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IN THE MATTER OF:

STRATEGIC DEBT SOLUTIONS LLC

    ("Respondent")

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ORDER REVOKING DEBT
NEGOTIATION LICENSE

                       AND

ORDER TO CEASE AND DESIST


I.  PRELIMINARY STATEMENT

WHEREAS, the Banking Commissioner (“Commissioner”) is charged with the administration of Sections 36a-671 to 36a-671e, inclusive, of the Connecticut General Statutes contained in Part II of Chapter 669 of the Connecticut General Statutes, “Debt Adjusters and Debt Negotiation”;

WHEREAS, the Commissioner, through the Consumer Credit Division of the Department of Banking, conducted an investigation of the activities of Respondent, pursuant to the authority granted by Section 36a-17 of the Connecticut General Statutes, as amended by Public Acts 14-7 and 14-89, to determine if it had violated, was violating or was about to violate the provisions of the Connecticut General Statutes within the jurisdiction of the Commissioner;

WHEREAS, on October 6, 2014, the Commissioner, acting pursuant to Section 36a-671d of the Connecticut General Statutes, as amended by Public Acts 14-7 and 14-22, Section 36a-52(b) of the Connecticut General Statutes, Sections 36a-671a(a) and 36a-671a(a)(3) of the Connecticut General Statutes, as amended by Public Act 14-7, subsections (a) and (b) of Section 36a-51, and Sections 36a-671a(b) and 36a-52(a) of the Connecticut General Statutes, issued a Notice of Automatic Suspension, Temporary Order to Cease and Desist, Notice of Intent to Revoke Debt Negotiation License, Notice of Intent to Issue Order to Cease and Desist and Notice of Right to Hearing (collectively “Notice”) against Respondent, which Notice is incorporated herein by reference;

WHEREAS, on October 7, 2014, the Notice was sent by certified mail, return receipt requested, to Respondent (Certified Mail No. 70120470000147897043);

WHEREAS, the Notice provided Respondent 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 Respondent’s debt negotiation license in Connecticut for 8461 Lake Worth Road, Suite 450, Lake Worth, Florida, and issue an order that Respondent cease and desist from violating Section 36a-671d of the Connecticut General Statutes, as amended;

WHEREAS, on October 14, 2014, Respondent received the Notice and no request for a hearing has been received by the Commissioner;

WHEREAS, the Commissioner alleged in the Notice, with respect to the activity described therein, that Respondent’s failure to maintain a surety bond that runs the entire the period of its debt negotiation license constitutes sufficient grounds for the Commissioner to deny an application for such license and constitutes a violation of Section 36a-671d of the Connecticut General Statutes, as amended, and constitutes sufficient grounds for the Commissioner to revoke Respondent’s debt negotiation license in Connecticut for 8461 Lake Worth Road, Suite 450, Lake Worth, Florida, pursuant to Sections 36a-671a(a) and 36a-671a(a)(3) of the Connecticut General Statutes, as amended, and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes and forms a basis to issue an order to cease and desist pursuant to Sections 36a 671a(b) and 36a-52(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”;

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”.

II.  FINDINGS OF FACT AND CONCLUSIONS OF LAW
1.
The Commissioner finds that the matters asserted, as set forth in paragraphs 1 through 5, inclusive, of Section II of the Notice shall constitute findings of fact within the meaning of Section 4-180(c) of the 2014 Supplement to the General Statutes, and that the conclusions as set forth in Section III of the Notice shall constitute conclusions of law within the meaning of Section 4-180(c) of the 2014 Supplement to the General Statutes and Section 36a-1-52 of the Regulations of Connecticut State Agencies.
2.
The Commissioner finds that Respondent has engaged in acts or conduct which, pursuant to Sections 36a-671a(a) and 36a-671a(a)(3) of the Connecticut General Statutes, as amended, and subsections (a) and (b) of Section 36a-51 of Connecticut General Statutes, constitutes sufficient grounds to revoke Respondent’s debt negotiation license in Connecticut for 8461 Lake Worth Road, Suite 450, Lake Worth, Florida.
3.
The Commissioner finds that Respondent has engaged in acts or conduct which, pursuant to Sections 36a-671a(b) and 36a-52(a) of the Connecticut General Statutes, forms the basis to issue an order to cease and desist against Respondent.
4.
The Commissioner finds that the Notice was given in compliance with subsections (a) and (b) of Section 36a-51 and Sections 36a-52(a) and 4-177 of the Connecticut General Statutes.

III.  ORDER

Having read the record, I HEREBY ORDER, pursuant to Sections 36a-671a(a) and 36a-671a(a)(3) of the Connecticut General Statutes, as amended, subsections (a) and (b) of Section 36a-51, and Sections 36a-671a(b) and 36a-52(a) of the Connecticut General Statutes, that:

1.
Strategic Debt Solutions LLC’s debt negotiation license in Connecticut for 8461 Lake Worth Road, Suite 450, Lake Worth, Florida, be and is hereby REVOKED;
2.
Strategic Debt Solutions LLC CEASE AND DESIST from violating Section 36a-671d of the Connecticut General Statutes, as amended; and
3.This Order shall become effective when mailed.

Dated at Hartford, Connecticut
this 10th day of November 2014.            

________/s/_________
Howard F. Pitkin
Banking Commissioner



This order was mailed by certified mail,
return receipt requested, to Respondent
on November 10, 2014.


Strategic Debt Solutions LLC                           Certified Mail No. 70120470000147903324
Attention:  Dave Green
8461 Lake Worth Road, Suite 450
Lake Worth, Florida 33467


Administrative Orders and Settlements