Bulletin 3214 - September 26, 2025

The Department of Banking News Bulletin

Bulletin # 3214 - Week Ending September 26, 2025

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 directed to Jorge L. Perez, Banking Commissioner. Written comments will be considered only if they are received within ten business days from the date of this bulletin.

CONSUMER CREDIT DIVISION ACTIVITY

Notice of New Exempt Mortgage Servicer Registration, Electronic Surety Bond Requirement and No-Action Position

On September 23, 2025, the Department issued a Notice of New Exempt Mortgage Servicer Registration, Electronic Surety Bond Requirement and No-Action Position concerning new exempt mortgage servicer registration requirements. From October 1, 2025, applications for exempt mortgage servicer registrations will be accepted on the Nationwide Multistate Licensing System and Registry ("NMLS") from any person licensed as a mortgage lender in Connecticut that seeks to commence or continue acting as a mortgage servicer from a licensed location on and after October 1, 2025. The new exempt mortgage servicer registration replaces the previous exemption for a licensed mortgage lender acting as a mortgage servicer from a licensed location. Effective October 1, 2025, or such later date that NMLS makes electronic surety bond functionality available, exempt mortgage servicer registrants and applicants shall file the surety bond required by the Commissioner pursuant to Section 36a-719c, as amended by Section 14 of Public Act 25-115, electronically on NMLS. To allow mortgage lenders sufficient time to file an application and comply with the requirements, the Department issued a no-action position concerning mortgage servicer licensure requirements for lenders who file applications by November 1, 2025.

Legal Funding, LLC d/b/a Crash Advance

On September 24, 2025, the Commissioner entered into a Consent Order with Legal Funding, LLC d/b/a Crash Advance, ("Legal Funding"), East Haven, Connecticut. The Consent Order was the result of a consumer complaint that resulted in an investigation by the Consumer Credit Division. The Consent Order resolved allegations made by the Commissioner in a Temporary Order to Cease and Desist, Order to Make Restitution, 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") issued on September 16, 2022. The Order and Notice alleged that Legal Funding: (1) made at least two small loans for a Connecticut borrower without the required license, in violation of Section 36a 556(a)(1) of the Connecticut General Statutes, in effect at such time; (2) enforced and collected monies in connection with at least two small loans against a Connecticut borrower without the required license, in violation of Section 36a-558(c)(1) of the Connecticut General Statutes, in effect at such time; and (3) failed to provide information requested during the Investigation, in violation of Section 36a 17(e) of the Connecticut General Statutes, in effect at such time. Legal Funding requested a hearing on the allegations in the Order and Notice, and after a hearing on August 8, 2023, the Commissioner issued a Findings of Fact, Conclusions of Law and Order against Legal Funding ("Final Order"). Legal Funding filed an appeal to the Appellate Court of the State of Connecticut ("Appeal") challenging the Superior Court's decision to dismiss the administrative appeal against the Final Order, which Appeal is pending. As part of the Consent Order, Legal Funding agreed to create and maintain a fund in the amount of $50,000 for the purpose of repayments to any Connecticut borrowers that entered into any advanced funding agreement with Legal Funding and paid sums on the same and withdraw its Appeal. The Consent Order vacated the Final Order.

Coinme Inc. d/b/a Coinme

On September 24, 2025, the Commissioner entered into a Consent Order with Coinme Inc. d/b/a Coinme (NMLS # 1185542), ("Coinme"), Seattle, Washington. The Consent Order was the result of an examination and investigation by the Consumer Credit Division. The Consent Order resolved allegations made by the Commissioner in an Order of Summary Suspension, Temporary Order to Cease and Desist, Order to Make Restitution, Order to Provide Disgorgement, Notice of Intent to Revoke and Refuse to Renew Money Transmission 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") issued on October 25, 2024. The Order and Notice alleged that Coinme: (1) engaged an entity to perform functions constituting money transmission activities in this state without establishing an authorized delegate relationship, in violation of Section 36a-607(a)(1) of the Connecticut General Statutes; (2) failed to maintain the minimum tangible net worth required of money transmission licensees, in violation of Sections 36a-600(d) and 36a-604(c) of the Connecticut General Statutes; (3) failed to establish, enforce, and maintain policies and procedures for supervising employees, agents and office operations that are reasonably designed to achieve compliance with applicable money transmission laws and regulations, in violation of Sections 36a-606a and 36a 607(c)(10) of the Connecticut General Statutes; and (4) that the totality of Respondent's conduct is likely to otherwise materially prejudice the interests of Connecticut consumers, and cause Respondent to be engaged in unsafe or unsound practices within the meaning of Section 36a 608(a) of the Connecticut General Statutes. The Order and Notice also alleged that the totality of Coinme's conduct caused the Commissioner unable to find that Coinme's financial condition is sound, its business will be conducted honestly, fairly, equitably, carefully and efficiently within the purposes and intent of Sections 36a-595 to 36a 612, inclusive, of the Connecticut General Statutes, in a manner commanding the confidence and trust of the community. As part of the Consent Order, Coinme paid $10,000 as a civil penalty and agreed to make restitution payments to 4 Connecticut consumers.

Dated: Tuesday, September 30, 2025

Jorge L. Perez
Banking Commissioner