Cambioreal Incorporated

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IN THE MATTER OF:

CAMBIOREAL INCORPORATED

       ("CambioReal")


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CONSENT ORDER

WHEREAS, the Banking Commissioner (“Commissioner”) is charged with the administration of Part V of Chapter 668, Sections 36a-595 to 36a-612, inclusive, of the Connecticut General Statutes, “Money Transmission Act”;

WHEREAS, CambioReal is a Delaware corporation with an office at 100 White Clay Center Drive, Suite 100, Newark, Delaware;

WHEREAS, on April 16, 2014, CambioReal filed an Application for Money Transmission License with the Commissioner, 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(a) of the Connecticut General Statutes, as amended by Public Acts 14-7 and 14-89, and Sections 36a-600 and 36a-608(a) of the 2014 Supplement to the General Statutes, into the activities of CambioReal to determine if it has violated, was violating or was about to violate the provisions of the Money Transmission Act;

WHEREAS, as a result of such investigation, the Commissioner alleges that CambioReal, during the period of January 2012 to the present, engaged in the business of money transmission without the required license, in violation of Section 36a-597(a) of the Connecticut General Statutes and Section 36a-597(a) of the 2014 Supplement to the General Statutes;

WHEREAS, the Commissioner believes that the allegation contained herein would support the initiation of enforcement proceedings against CambioReal, including proceedings to issue a cease and desist order against CambioReal pursuant to Section 36a-608(c) of the 2014 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty of up to one hundred thousand dollars ($100,000) per violation on CambioReal pursuant to Section 36a-608(c) of the 2014 Supplement to the General Statutes and Section 36a-50(a) of the Connecticut General Statutes;

WHEREAS, initiation of such enforcement proceedings constitute a “contested case” within the meaning of Section 4-166(4) of the Connecticut General Statutes, as amended by Public Act 14-187;

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, both the Commissioner and CambioReal acknowledge the possible consequences of formal administrative proceedings, and CambioReal voluntarily agrees to consent to the entry of the sanctions imposed below without admitting or denying any allegation set forth herein and solely for the purpose of obviating the need for further formal administrative proceedings concerning the allegation set forth herein;

WHEREAS, CambioReal specifically assures the Commissioner that the violation described herein shall not occur in the future;

AND WHEREAS, CambioReal, through its execution of this Consent Order, voluntarily agrees to waive its procedural rights, including a right to a notice and an opportunity for a 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, CambioReal, 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 CambioReal, CamioReal shall remit to the Department of Banking by cashier’s check, certified check or money order made payable to “Treasurer, State of Connecticut”, the sum of Five Thousand Dollars ($5,000) as a civil penalty;
2.	No later than the date this Consent Order is executed by CambioReal, CambioReal shall remit to the Department of Banking by cashier’s check, certified check or money order made payable to “Treasurer, State of Connecticut”, the sum of Two Thousand Eight Hundred Seventy-five Dollars ($2,875) as payment for back licensing fees; and
3.	CambioReal shall cease and desist from engaging in the business of money transmission in Connecticut without a license, in violation of Section 36a-597(a) of the 2014 Supplement to the 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 CambioReal 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 CambioReal 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 CambioReal and reflected herein is subsequently discovered to be untrue;
3.	Nothing in the issuance of this Consent Order shall adversely affect the ability of CambioReal to apply for or obtain an original license or renewal license under Part V of Chapter 668, Sections 36a-595 to 36a-610, inclusive, of the Connecticut General Statutes, provided all legal requirements for such license are satisfied; and
4.	This Consent Order shall become final when issued.

Issued at Hartford, Connecticut
this 17th day of Sept 2014.            _______/s/_________
                                                     Howard F. Pitkin
                                                     Banking Commissioner

I, Cleverson Cassel, state on behalf of CambioReal Incorporated, that I have read the foregoing Consent Order; that I know and fully understand its contents; that I am authorized to execute this Consent Order on behalf of CambioReal Incorporated; that CambioReal Incorporated agrees freely and without threat or coercion of any kind to comply with the sanctions entered herein; and that CambioReal Incorporated voluntarily agrees to enter into this Consent Order, expressly waiving the procedural rights set forth herein as to the matters described herein.

                                            By: ________/s/___________
                                                  Name:  Cleverson Cassel
                                                  Title:  President
                                                  CambioReal Incorporated

State of: Delaware

County of: New Castle

On this the 10th day of Sept 2014, before me, Aaron D. Fray, the undersigned officer, personally appeared Cleverson Cassel who acknowledged himself/herself to be the President of CambioReal Incorporated, a corporation, and that he/she as such President, being authorized so to do, executed the foregoing instrument for the purposes therein contained, by signing the name of the corporation by himself/herself as President.

In witness whereof I hereunto set my hand.

                                                       _________/s/_________
                                                       Notary Public
                                                       Date Commission Expires:  February 09, 2017

Administrative Orders and Settlements

State of Connecticut Department of Banking