On November 12, 2019, the Commissioner entered into a Consent Order with The Hamilton Law Association, P.A. (“Hamilton”), Coral Springs, Florida. The Consent Order was based on an investigation by the Consumer Credit Division. As a result of such investigation, on March 18, 2019, the Commissioner issued a Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing against Hamilton. The Commissioner alleged that Hamilton acted within this state as a consumer collection agency without a consumer collection agency license, in violation of Section 36a-801(a) of the Connecticut General Statutes. As part of the Consent Order, Hamilton paid $10,000 as a civil penalty and $800 for back licensing fees.

Notice of Intent to Revoke Consumer Collection Agency Licenses, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing

On November 14, 2019, the Commissioner issued a Notice of Intent to Revoke Consumer Collection Agency Licenses, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing (“Notice”) in the Matter of: Credit Protection Association, L. P. d/b/a Credit Protection Association, Limited Partnership, NMLS # 933191 (“Respondent”), Plano, Texas. The Notice was the result of an investigation by the Consumer Credit Division. The Notice alleges that Respondent: (1) failed to adequately reconcile its collection trust accounts, in violation of Section 36a-811 of the Connecticut General Statutes, in effect at such time; (2) failed to remit money collected which was not in dispute to clients and escheat unclaimed property in a timely manner, in violation of Section 36a-805(a)(9) of the Connecticut General Statutes, in effect at such time; (3) failed to maintain a contract or other evidence of an agreement substantiating such debt and charged a Connecticut debtor a collection fee in excess of 15% of the amount collected, in violation of Section 36a-805(a)(12) of the Connecticut General Statutes, in effect at such time; (4) charged consumers convenience fees for certain methods of payment, in violation of Section 36a-805(a)(12) of the Connecticut General Statutes, in effect at such time; (5) failed to update its most recent application filed on the Nationwide Multistate Licensing System and Registry (“NMLS”), in violation of Section 36a-801(e) of the Connecticut General Statutes, in effect at such time; (6) made statements to the Commissioner in response to the Department’s examination findings that were, at the time and in the light of the circumstances under which they were made, false or misleading in a material respect, in violation of Section 36a-53a of the Connecticut General Statutes; (7) failed to provide the Department with thirty (30) calendar days advance notice of a change in location and provide a bond rider, endorsement or addendum to the bond, in violation of Section 36a-801(i) of the Connecticut General Statutes; and (8) that Respondent’s conduct renders the Commissioner unable to determine that the financial responsibility, character, reputation, integrity and general fitness of Respondent are such to warrant belief that the business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-800 to 36a-814, inclusive, as required pursuant to Section 36a-801(c)(2) of the Connecticut General Statutes. Respondent was afforded an opportunity to request a hearing with regard to the allegations set forth in the Notice.

      Dated: Tuesday, November 26, 2019