DOB: Cornerstone Credit Corporation, Rene M. Gagnon, Temporary Order to Cease and Desist, Notice of Intent to Issue Order to Cease and Desist, Intent to Impose Civil Penalty and Right to Hearing

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IN THE MATTER OF:

CORNERSTONE CREDIT
CORPORATION ("Cornerstone")

RENE M. GAGNON ("Gagnon")

    (collectively "Respondents")

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TEMPORARY ORDER TO
CEASE AND DESIST

NOTICE OF INTENT TO ISSUE
ORDER TO CEASE AND DESIST

NOTICE OF INTENT TO IMPOSE CIVIL
PENALTY

AND

NOTICE OF RIGHT TO HEARING

I. LEGAL AUTHORITY AND JURISDICTION

The Banking Commissioner (“Commissioner”) is charged with the administration of Part XII of Chapter 669, Sections 36a-800 to 36a-810, inclusive, of the Connecticut General Statutes, “Consumer Collection Agencies”, and the regulations promulgated thereunder (Sections 36a-809-1 to 36a-809-5, inclusive, of the Regulations of Connecticut State Agencies) (“Regulations”).
 
Pursuant to the authority granted by Section 36a-17 of the Connecticut General Statutes, the Commissioner, through the Consumer Credit Division (“Division”) of the Department of Banking, has investigated the activities of Respondent to determine if it has violated, is violating or is about to violate the provisions of the Connecticut General Statutes.  Section 36a-17(a) of the Connecticut General Statutes provides that:

The commissioner, in the commissioner’s discretion, may make such public or private investigations or examinations within or outside this state, concerning any person subject to the jurisdiction of the commissioner, as the commissioner deems necessary to carry out the duties of the commissioner.

Section 36a-806(a) of the Connecticut General Statutes provides, in pertinent part, that:

The commissioner shall have power to examine the affairs of every consumer collection agency in this state in order to determine whether it has been or is engaged in any act or practice prohibited by sections 36a-805 to 36a-808, inclusive.

Section 36a-52(a) of the 2008 Supplement to the General Statutes provides, in pertinent part, that:

Whenever it appears to the commissioner that any person has violated, is violating or is about to violate any provision of the general statutes within the jurisdiction of the commissioner or any regulation . . . issued thereunder, the commissioner may send a notice to such person by registered or certified mail, return receipt requested, or by any express delivery carrier that provides a dated delivery receipt.  The notice shall be deemed received by the person on the earlier of the date of actual receipt, or seven days after mailing or sending.  Any such notice shall include:  (1) A statement of the time, place, and nature of the hearing; (2) a statement of the legal authority and jurisdiction under which the hearing is to be held; (3) a reference to the particular sections of the general statutes . . . [or] regulations . . . alleged to have been violated; (4) a short and plain statement of the matters asserted; and (5) a statement indicating that such person may file a written request for a hearing on the matters asserted within fourteen days of receipt of the notice.  If a hearing is requested within the time specified in the notice, the commissioner shall hold a hearing upon the matters asserted in the notice, unless the person fails to appear at the hearing.  After the hearing, the commissioner shall determine whether an order to cease and desist should be issued against the person named in the notice.  If the person does not request a hearing within the time specified in the notice or fails to appear at the hearing, the commissioner shall issue an order to cease and desist against the person.  No such order shall be issued except in accordance with the provisions of chapter 54.

Section 36a-52(b) of the 2008 Supplement to the General Statutes provides that:

If the commissioner finds that the public welfare requires immediate action, the commissioner may incorporate a finding to that effect in the notice sent in accordance with subsection (a) of this section and issue a temporary order requiring the person to cease and desist from the activity which constitutes such alleged violation and to take or refrain from taking such action as in the opinion of the commissioner will effectuate the purposes of this section.  Such temporary order shall become effective on receipt and, unless set aside or modified by a court, shall remain in effect until the effective date of a permanent order or dismissal of the matters asserted in the notice.

Section 36a-50(a) of the Connecticut General Statutes provides, in pertinent part, that:

(1) Whenever the commissioner finds as the result of an investigation that any person has violated any provision of the general statutes within the jurisdiction of the commissioner, or any regulation . . . issued thereunder, the commissioner may send a notice to such person by registered or certified mail, return receipt requested, or by any express delivery carrier that provides a dated delivery receipt.  The notice shall be deemed received by the person on the earlier of the date of actual receipt or seven days after mailing or sending.  Any such notice shall include:  (A) A statement of the time, place, and nature of the hearing; (B) a statement of the legal authority and jurisdiction under which the hearing is to be held; (C) a reference to the particular sections of the general statutes . . . [or] regulations . . . alleged to have been violated; (D) a short and plain statement of the matters asserted; (E) the maximum penalty that may be imposed for such violation; and (F) a statement indicating that such person may file a written request for a hearing on the matters asserted within fourteen days of receipt of the notice.

(2)  If a hearing is requested within the time specified in the notice, the commissioner shall hold a hearing upon the matters asserted in the notice unless such person fails to appear at the hearing.  After the hearing, if the commissioner finds that the person has violated any such provision . . . [or] regulation . . . the commissioner may, in the commissioner’s discretion and in addition to any other remedy authorized by law, order that a civil penalty not exceeding one hundred thousand dollars per violation be imposed upon such person.  If such person does not request a hearing within the time specified in the notice or fails to appear at the hearing, the commissioner may, as the facts require, order that a civil penalty not exceeding one hundred thousand dollars per violation be imposed upon such person.

(3)  Each action undertaken by the commissioner under this subsection shall be in accordance with the provisions of chapter 54.

Section 36a-804(b) of the 2008 Supplement to the General Statutes provides, in pertinent part, that:

Whenever it appears to the commissioner that any person has violated, is violating or is about to violate any of the provisions of sections 36a-800 to 36a-810, inclusive, or any regulation adopted pursuant thereto . . . the commissioner may take action against such person . . . in accordance with sections 36a-50 and 36a-52.

Section 36a-807(a) of the Connecticut General Statutes provides that:

If the commissioner determines that any person has been engaged, or is engaging, in violations of sections 36a-801 to 36a-808, inclusive, in any act or practice prohibited in section 36a-805, or in violations of any regulations issued pursuant to section 36a-809, the commissioner may order such person to cease and desist from such practices in accordance with section 36a-52.  In that connection, the commissioner may exercise the powers contained in section 36a-17.

Section 36a-808 of the Connecticut General Statutes provides, in pertinent part, that:

[W]henever it appears to the commissioner that any . . . person has violated, is violating, or is about to violate any provision of sections 36a-800 to 36a-810, inclusive, or any regulation adopted pursuant to section 36a-809, the commissioner may take action against such . . . person in accordance with section 36a-50.

Section 36a-809 of the Connecticut General Statutes provides that:

The powers vested in the commissioner by sections 36a-805 to 36a-808, inclusive, shall be additional to any other powers to enforce any penalties, fines or forfeitures authorized by law with respect to the methods, acts and practices prohibited or declared to be unfair or deceptive . . . .


II.  MATTERS ASSERTED

1.
Cornerstone is a Connecticut corporation with its main office currently located at 2024 East Main Street, Waterbury, Connecticut.
2.
Gagnon is President of Cornerstone and was President of Cornerstone during all relevant periods.
3.
From at least November 20, 1992 to September 30, 2005, Cornerstone was licensed by the Commissioner as a consumer collection agency in Connecticut.  Cornerstone has not been licensed with the Commissioner since September 30, 2005.
4.
From at least September 2005 to at least March 2008, Cornerstone, through Gagnon, attempted to collect and collected consumer debts from Connecticut on behalf of one or more medical and dental providers located in Connecticut.
5.
From at least September 2005 to at least March 2008, Cornerstone received payments which were not in dispute from one or more consumer debtors, which it then failed to account for and remit to its clients within sixty days from the last day of the month in which said money was collected.
6.
On or about November 20, 2007, the Commissioner received notice from Western Surety Company that bond number 22827379, issued on behalf of Cornerstone with respect to its consumer collection license, had been cancelled and voided as of October 27, 2007, or the earliest time permitted by applicable law, for nonpayment of premium.  To date, Cornerstone has failed to file a new bond or a replacement bond with the Commissioner.
7.
On or about February 19, 2008, July 8, 2008 and July 15, 2008, the Commissioner, through employees of the Division, went to the main office of Cornerstone to investigate and examine the affairs of Respondents to determine whether Respondents were engaging in the business of collecting or receiving for payment for others of any account, bill or other indebtedness from a consumer debtor and remitting such payments (“Investigation”).
8.
During the Investigation, Gagnon claimed, inter alia, neither he nor Cornerstone has consumer collection clients in Connecticut and that the only state in which Respondents collect consumer debts is Texas.  In fact, during that time frame, Respondents did have Connecticut consumer collection clients and were collecting consumer debts from their place of business in Connecticut.
9.
During the Investigation, the Commissioner, through employees of the Division, requested, inter alia, Cornerstone’s debtor and creditor records.  Cornerstone failed to produce such debtor and creditor records to the Division’s employees.
 

III.  STATUTORY AND REGULATORY BASIS FOR
TEMPORARY ORDER TO CEASE AND DESIST, ORDER TO
CEASE AND DESIST AND IMPOSITION OF CIVIL PENALTY

Section 36a-53a of the Connecticut General Statutes provides, in pertinent part, that:

No person shall make or cause to be made orally . . . in any . . . investigation . . . under this title, any statement which is, at the time and in the light of the circumstances under which it is made, false or misleading in any material respect.

Section 36a-800(1) of the Connecticut General Statutes prior to January 1, 2008, provided, and Section 36a-800(1) of the 2008 Supplement to the General Statutes currently provides, in pertinent part, that:

“Consumer collection agency” means any person engaged in the business of collecting or receiving for payment for others of any account, bill or other indebtedness from a consumer debtor . . . .

Section 36a-800(2) of the Connecticut General Statutes prior to January 1, 2008, provided, and Section 36a-800(2) of the 2008 Supplement to the General Statutes currently provides, in pertinent part, that:

“Consumer debtor” means any natural person, not an organization, who has incurred indebtedness or owes a debt for personal, family or household purposes . . . .

Section 36a-801(a) of the Connecticut General Statutes provides, in pertinent part, that:

No person shall act within this state as a consumer collection agency without a consumer collection agency license.  A consumer collection agency is acting within this state if it (1) has its place of business located within this state . . . .

Section 36a-802(a) of the Connecticut General Statutes provides that:

No such license and no renewal thereof shall be granted unless the applicant has filed with the commissioner a bond to the people of the state in the penal sum of five thousand dollars, approved by the Attorney General as to form and by the commissioner as to sufficiency of the security thereof.  Such bond shall be conditioned that such licensee shall well, truly and faithfully account for all funds entrusted to the licensee and collected and received by the licensee in the licensee’s capacity as a consumer collection agency.  Any person who may be damaged by the wrongful conversion of any creditor, consumer debtor or property tax debtor funds received by such consumer collection agency may proceed on such bond against the principal or surety thereon, or both, to recover damages.  The commissioner may proceed on such bond against the principal or surety thereon, or both, to collect any civil penalty imposed upon the licensee pursuant to subsection (a) of section 36a-50.  The proceeds of the bond, even if commingled with other assets of the licensee, shall be deemed by operation of law to be held in trust for the benefit of such claimants against the licensee in the event of bankruptcy of the licensee and shall be immune from attachment by creditors and judgment creditors.  The bond shall run concurrently with the period of the license granted to the applicant, and the aggregate liability under the bond shall not exceed the penal sum of the bond.

Section 36a-805(a) of the Connecticut General Statutes provides, in pertinent part, that:

No consumer collection agency shall: . . . (9) refuse or fail to account for and remit to its clients all money collected which is not in dispute within sixty days from the last day of the month in which said money is collected . . . .

Section 36a-809-1(a) of the Regulations provided, in pertinent part, that:

Each consumer collection agency shall maintain its debtor and creditor records so as to clearly identify the amounts and dates of all payments received from consumer debtors and all remittances made to creditors.  Debtor and creditor records shall be kept so as to be readily available to the commissioner or his authorized representative and retained for a period of not less than two years after the date of final entry thereon.  All accounting records shall be maintained in accordance with generally accepted accounting practices.

1.
Cornerstone’s engaging in the business of collecting consumer debts, as more fully described in paragraph 4 of the Matters Asserted, constitutes a violation of Section 36a-801(a) of the Connecticut General Statutes, which forms the basis to issue an order to cease and desist pursuant to Sections 36a-804(b) and 36a-52(a) of the 2008 Supplement to the General Statutes and Section 36a-807(a) of the Connecticut General Statutes and an order imposing civil penalty pursuant to Section 36a-804(b) of the 2008 Supplement to the General Statutes and Sections 36a-808 and 36a-50(a) of the Connecticut General Statutes.  Section 36a-50(a) of the Connecticut General Statutes authorizes the Commissioner to impose a civil penalty upon Cornerstone in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a maximum civil penalty upon Cornerstone not to exceed One Hundred Thousand Dollars ($100,000), subject to Cornerstone’s right to a hearing on the allegations set forth above.
2.
Cornerstone’s receipt of payments from one or more consumer debtors which it then failed to timely remit to the creditor, as more fully described in paragraph 5 of the Matters Asserted, constitutes a violation of Section 36a-805(a)(9) of the Connecticut General Statutes, which forms the basis to issue an order to cease and desist pursuant to Sections 36a-804(b) and 36a-52(a) of the 2008 Supplement to the General Statutes and Section 36a-807(a) of the Connecticut General Statutes and an order imposing civil penalty pursuant to Section 36a-804(b) of the 2008 Supplement to the General Statutes and Sections 36a-808 and 36a-50(a) of the Connecticut General Statutes.  Section 36a-50(a) of the Connecticut General Statutes authorizes the Commissioner to impose a civil penalty upon Cornerstone in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a maximum civil penalty upon Cornerstone not to exceed One Hundred Thousand Dollars ($100,000), subject to Cornerstone’s right to a hearing on the allegations set forth above.
3.
Cornerstone’s failure to maintain a bond, as more fully described in paragraph 6 of the Matters Asserted, constitutes a violation of Section 36a-802(a) of the Connecticut General Statutes, which forms the basis to issue an order to cease and desist pursuant to Sections 36a-804(b) and 36a-52(a) of the 2008 Supplement to the General Statutes and Section 36a-807(a) of the Connecticut General Statutes and an order imposing civil penalty pursuant to Section 36a-804(b) of the 2008 Supplement to the General Statutes and Sections 36a-808 and 36a-50(a) of the Connecticut General Statutes.  Section 36a-50(a) of the Connecticut General Statutes authorizes the Commissioner to impose a civil penalty upon Cornerstone in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a maximum civil penalty upon Cornerstone not to exceed One Hundred Thousand Dollars ($100,000), subject to Cornerstone’s right to a hearing on the allegations set forth above.
4.
Cornerstone’s failure to produce its debtor and creditor records to the Department, as more fully described in paragraph 9 of the Matters Asserted, constitutes a violation of Section 36a-809-1(a) of the Regulations, which forms the basis to issue an order to cease and desist pursuant to Sections 36a-804(b) and 36a-52(a) of the 2008 Supplement to the General Statutes and Section 36a-807(a) of the Connecticut General Statutes and an order imposing civil penalty pursuant to Section 36a-804(b) of the 2008 Supplement to the General Statutes and Sections 36a-808 and 36a-50(a) of the Connecticut General Statutes.  Section 36a-50(a) of the Connecticut General Statutes authorizes the Commissioner to impose a civil penalty upon Cornerstone in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a maximum civil penalty upon Cornerstone not to exceed One Hundred Thousand Dollars ($100,000), subject to Cornerstone’s right to a hearing on the allegations set forth above.
5.
Gagnon’s engaging in the business of collecting consumer debts, as more fully described in paragraph 4 of the Matters Asserted, constitutes a violation of Section 36a-801(a) of the Connecticut General Statutes, which forms the basis to issue an order to cease and desist pursuant to Sections 36a-804(b) and 36a-52(a) of the 2008 Supplement to the General Statutes and Section 36a-807(a) of the Connecticut General Statutes and an order imposing civil penalty pursuant to Section 36a-804(b) of the 2008 Supplement to the General Statutes and Sections 36a-808 and 36a-50(a) of the Connecticut General Statutes.  Section 36a-50(a) of the Connecticut General Statutes authorizes the Commissioner to impose a civil penalty upon Gagnon in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a maximum civil penalty upon Gagnon not to exceed One Hundred Thousand Dollars ($100,000), subject to Gagnon’s right to a hearing on the allegations set forth above.
6.
Gagnon’s statements that, inter alia, neither he nor Cornerstone has consumer collection clients in Connecticut and that the only state in which Respondents collect consumer debts is Texas when, in fact, Respondents do have Connecticut consumer collection clients and were collecting consumer debts in Connecticut, as more fully described in paragraph 8 of the Matters Asserted, constitute a violation of Section 36a-53a of the Connecticut General Statutes, which forms the basis to issue an order to cease and desist pursuant to Section 36a-52(a) of the 2008 Supplement to the General Statutes and an order imposing civil penalty pursuant to Section 36a-50(a) of the Connecticut General Statutes.  Section 36a-50(a) of the Connecticut General Statutes authorizes the Commissioner to impose a civil penalty upon Gagnon in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a maximum civil penalty upon Gagnon not to exceed One Hundred Thousand Dollars ($100,000), subject to Gagnon’s right to a hearing on the allegations set forth above.
 

IV.  TEMPORARY ORDER TO CEASE AND DESIST, NOTICE OF INTENT
TO ISSUE ORDER TO CEASE AND DESIST, NOTICE OF INTENT TO
IMPOSE CIVIL PENALTY AND NOTICE OF RIGHT TO HEARING

WHEREAS, the Commissioner has reason to believe that Respondents have engaged in acts or conduct which form a basis to issue an order to cease and desist against Respondents pursuant to Sections 36a-804(b) and 36a-52(a) of the 2008 Supplement to the General Statutes and Section 36a-807(a) of the Connecticut General Statutes and to impose a civil penalty against Respondents for each violation pursuant to Section 36a-804(b) of the 2008 Supplement to the General Statutes and Sections 36a-808 and 36a-50(a) of the Connecticut General Statutes;
 
WHEREAS, the Commissioner finds that public safety and welfare require emergency action with respect to Cornerstone’s engaging in the business of collecting consumer debts absent licensure, failing to timely remit payments to creditors, failing to maintain a bond and failing to produce its debtor and creditor records to the Division’s employees because consumers and creditors are being financially harmed and may continue to be harmed;
 
AND WHEREAS, the Commissioner finds that public safety and welfare require emergency action because consumers and creditors are being harmed with respect to Gagnon’s engaging in the business of collecting consumer debts absent licensure and making false statements to the Division’s employees because consumers and creditors are currently being financially harmed and may continue to be harmed.
 
NOW THEREFORE, the Commissioner hereby ORDERS, pursuant to Section 36a-52(b) of the 2008 Supplement to the General Statutes, that Cornerstone immediately CEASE AND DESIST from further violations of Sections 36a-801(a), 36a-802(a) and 36a-805(a)(9) of the Connecticut General Statutes and Section 36a-809-1(a) of the Regulations; and that Gagnon immediately CEASE AND DESIST from further violations of Sections 36a-53a and 36a-801(a) of the Connecticut General Statutes.  This Temporary Order shall become effective upon receipt by each Respondent and, unless set aside or modified by a court, shall remain in effect until the effective date of a permanent order or dismissal of the matters asserted in this Order.
 
THE COMMISSIONER FURTHER ORDERS, pursuant to Section 36a-52(b) of the 2008 Supplement to the General Statutes that Respondents shall:

(A)
As of the date of this Order, not collect or receive for payment, or attempt to collect or receive for payment, for others any account, bill or other indebtedness from a consumer debtor in Connecticut or from Connecticut;
(B)
As soon as possible, but no later than thirty (30) days from the date of this Order, provide each of their clients with a detailed final accounting of such client’s consumer debtor accounts;
(C)
As soon as possible, but no later than thirty (30) days from the date of this Order, remit to each of their clients the money owed to such clients;
(D)
As soon as possible, but no later than thirty (30) days from the date of this Order, return to each of their clients all papers, documents and other property of the clients submitted to Respondents in connection with their collection efforts;
(E) Immediately update each credit rating agency to reflect the current account information of all consumer debtors from whom payments were collected, and notify each credit rating agency that Cornerstone and Gagnon are no longer authorized to collect on such consumer debtor accounts;
(F)

Immediately, but no later than the next business day, return any and all payments from any consumer debtor received on or after the date of the Order;

(G)
As soon as possible, but no later than thirty (30) days from the date of this Order, provide via e-mail to the Division at dena.wood@ct.gov an accounting of:  (a) all funds previously received from consumer debtors; (b) all payments previously made on behalf of consumer debtors to their clients; and (c) all payments received from consumer debtors after the date of this Order which have been returned to such consumer debtors; and
(H)
As soon as possible, but no later than thirty (30) days from the date of this Order, provide to the Division verification of compliance with paragraphs (B) through (G), inclusive, of this Order.

FURTHER, notice is hereby given to Cornerstone that the Commissioner intends to issue an order requiring Cornerstone to CEASE AND DESIST from violating Sections 36a-801(a), 36a-802(a) and 36a-805(a)(9) of the Connecticut General Statutes and Section 36a-809-1(a) of the Regulations, and impose a CIVIL PENALTY upon Cornerstone in an amount not to exceed Four Hundred Thousand Dollars ($400,000), subject to its right to a hearing on the allegations set forth above.
 
FURTHER, notice is hereby given to Gagnon that the Commissioner intends to issue an order requiring Gagnon to CEASE AND DESIST from violating Sections 36a-53a and 36a-801(a) of the Connecticut General Statutes, and impose a CIVIL PENALTY upon Gagnon in an amount not to exceed Two Hundred Thousand Dollars ($200,000), subject to his right to a hearing on the allegations set forth above.
 
A hearing will be granted to each Respondent if a written request for a hearing is received by the Department of Banking, Legal Division, 260 Constitution Plaza, Hartford, Connecticut 06103-1800 within fourteen (14) days following each respondent’s receipt of this Temporary Order to Cease and Desist, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing as set forth in Section 36a-50(a) of the Connecticut General Statutes and Section 36a-52(a) of the 2008 Supplement to the General Statutes.  This Temporary Order to Cease and Desist, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing shall be deemed received on the earlier of the date of actual receipt, or seven days after mailing or sending.  The enclosed Appearance and Request for Hearing Form must be completed and mailed to the above address.  If either Respondent will not be represented by an attorney at the hearing, please complete the Appearance and Request for Hearing Form as “pro se”.  Once a written request for a hearing is received, the Commissioner may issue a notification of hearing and designation of hearing officer that acknowledges receipt of a request for a hearing, designates a hearing officer and sets the date of the hearing in accordance with Section 4-177 of the Connecticut General Statutes and Section 36a-1-21 of the Regulations of Connecticut State Agencies.  If a hearing is requested, the hearing will be held on October 7, 2008, at 9 a.m. at the Department of Banking, 260 Constitution Plaza, Hartford, Connecticut.
 
The hearing will be held in accordance with the provisions of Chapter 54 of the Connecticut General Statutes, unless Respondents fails to appear at the requested hearing.  At such hearing, each Respondent will have the right to appear and present evidence, rebuttal evidence and argument on all issues of fact and law to be considered by the Commissioner.
 
If Cornerstone does not request a hearing within the time prescribed, the Commissioner will issue an order that Cornerstone cease and desist from violating Sections 36a-801(a), 36a-802(a) and 36a-805(a)(9) of the Connecticut General Statutes and Section 36a-809-1(a) of the Regulations, and may order that the maximum civil penalty in an amount not to exceed Four Hundred Thousand Dollars ($400,000) be imposed upon Cornerstone.
 
If Gagnon does not request a hearing within the time prescribed, the Commissioner will issue an order that Gagnon cease and desist from violating Sections 36a-53a and 36a-801(a) of the Connecticut General Statutes, and may order that the maximum civil penalty in an amount not to exceed Two Hundred Thousand Dollars ($200,000) be imposed upon Gagnon.


So ordered at Hartford, Connecticut
this 4th day of August 2008.                         ________/s/_________
                                                               Howard F. Pitkin
                                                               Banking Commissioner




CERTIFICATION

I hereby certify that on this 4th day of August 2008, the foregoing Temporary Order to Cease and Desist, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing was sent by registered mail, return receipt requested, to Cornerstone Credit Corporation at:  2024 East Main Street, Waterbury, Connecticut 06705, registered mail no. RB028035035US; P.O. Box 3367, Waterbury, Connecticut 06705-2605, registered mail no. RB028035044US; and to Rene M. Gagnon at:  335 Meriden Road, Waterbury, Connecticut 06705, registered mail no. RB028035058US; and 172 Alexander Avenue, Waterbury, Connecticut 06705, registered mail no. RB028035061US.

                                                              ________/s/_________
                                                              Jesse B. Silverman
                                                              Prosecuting Attorney
 


Administrative Orders and Settlements