Temporary Order to Cease and Desist (ChecKings LLC d/b/a Family Financial Centers and Joana de Oliveira McLaughlin and Diane CammarataNMLS 1499209)

Findings of Fact

1. The Division of Banks (Division), through the Commissioner, has jurisdiction over the licensing and regulation of persons and entities engaged in the check cashing business in Massachusetts pursuant to Massachusetts General Laws chapter 169A, section 2 and applicable regulations found at 209 CMR 45.00 et seq., which are administered by the Commissioner.
2. ChecKings is, and at all relevant times has been, a corporation conducting business in the Commonwealth of Massachusetts. ChecKings is located at 328 Main Street, Everett, Massachusetts 02149.
3. ChecKings is not authorized to engage in the business of a check casher from any other location in Massachusetts.
4. ChecKings is licensed by the Commissioner as a check casher under Massachusetts General Laws chapter 169A, section 2. According to records maintained on file with the Division and the Nationwide Multi-State Licensing System (NMLS), the Commissioner issued ChecKings a license to engage in the business of a check casher at 328 Main Street, Everett, Massachusetts 02149 on August 3, 2017.
5. The Division's licensing system of record is the NMLS and licensees and all control people are required to maintain an updated record.
6. According to the Division's records, Joana De Oliveira McLaughlin is the 75% owner of ChecKings.
7. According to the Division's records, Diane Cammarata is the 25% owner of ChecKings.
8. ChecKings is a check casher as defined by the Bank Secrecy Act (BSA) and its implementing regulation at 31 C.F.R. Chapter X. ChecKings is also required to register as a money services business with the Department of Treasury's Financial Crimes and Enforcement Network (FinCEN) and is obligated to comply with all applicable BSA programmatic, recordkeeping, and reporting requirements.

A. Failure to Demonstrate the Character, Reputation, Integrity and General Fitness to Maintain a Check Casher License

1. The Division's regulation 209 CMR 45.03 establishes the application procedure for those entities that wish to engage in the check cashing business.
2. The Division's regulation 209 CMR 45.03(2)(c) states in part:
   Character and Fitness. An Applicant shall submit information demonstrating that the Applicant possesses the character, reputation, integrity, and fitness to engage in the licensed business in an honest, fair, sound, and efficient manner.
3. The Division's regulation 209 CMR 45.05 establishes the licensing standards for check cashers and 209 CMR 45.05(2) states in part:
   
   (2) (a) The Commissioner may deny an application to engage in the business of check cashing, if the Commissioner upon review of the application and other relevant information, determines that the Applicant has not satisfied the requirements of 209 CMR 45.03 or 45.04, or M.G.L. c. 169A.
   (b) The Commissioner may also deny such an application or the renewal thereof if the Applicant has:
   1. violated any provisions of M.G.L. c. 169A or 209 CMR 45.00;
   2. violated or engaged in a pattern of violations of any state or federal law applicable to the conduct of a business of a casher of checks or any rule, regulation or administrative order or directive promulgated thereunder;
   3. conducted or will conduct its business in an unsafe or unsound manner; and
   4. engaged in conduct which has resulted in the suspension or revocation of its license to engage in the business of a casher of checks or any other business by any licensing authority of any other state.
4. The Division's regulation 209 CMR 45.13 establishes grounds for license revocation, the issuance of cease and desist orders, or other disciplinary actions included in 209 CMR 45.13(1)(j), which states:
   
   It shall be a prohibited act or practice for a Licensee to:
   (j) Knowingly participate in fraud or in an attempt to defraud.
5. On or around May 12, 2026, the Division received a report of alleged fraud (Report) by a depository institution (Institution) as required pursuant to the provisions of Massachusetts General Laws chapter 167, section 10.
6. The Report alleged that the Institution had become aware of check fraud perpetrated against the Institution by Joana De Oliveira McLaughlin, individually, and ChecKings.
7. The Report further identified Joana De Oliveira McLaughlin as the individual depositing checks involved in the alleged check fraud on behalf of ChecKings.
8. According to information provided by the Institution, ChecKings had a historic approximate return rate of 15% on checks deposited with the Institution. In March 2026 approximately 61% of the checks presented for deposit were returned, and in April 2026 approximately 78% of the checks presented were returned. In prior months, ChecKings had an approximate return rate of 15% on checks deposited with the Institution.
9. The Report alleged that in a review of a transaction history for the ChecKings account held at the Institution between March 1, 2026, and March 31, 2026, the aggregate amount of all deposits was $21,637,926.68. The deposits were made in person with the Institution by Joana De Oliveira McLaughlin and two unnamed ChecKings employees.
10. The Report further alleged that a review of the deposits revealed that from March 1, 2026, through March 27, 2026, at least 237 checks that were deposited were returned, totaling $7,769,798.36.
11. The Report further noted that the Institution was in the process of conducting an analysis of April 2026 transactions and as of the date the Report was sent to the Division, the Institution confirmed 61 returned deposit items, totaling $1,550,787.77.
12. A significant amount of the checks returned in March and April 2026 contained clear indicators of risk. For example, many of the makers of the checks appear to be closed businesses. Many of the checks were written back and forth between the same companies or individuals, and many of the returned checks appear to be from different makers but appear to be written with similar handwriting and/or with similar signatures. ChecKings continued to cash checks for clients despite the client having previous checks returned.

B. Failure to Demonstrate the Financial Responsibility Necessary to Maintain a Check Casher License

1. The Division's regulation 209 CMR 45.03(2)(a) states in part:
   
   Financial Responsibility. An Applicant shall demonstrate and maintain a net worth of not less than $25,000 and maintain adequate liquidity for the nature and volume of the Applicant's business. A review of financial responsibility may include a review of historical net losses, profitability, and any other information that the Commissioner may deem necessary.
2. The significant volume and dollar amount of returned checks raises serious doubt as to whether ChecKings continues to meet the minimum net worth and financial responsibility standards for licensed check cashers.

C.Unlicensed Check Cashing Activity

1. Massachusetts General Laws chapter 169A, section 2 states in part:
   No person or entity shall engage in cashing checks, drafts or money orders for a consideration in excess of one dollar per item without first obtaining a license from the commissioner.
2. Massachusetts General Laws chapter 169A, section 5 states in part:
   Each license shall state the address at which the business is to be conducted and, if a mobile unit, the appropriate identification thereof, and shall state fully the name of the licensee. If a licensee intends to carry on business in more than one location or, in the case of a mobile unit, in an area greater than that specified on the license, he shall procure a license for each place or area where such business is to be conducted. [Emphasis added]
3. The Division's regulation 209 CMR 45.08(1) states:
   Office Locations. A Licensee shall obtain a separate license in order to conduct business at another location.
4. The Division's regulation 209 CMR 45.04 states, in part:
   If the licensed check casher business is to be conducted from a mobile unit, the Applicant must provide the following information, in addition to the information required under 209 CMR 45.03:
   1. the Massachusetts motor vehicle registration number or other satisfactory identification of the mobile unit;
   2. a description of the area in which the Applicant seeks to utilize the mobile unit;
   3. information demonstrating the adequacy of the vehicle for the transaction of cashing a check, draft, or money order, including, but not limited to, provisions relative to security; and
   4. other information which the Commissioner may require
5. The Report alleged that the internal investigation conducted by the Institution revealed that it was Joana De Oliveira McLaughlin's practice to "drive to different locations to gather checks from 'customers,' then bring them back to her place of business, process the checks, and then deliver the cash to customers."
6. During the license application process, the Company reported it would be open and operational during "typical bank hours" which the Company defined as 8:30/9:00 am - 4:30/5:00 pm except on Thursdays and Fridays where the location may be open an hour later because those were typical payroll days.
7. Based on the allegations outlined in the Report, the Division commenced an investigation of the allegation that the Company received checks at locations other than its authorized 328 Main Street location. As part of its investigation, the Division's field staff attempted to conduct a visitation of the business location. Division field staff visited the ChecKings location at 328 Main Street in Everett on July 13, 2026, between the hours of 10:30 am and 11:45 am and on July 23, 2026, between 9:58 am and 10:05 am as the Division expected the Company to be open at that location at that time. On each occasion, the location was closed and inaccessible to the Division's staff.
8. The Division has no record of ChecKings notifying the Division that their hours of operation had changed.
9. The Division has no record of ChecKings' submission of an application to conduct the check cashing business from a mobile unit.

D. Failure to Provide Access to Books and Records and Failure to Maintain Adequate Records

1. Pursuant to Massachusetts General Laws chapter 169A, section 10, the Division is authorized to inspect the books, accounts, records, and files of check cashers transacting business in Massachusetts to determine compliance with the provisions of Massachusetts General Laws or any rule, or regulation issued thereunder, and with any law, rule, or regulation applicable to the conduct of the business of a check casher.
2. The Division's regulation, 209 CMR 45.09(1) states, in part:
   Each Licensee shall keep and use within the Commonwealth its books, records and accounts in a manner which will allow the Commissioner to determine whether the Licensee is complying with the provisions of M.G.L. c. 169A and 209 CMR 45.00 and applicable state and federal laws and regulations.
3. The Division's regulation, 209 CMR 45.09(3) states, in part:
   1. (3) A Licensee shall maintain, at a minimum, the following records:
      1. A daily written record of all check cashing transactions occurring each day, which shall be limited to the following, provided a sufficient audit trail is available through records obtainable from the Licensee's bank account(s):
         1. The amount of the check cashed;
         2. The amount of the fee charged for cashing the check; and 3. The name and address of the consumer conducting the transaction.
      2. A daily cash reconcilement summarizing each day's activity and reconciling cash on hand at the opening of business to cash on hand at the close of business, and which shall separately reflect cash received from the redemption of returned items, bank cash withdrawals, cash disbursed in cashing of checks, and bank cash deposits; and
      3. Copies of any agreements between the Licensee and third parties relative to check cashing activities.
4. The Division's regulation 209 CMR 48.00 which is the Division's "Licensee Record Keeping" regulation, requires licensees to provide immediate access to these records in response to an official request by the Division.
5. The Division's regulation at 209 CMR 48.06(2) establishes the effect of non-compliance with the Division's request for access to books and records and states in part:
   If you do not comply with 209 CMR 48.00, the Commissioner may take enforcement action against you, including but not limited to, the suspension or revocation of your license under applicable authority.
6. The Division's regulation 209 CMR 45.13 establishes grounds for license revocation, the issuance of cease and desist orders, or other disciplinary actions included in 209 CMR 45.13(1)(e), which states:
   It shall be a prohibited act or practice for a Licensee to:
   1. Fail to maintain books and records as required by 209 CMR 45.09 and 209 CMR 48.00: Licensee Record Keeping;
7. On July 20, 2026, the Division initiated a demand for the production of records (Demand) pursuant to Massachusetts General Laws chapter 169A, section 10 based on a review of the Report and the Division's internal investigation.
8. The Demand requested all documents to be produced by the end of business on Friday July 24, 2026.
9. The Demand, which was sent via email to all email addresses on the Company record on the NMLS, required the following to be produced:
   1. Bank statements for all ChecKings' "check cashing" account/s, including copies of cancelled checks and reconciliation.
   2. Bank statements for all ChecKings' "operating" account/s, including copies of cancelled checks and reconciliation.
   3. Bank statements for all ChecKings' "Western Union" account/s, including copies of cancelled checks and reconciliation.
   4. Bank statements for all McLaughlin Corporation's "checking" and "savings" accounts, including copies of cancelled checks and reconciliation.
   5. Bank statements for all Joana McLaughlin's "personal checking" and "personal savings" account/s, including copies of cancelled checks and reconciliation.
   6. A complete copy of the daily record of checks cashed (check cashing log) for the period of January 1, 2026 through June 30, 2026.
   7. An update on the status of business operations at the licensed location, 328 Main Street, Everett during the period in question.
   8. Indicate if the licensed location is open for check cashing business as per the operational hours previously disclosed to the Division.
   9. Provide an explanation of any check cashing activity conducted at any place other than the licensed location during the period in question.
   10. Provide a current breakdown of licensee ownership and management.
       ChecKings and Joana De Oliveira McLaughlin failed to provide accurate records in response to Division's Demand.
10. Through counsel, ChecKings and Joana De Oliveira McLaughlin provided a response to the Demand (Response).
11. The Response states, in part, "ChecKings is actively applying to open new bank accounts and intends to resume operations at the licensed location once new business bank accounts are in place."
12. As part of the Response, ChecKings and Joana De Oliveira McLaughlin provided a log purporting to list all checks cashed by ChecKings from approximately January 2, 2026, through April 22, 2026.
13. The Division attempted to reconcile the check cashing log provided by ChecKings against the records of the Institution for checks presented by ChecKings for deposit. The Division found that the majority of returned checks identified in the Institution's log were not listed in the check cashing log provided by ChecKings to the Division.
14. Investigations are still ongoing, but in March 2026, ChecKings presented to the Institution at least 263 checks that were returned. Of the checks returned, 215 (81.7%) were not found in the log provided by ChecKings to the Division.
15. In April 2026, ChecKings presented 429 checks to the Institution that were returned. Of the checks returned, 341 (79.5%) were not found in the log provided by ChecKings to the Division.
    Diane Cammarata has failed to respond the Division's Inquiries
16. On July 21, 2026, the Division had a virtual call with counsel for ChecKings and Joana De Oliveira McLaughlin, during which the attorney clarified that his representation did not extend to Diane Cammarata, 25% owner of ChecKings.
17. On July 21, 2026, the Division attempted to contact Diane Cammarata via the contact information identified on the Company's NMLS record. The Division reached out via email and via the two telephone numbers identified on the Company's NMLS record; however, the Division has received no response to the email, and each phone number was identified as being "no longer in service."
18. Through a public records search via www.whitepages.com, the Division's licensing unit was able to access a landline number associated with Diane Cammarata's residential address.
19. On July 21, 2026, at 2:41 pm, the Division attempted to contact Diane Cammarata on the landline number. The Division's call went to voicemail, which identified the number as belonging to Diane Cammarata. The Division left a voicemail requesting a call back to discuss a time-sensitive and pending matter.
20. To date, Diane Cammarata having failed to update her contact information in NMLS has also failed to return the Division's voicemail or email.
    ChecKings failed to maintain records sufficient for the Division todetermine the Company's Compliance with the BSA's Currency Transaction Report (CTR) Filing Requirements
21. The BSA's implementing regulation at 31 CFR §1010.311, states in part:
    Each financial institution other than a casino shall file a report of each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to such financial institution which involves a transaction in currency of more than $10,000.
22. The BSA's implementing regulation at 31 CFR §1010.306(a)(1), states in part:
    A report required by §1010.311 or §1021.311, shall be filed by the financial institution within 15 days following the day on which the reportable transaction occurred.
23. The Division conducted an investigation of the 61 checks returned [to the Institution] in April 2026, totaling $1,550,787.77, and made a preliminary determination that all but one of these checks would likely have required the filing of a CTR. Because of the deficiencies in the Company's check cashing log, referred to in Paragraphs 42 - 45, which failed to list 58 of the returned checks referenced in information provided by the Institution, the Division was unable to determine if a CTR should have, in fact, been filed for any of the 58 checks returned in April 2026.
24. In the three instances where the Division was able to determine that CTRs should have been filed for returned checks in 2026, the Division was unable to locate any record of such CTRs having been filed.

Conclusions of Law

1. Based on the information contained in Paragraphs 1 through 55, ChecKings has failed to demonstrate the financial responsibility, character, reputation, integrity, and general fitness that would warrant the belief that the business will be operated honestly, fairly, and soundly in the public interest in violation of Massachusetts General Laws chapter 169A, section 3, and the Division's regulations 209 CMR 45.03 and 209 CMR 45.05.
2. Based on the information contained in Paragraphs 1 through 55, ChecKings and Joana De Oliveira McLaughlin have engaged in prohibited acts and practices by knowingly participating in fraud or in an attempt to defraud, in violation of the Division's regulation 209 CMR 45.13(1)(j).
3. Based upon the information contained in Paragraphs 1 through 55, by engaging in unlicensed check cashing activity via a mobile unit, ChecKings violated Massachusetts General Laws chapter 169A, section 2, Massachusetts General Laws chapter 169A, section 5, and the Division's regulations 209 CMR 45.08(1) and 209 CMR 45.04.
4. Based on the information contained in Paragraphs 1 through 55, ChecKings failed to maintain adequate books and records to ensure compliance, in violation of the Division's regulation 209 CMR 45.09(3).
5. Based on the information contained in Paragraphs 1 through 55, ChecKings and Joana De Oliveira McLaughlin have engaged in prohibited acts and practices by failing to maintain adequate books and records, in violation of the Division's regulation 209 CMR 45.13(1)(e).
6. Based upon the information contained in Paragraphs 1 through 55, the public interest will be harmed by delay in issuing an Order to Cease and Desist under General Laws chapter 169A, section 9 because, upon information and belief, ChecKings and its majority owner have engaged in activity that has perpetuated fraud, failed to maintain accurate books and records, may no longer meet the minimum net worth and financial responsibility requirements, and may be or may have been engaged in unlicensed check cashing activity from locations other than its authorized location at 328 Main Street in Everett. Counsel for the Company has indicated the Company is in search of a new bank partner and intends to continue operations. The Division does not have confidence in the Company or its owners to operate honestly and with integrity and believes the public interest requires the Division to take immediate action against the license of the Company.
7. Based on the information contained in Paragraphs 1 through 55, had the facts and conditions found therein existed at the time of ChecKings' original check casher license application, the Commissioner would have been warranted in refusing to issue such license.
8. Based upon the information contained in Paragraphs 1 through 55, the Commissioner has determined that:
   1. ChecKings has engaged, or is about to engage in, acts or practices which warrant the belief that the Company is not operating honestly, fairly, soundly and efficiently in the public interest in violation of standards governing the licensing and conduct of a check casher including, but not limited to, the provisions under General Laws chapter 169A and the Division's regulations at 209 CMR 45.00 et seq.
   2. The public interest will be irreparably harmed by delay in issuing an Order to Cease and Desist against ChecKings.

Order to Cease and Desist

After taking into consideration the Findings of Fact and Conclusions of Law stated herein, it is hereby:

1. Ordered that ChecKings, any and all officers, directors, employees, independent contractors, or agents operating on behalf of ChecKings, and their successors or assigns, shall immediately cease engaging directly or indirectly in the business of a check casher in Massachusetts, as defined in General Laws chapter 169A, section 1, except as otherwise expressly permitted by the terms of this Temporary Order or by the Commissioner.
2. It is further ordered that Joana De Oliveira McLaughlin shall immediately cease engaging in the check cashing business as defined in General Laws chapter 169A, section 1 and furthermore is prohibited from taking an ownership position in an entity licensed under General Laws chapter 169A and from participating, in any manner, in the responsibilities or duties of a control person of such an entity.
3. It is further ordered that Diane Cammarata shall immediately cease engaging in the check cashing business as defined in General Laws chapter 169A, section 1 and furthermore is prohibited from taking an ownership position in an entity licensed under General Laws chapter 169A and from participating, in any manner, in the responsibilities or duties of a control person of such an entity.
4. It is further ordered that ChecKings shall post, in a clear and conspicuous manner, on any websites the Company operates and at 328 Main Street, Everett, Massachusetts a notice which contains the following statement: "If you have an unresolved complaint concerning ChecKings you may contact the Division of Banks by calling the Division's Consumer Assistance Unit at (800) 495-2265 within Massachusetts, outside of Massachusetts call (617) 956-1500 ext. 501, or by filing a written complaint with the Division of Banks at https://www.mass.gov/how-to/file-a-complaint-with-the-division-of-banks."
5. It is further ordered that ChecKings shall immediately secure all records, files, and documents (Records) relative to the Company's check cashing business. ChecKings is prohibited from destroying, altering, and/or modifying any of the referenced Records. The Records shall be available to the Commissioner in their entirety upon request.
6. It is further ordered that ChecKings, shall reimburse all fees collected by the Company for unlicensed check cashing activity from a mobile unit or any other unlicensed location. Reimbursements shall be made to each person on a per transaction basis in an amount equal to the entire portion of the fee retained by the Company for such transaction. A record shall be provided to the Division of the names and addresses of all individuals whom the Company charged a fee for the purpose of cashing a check, the total fees charged on each transaction, and check numbers of payments issued by the Company to evidence reimbursements made to consumers, and the amount reimbursed to each individual.
7. It is further ordered that this Temporary Order shall become effective immediately and shall remain in effect unless set aside, limited, or suspended by the Commissioner or upon court order after review pursuant to General Laws chapter 30A.
8. IIt is further orderedthat a hearing will be scheduled on this matter to determine whether or not such Temporary Order shall become permanent and final only upon receipt of a written request for such a hearing from the Licensee within twenty (20) days of the effective date of this Temporary Order. If no hearing is requested within this twenty (20) day period, this Temporary Order shall become permanent and final until it is modified or vacated by the Commissioner.

By Order and Direction of the Commissioner of Banks.

Dated at Boston, Massachusetts, this 31st day of July 2026.

By: Mary L. Gallagher
Commissioner of Banks
Commonwealth of Massachusetts