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, on April 18, 2012, Global Client Solutions filed an application for a money transmission license with the Commissioner (“Application”), which licensed was issued on May 6, 2012;

WHEREAS, on August 23, 2013, Global Client Solutions filed an application to renew its money transmission license with the Commissioner (“Renewal”);

WHEREAS, the Commissioner, through the Consumer Credit Division (“Division”) of the Department of Banking, conducted an investigation pursuant to Section 36a-17 of the Connecticut General Statutes, as amended by Public Acts 14-7 and 14-89, and Section 36a-608(a) of the 2014 Supplement to the General Statutes into the activities of Global Client Solutions 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 Global Client Solutions failed to disclose the existence of an Illinois Department of Financial and Professional Regulation, Division of Financial Institutions issued Cease and Desist Order in its Application and Renewal relating to a dispute with the state of Illinois that was ultimately resolved with Illinois regulators relating to a licensing issue prior to any period relevant to its Connecticut licensing or renewal, in alleged violation of Section 36a-598(e)(3) Connecticut General Statutes; 

WHEREAS, as a result of such investigation, the Commissioner also alleges that Global Client Solutions failed to notify the Commissioner in writing, not later than fifteen days after it became aware of the Settlement Agreement with Illinois, of the existence of such agreement, in violation of Section 36a 598(c) of the 2014 Supplement to the General Statutes;

WHEREAS, Section 36a-598(e)(3) of the Connecticut General Statutes requires a licensee to provide a written notice to the Commissioner not later than one business day after the licensee has reason to know of the occurrence of 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 reason therefor;

WHEREAS, Section 36a-598(c) of the 2014 Supplement to the General Statutes requires a licensee to notify the Commissioner, in writing, of any change in the information provided in the application for the license or most recent renewal of such license not later than fifteen days after the applicant or licensee has reason to know of such change;

WHEREAS, the Commissioner believes that the allegation contained herein would support the initiation of enforcement proceedings against Global Client Solutions, including proceedings to revoke its money transmission license pursuant to Section 36a-608(b) of the 2014 Supplement to the General Statutes and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes, to issue a cease and desist order against Global Client Solutions 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 Global Client Solutions 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, Global Client Solutions has represented to the Commissioner that it has updated its internal policies, procedures and controls to ensure compliance with its obligations to notify the Commissioner, in writing, of any change in the information provided in its Application or most recent renewal application for its license, consistent with Section 36a-598(c) of the 2014 Supplement to the General Statutes;

WHEREAS, initiation of such enforcement proceedings would 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 Global Client Solutions acknowledge the possible consequences of formal administrative proceedings, and Global Client Solutions voluntarily agrees to consent to the entry of the sanction described 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, Global Client Solutions specifically assures the Commissioner that the violations alleged herein shall not occur in the future;

AND WHEREAS, Global Client Solutions, through its execution of this Consent Order, voluntarily agrees to waive its procedural rights, including a right to notice and an opportunity for hearing as it pertains to the allegations set forth herein, and voluntarily waives its rights to seek judicial review or otherwise challenge or contest the validity of this Consent Order.

CONSENT TO ENTRY OF SANCTION

WHEREAS, Global Client Solutions, through its execution of this Consent Order, consents to the Commissioner’s entry of a Consent Order imposing the following sanction:

CONSENT ORDER

NOW THEREFORE, the Commissioner enters the following:

Issued at Hartford, Connecticut
this 15th day of December 2014.     _______/s/_________
                                                     Howard F. Pitkin
                                                     Banking Commissioner

I, Brent J. Hampton, state on behalf of Global Client Solutions, LLC, 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 Global Client Solutions, LLC; that Global Client Solutions, LLC agrees freely and without threat or coercion of any kind to comply with the sanctions entered herein; and that Global Client Solutions, LLC 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:  Brent J. Hampton
                                                  Title:  V.P. & General Counsel
                                                  Global Client Solutions, LLC

State of:  Oklahoma

County of:  Tulsa

On this the 8th day of December 2014, before me, Kelsea Farmer, the undersigned officer, personally appeared Brent Hampton who acknowledged himself/herself to be the V.P. & General Counsel of Global Client Solutions, LLC, a member managed/manager managed limited liability company, and that he/she as such V.P. & General Counsel, being authorized so to do, executed the foregoing instrument for the purposes therein contained, by signing the name of the limited liability company by himself/herself as V.P. & General Counsel.

In witness whereof I hereunto set my hand.

                                                       _________/s/_________
                                                       Notary Public  
                                                       Date Commission Expires:  Jan. 11, 2016

Administrative Orders and Settlements