World First USA Inc CO

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IN THE MATTER OF:

WORLD FIRST USA, INC.

("World First")

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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, World First is a Delaware corporation with an office at 2800 Crystal Drive, Suite 310, Arlington, Virginia;

WHEREAS, on June 3, 2014, World First filed an application for a 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 Section 36a-608(a) of the 2014 Supplement to the General Statutes into the activities of World First 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 World First, during the period of September 2012 to February 2014, engaged in the business of money transmission without the required license, in violation of Section 36a-597(a) of the Connecticut General Statutes in effect prior to October 1, 2013, 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 World First, including proceedings to issue a cease and desist order against World First 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 World First 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 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 World First acknowledge the possible consequences of formal administrative proceedings, and World First 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 formal administrative proceedings concerning the allegation set forth herein;

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

AND WHEREAS, World First, 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, World First, 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 World First, World First 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 Ten Thousand Dollars ($10,000) as a civil penalty;
2.	No later than the date this Consent Order is executed by World First, World First 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 One Thousand Four Hundred Thirty-five and 50/100 Dollars ($1,435.50) as payment for back licensing fees; and
3.	World First 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 World First 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 World First 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 World First and reflected herein is subsequently discovered to be untrue;
3.	Nothing in the issuance of this Consent Order shall adversely affect the ability of World First to apply for or obtain an original license or renewal license under Part V of Chapter 668, Sections 36a-595 to 36a-612, inclusive, of the Connecticut General Statutes; and
4.	This Consent Order shall become final when issued.

Issued at Hartford, Connecticut
this 29th day of August 2014.           _______/s/_________
                                                     Howard F. Pitkin
                                                     Banking Commissioner

I, Christopher Russell, state on behalf of World First USA, Inc., 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 World First USA, Inc.; that World First USA, Inc., agrees freely and without threat or coercion of any kind to comply with the sanctions entered herein; and that World First USA, Inc., 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:  Christopher Russell
                                                  Title:  President/CEO
                                                  World First USA, Inc.

State of: Virginia

County of: Arlington

On this the 21st day of August 2014, before me, Andrea Jean Kotrosits, the undersigned officer, personally appeared Christopher Russell who acknowledged himself/herself to be the President/CEO of World First USA, Inc., a Delaware corporation, and that he/she as such President/CEO, 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/CEO.

In witness whereof I hereunto set my hand.

                                                       _________/s/_________
                                                       Notary Public
                                                       Date Commission Expires:  08/31/2018

Administrative Orders and Settlements

State of Connecticut Department of Banking