Bulletin # 3143 - Week Ending May 17, 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.

BANK ACTIVITY

Out-of-State Trust Company 

On May 14, 2024, the Commissioner approved the application of Argentum Peak, LLC, a Wyoming-chartered non-depository trust company, to establish a trust office in Connecticut pursuant to Section 36a-434a of the Connecticut General Statutes. The office will be located at 600 Washington Boulevard, 7th floor, in Stamford, Connecticut.

CONSUMER CREDIT ACTIVITY

Consent Order

On May 15, 2024, the Commissioner entered into a Consent Order with LoanSnap, Inc. d/b/a LoanSnap (NMLS # 76967) (“LoanSnap”), Costa Mesa, California. The Consent Order resolved allegations made by the Commissioner in 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 against LoanSnap issued on January 4, 2024 (“Order and Notice”). The Order and Notice was the result of an examination by the Consumer Credit Division. The Order and Notice alleged that from at least August 29, 2022 to December 2, 2022, LoanSnap: (1) 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) 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) required that Connecticut applicants submit documents verifying information related to the application before providing loan estimates required under 12 CFR Section 1026.19(e)(1)(i) of Regulation Z, 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) 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) 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; and (6) 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. As part of the Consent Order, among other items, LoanSnap agreed to pay $75,000 as a civil penalty and $1,200 as payment for back licensing fees.

      Dated:  Tuesday, May 21, 2024

      Jorge L. Perez
      Banking Commissioner