request for a hearing was received by the Commissioner;

WHEREAS, Section 36a-51(a) of the Connecticut General Statutes provides, in pertinent part, that “[t]he notice shall be deemed received by the licensee on the earlier of the date of actual receipt or seven days after mailing or sending”;

WHEREAS, Section 36a-52(a) of the Connecticut General Statutes provides, in pertinent part, that “[t]he notice shall be deemed received by the person on the earlier of the date of actual receipt, or seven days after mailing or sending”;

WHEREAS, Section 36a-50(a)(1) of the Connecticut General Statutes provides, in pertinent part, that “[t]he notice shall be deemed received by the person on the earlier of the date of actual receipt or seven days after mailing or sending”;

WHEREAS, on April 19, 2013, the Notice was deemed received by Global, and no request for a hearing was received by the Commissioner;

WHEREAS, the Commissioner alleged in the Notice, with respect to the activity described therein, that Global’s failure to transmit money or monetary value received from purchasers 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 upon Global pursuant to Sections 36a-608(c) and 36a-50(a) of the Connecticut General Statutes;

WHEREAS, the Commissioner alleged in the Notice, with respect to the activity described therein, that Global’s failure to transmit money or monetary value received from purchasers and the similarity of the allegations made against Global by the Commonwealth of Massachusetts, Commissioner of Banks in a Findings of Fact and Temporary Order to Cease and Desist dated April 10, 2013 (“Global Order”), 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, of the Connecticut General Statutes, 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;

WHEREAS, the Commissioner alleged in the Notice, with respect to the activity described therein, that InterTransfers’ common ownership with Global and the substance and similarity of the allegations made against InterTransfers by the Commonwealth of Massachusetts, Commissioner of Banks in a Findings of Fact and Temporary Order to Cease and Desist dated April 10, 2013 (“InterTransfers Order”), fails to demonstrate that InterTransfers’ business will be conducted honestly, fairly, equitably, carefully and efficiently within the purposes and intent of Section 36a-595 to 36a-610, inclusive, of the Connecticut General Statutes 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;

WHEREAS, the Commissioner alleged in the Notice, with respect to the activity described therein, that Global’s failure to notify the Commissioner, in writing, no later than one business day after the issuance of the Global Order, 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 and 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 upon Global pursuant to Sections 36a-608(c) and 36a-50(a) of the Connecticut General Statutes;

WHEREAS, the Commissioner alleged in the Notice, with respect to the activity described therein, that InterTransfers’ failure to notify the Commissioner, in writing, no later than one business day after the issuance of the InterTransfers Order, 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 and 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 upon InterTransfers pursuant to Sections 36a-608(c) and 36a-50(a) of the Connecticut General Statutes;

WHEREAS, Section 36a-51(b) of the Connecticut General Statutes provides, in pertinent part, that “[i]f the licensee does not request a hearing within the time specified in the notice . . . , the commissioner shall . . . revoke . . . the license.  No such license shall be . . . revoked except in accordance with the provisions of chapter 54”;

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 . . . , 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 . . . , the commissioner may, as the facts require, order that a civil penalty not exceeding one hundred thousand dollars per violation be imposed on 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”.