Bulletin # 3125 - Week Ending January 12, 2024

This bulletin constitutes the only official notification you will receive from this office concerning any of the following applications.  Any observations you may have are solicited.  Any comments should be in writing to Jorge L. Perez, Banking Commissioner, Department of Banking, 260 Constitution Plaza, Hartford, CT 06103-1800.  Written comments will be considered only if they are received within ten business days from the date of this bulletin.

CREDIT UNION ACTIVITY 

Merger

On January 8, 2024, Nutmeg State Financial Credit Union, a Connecticut credit union, and First Bristol Federal Credit Union, a federal credit union, filed an application pursuant to Section 36a-468a of the Connecticut General Statutes seeking approval for the merger of First Bristol Federal Credit Union with and into Nutmeg State Financial Credit Union. The proposed target date for this merger is June 1, 2024.

CONSUMER CREDIT DIVISON ACTIVITY 

Temporary Order to Cease and Desist, Notice of Intent to Revoke and Refuse to Renew Mortgage Lender License, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing

On January 4, 2024, the Commissioner issued a Temporary Order to Cease and Desist, Notice of Intent to Revoke and Refuse to Renew Mortgage Lender License, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing (collectively, “Order and Notice”) in the Matter of: LoanSnap, Inc. d/b/a LoanSnap, NMLS # 76967 (“Respondent”), Costa Mesa, California. The Order and Notice was a result of an examination by the Consumer Credit Division. The Commissioner alleges in the Order and Notice that: (1) Respondent engaged the services of at least four individuals to act as mortgage loan originators in Connecticut who were not licensed, in violation of 12 CFR Section 1026.36(f)(2) of Regulation Z, Section 36a 486(b)(1) of the Connecticut General Statutes in effect at such time, and Section 36a 678(a) of the Connecticut General Statutes; (2) Respondent assisted or aided and abetted the conduct of at least four individuals acting as mortgage loan originators without valid licenses, in violation of Section 36a-498e(a)(6) of the Connecticut General Statutes in effect at such time; (3) Respondent required that Connecticut applicants submit documents verifying information related to the application before providing Loan Estimates, in violation of 12 CFR Section 1026.19(e)(2)(iii) of Regulation Z and Section 36a-678(a) of the Connecticut General Statutes; (4) Respondent failed to provide Connecticut applicants the adverse action notices required by the Fair Credit Reporting Act, in violation of 15 USC Section 1681m(a); (5) Respondent failed to comply with Sections 36a 485 to 36a-498e, inclusive, 36a-498h, 36a 534a and 36a-534b of the Connecticut General Statutes or other state or federal law applicable to its business, in violation of Section 36a 498e(a)(8) of the Connecticut General Statutes in effect at such time; (6) Respondent failed to establish, enforce and maintain policies and procedures reasonably designed to achieve compliance with Section 36a-498e(a) of the Connecticut General Statutes in effect at such time, in violation of Section 36a-498e(b)(1) of the Connecticut General Statutes; and (7) The conduct of Respondent fails to demonstrate that its character and general fitness are such as to command the confidence of the community and to warrant a determination that Respondent will operate honestly, fairly and efficiently within the purposes of Sections 36a-485 to 36a-498e, inclusive, 36a-498h, 36a-534a and 36a-534b, as required by Section 36a-489(a)(1)(C) of the Connecticut General Statutes. The Commissioner found that the public welfare required the issuance of Temporary Order to Cease and Desist against Respondent. Respondent was afforded an opportunity to request a hearing with regard to the allegations set forth in the Order and Notice.