DOB: Envios R.D. Corp. d/b/a Pronto Envios, Temporary Order to Cease and Desist, Notice of Intent to Revoke Money Transmission License, Issue Order to Cease and Desist, Impose Civil Penalty

* * * * * * * * * * * * * * * * * *

IN THE MATTER OF:

ENVIOS R.D. CORP.
d/b/a PRONTO ENVIOS

    ("Respondent")

 
 



* * * * * * * * * * * * * * * * * *

*
*
*
*
*
*
*
*
*
*
*
*
*
*
*

TEMPORARY ORDER TO
CEASE AND DESIST

NOTICE OF INTENT TO REVOKE
MONEY TRANSMISSION
 LICENSE

NOTICE OF INTENT TO ISSUE
ORDER TO CEASE AND DESIST

NOTIE 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 V of Chapter 668, Sections 36a-595 to 36a-610, inclusive, of the Connecticut General Statutes, “Money Transmission Act”.
 
Pursuant to the authority granted by Section 36a-608(a) of the Connecticut General Statutes, as amended by Public Act 09-208, and Section 36a-17(a) 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 within the jurisdiction of the Commissioner.
 
Section 36a-608(a) of the Connecticut General Statutes, as amended, provides:
The commissioner shall make such investigations . . . as the commissioner considers necessary to determine whether any licensee or any other person has violated or is about to violate any of the provisions of sections 36a-595 to 36a-610, inclusive, or whether any licensee has acted in such manner as otherwise would justify the . . . revocation of the license.  The provisions of section 36a-17 shall apply to such investigation.
Section 36a-17(a) of the Connecticut General Statutes provides:
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.
Subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes provides, in pertinent part:
(a)  The commissioner may . . . revoke . . . any license issued by the commissioner under any provision of the general statutes by sending a notice to the licensee 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 licensee 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, regulations, rules or orders involved; (4) a short and plain statement of the matters asserted; and (5) a statement indicating that the licensee may file a written request for a hearing on the matters asserted within fourteen days of receipt of the notice. . . .
(b)  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 licensee fails to appear at the hearing.  After the hearing, the commissioner shall . . . revoke . . . the license for any reason set forth in the applicable licensing provisions of the general statutes if the commissioner finds sufficient grounds exist for such . . . revocation . . . .  If the licensee does not request a hearing within the time specified in the notice or fails to appear at the hearing, the commissioner shall . . . revoke . . . the license.  No such license shall be . . . revoked except in accordance with the provisions of chapter 54.
Section 36a-52 of the Connecticut General Statutes provides, in pertinent part:
(a)  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, . . . 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 . . . 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.
(b)  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:
(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, . . . 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 . . . 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, . . . 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.


II.  MATTERS ASSERTED
1.
Respondent is a New York corporation with an office at 2 Bennett Avenue, 3rd Floor, New York, New York.
2.
Pursuant to Section 36a-600 of the Connecticut General Statutes, as amended by Public Act 09-208, Respondent currently maintains a license (no. 13953) to engage in the business of money transmission in Connecticut.
3.
On March 6, 2006, the State of California, Department of Financial Institutions, issued a Cease and Desist Order, pursuant to Financial Code Section 1818 (“Cease and Desist Order”), against Respondent.
4.
On June 7, 2006, Respondent filed a Renewal Application for a Money Transmitters or Issuer of Connecticut Payment Instruments License (“2006 Renewal Application”).  In response to question 12(b) on the 2006 Renewal Application which asked, in pertinent part, “[h]as the Applicant or any of its agents, subagents, employees, principal officers, members or similar persons whether independent contractors or not and any shareholder owning ten per cent or more of each class of its securities . . . (b)  ever been the subject of actions (cease and desist order, consent orders, injunctions, license suspensions or revocations, etc.) by any regulatory agency?”, Respondent answered “No”.
5. On May 23, 2007, Respondent filed a Renewal Application for a Money Transmitters or Issuer of Connecticut Payment Instruments License (“2007 Renewal Application”).  In response to question 12(b) on the 2007 Renewal Application which asked, in pertinent part, “[h]as the applicant, control person (member, partner, trustee, officer, director, or individual with a similar status or function) or owner of 10% or more of capital . . . (b)  ever been the subject of actions (cease and desist orders, consent orders, injunctions, license suspensions or revocations, etc.) by any regulatory agency?”, Respondent answered “No”.
6.
On June 6, 2007, Respondent entered into a Consent Agreement with the State of New Hampshire, Department of Banking (Case No. 07-067) (“Consent Agreement”), existence of which Respondent failed to promptly notify the Commissioner.
7.
On August 28, 2009, Respondent filed a Renewal of Money Transmitter or Issuer of Connecticut Payment Instruments License (“2009 Renewal Application”).  In response to question 8(e) on the 2009 Renewal Application which asked, in pertinent part, “[h]as the applicant or . . . any officer, director, trustee, principal employee, or shareholder owning ten percent or more of outstanding stock of the applicant (if the applicant is a corporation) . . . (e) ever been the subject of actions (cease and desist orders, consent orders, injunctions, license suspensions or revocations, etc.) by any regulatory agency, state of federal?”, Respondent answered “Yes”.
8. As part of Question 8 on the 2009 Renewal Application, applicants were instructed that “[i]f the answer to any of the above questions is “YES”, [applicant is instructed to] provide complete details of all events or proceedings in an attachment”.  Respondent enclosed a copy of the Consent Agreement, but did not provide a copy of the Cease and Desist Order.
9.
During the period from November 11, 2009 to December 23, 2009, Respondent received money or monetary value from a number of Connecticut based agents on behalf of purchasers for future transmission.
10. Respondent failed to transmit money or monetary value or failed to return money or monetary value for reimbursement to the purchasers.
11. On January 8, 2010, pursuant to Section 4-182(c) of the Connecticut General Statutes, the Division sent a letter to Respondent giving Respondent an opportunity to show compliance with all lawful requirements for retention of its license to engage in the business of money transmission in Connecticut.
12.
On January 12, 2010, Respondent replied to the January 8, 2010, letter, but did not fully provide the requested information.  The Commissioner was not persuaded that Respondent showed any such compliance.
 
 
III.  STATUTORY BASIS FOR REVOCATION OF LICENSE TO
ENGAGE IN THE BUSINESS OF MONEY TRANSMISSION, ORDER TO
CEASE AND DESIST AND IMPOSITION OF CIVIL PENALTY
 
Section 36a-598(b) of the Connecticut General Statutes, as amended by Public Act 09-208, provides, in pertinent part:
An applicant or licensee shall promptly notify the commissioner, in writing, of any change in the information provided in the application for license or most recent renewal of such license.
Section 36a-600 of the Connecticut General Statutes, as amended, provides, in pertinent part:
(a) Upon the filing of an application for an original license, and the payment of the fees for investigation and license, the commissioner shall investigate the financial condition and responsibility, financial and business experience, character and general fitness of the applicant.  The commissioner shall approve conditionally any application, if the commissioner finds that: . . .
(2) The applicant’s business will be conducted honestly, fairly, equitably, carefully and efficiently within the purposes and intent of sections 36a-595 to 36a-610, inclusive, and in a manner commanding the confidence and trust of the community . . . .
(5) No person on behalf of the applicant knowingly has made any incorrect statement of a material fact in the application, or in any report or statement made pursuant to sections 36a-595 to 36a-610, inclusive; and
(6) No person on behalf of the applicant knowingly has omitted to state any material fact necessary to give the commissioner any information lawfully required by the commissioner.
(b) . . . The commissioner shall not issue a license to any applicant unless the applicant is in compliance with all the requirements of subsection (a) of this section . . . .
Section 36a-608(b) of the Connecticut General Statutes, as amended by Public Act 09-208, provides, in pertinent part:
The commissioner may . . . revoke a license or take any other action, in accordance with section 36a-51, on any ground on which the commissioner might refuse to issue an original license, [or] . . . for engaging in an unsafe and unsound practice.
Section 36a-608(c) of the Connecticut General Statutes, as amended by Public Act 09-208, provides, in pertinent part:
Whenever it appears to the commissioner that any person has violated, is violating or is about to violate any provision of sections 36a-595 to 36a-610, inclusive, . . . or engaged in an unsafe and unsound practice, the commissioner may take action against such person in accordance with sections 36a-50 and 36a-52.
Section 36a-596(16) of the Connecticut General Statutes, as amended by Public Act 09-208, defines “unsafe or unsound practice” to mean, in pertinent part:
[A] practice or conduct by a licensee . . . that is likely to . . . otherwise materially prejudice the interests of purchasers.
Section 36a-596(13) of the Connecticut General Statutes, as amended by Public Act 09-208, defines “purchaser” to mean, in pertinent part:
[A] person . . . who has given money or monetary value for current or future transmission.
1.
Respondent’s failure to transmit money or monetary value received from purchasers or to return such money or monetary value to purchasers, as more fully described in paragraphs 9 and 10 of the Matters Asserted, constitutes conduct that is likely to otherwise materially prejudice the interests of purchasers, which conduct constitutes an unsafe or unsound practice, within the meaning of Section 36a-596(16) of the Connecticut General Statutes, as amended.  Such conduct constitutes grounds for the Commissioner to revoke Respondent’s license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) of the Connecticut General Statutes, as amended, and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes, and forms the basis to issue an order to cease and desist pursuant to Section 36a-608(c) of the Connecticut General Statutes, as amended, and Section 36a-52(a) of the Connecticut General Statutes and impose a civil penalty pursuant to Section 36a-608(c) of the Connecticut General Statutes, as amended, and 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 Respondent in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a civil penalty upon Respondent not to exceed One Hundred Thousand Dollars ($100,000), subject to Respondent’s right to a hearing on the allegations set forth above.
2.
Respondent’s failure to transmit money or monetary value received from purchasers or to return such money or monetary value to purchasers, as more fully described in paragraphs 9 and 10 of the Matters Asserted, fails to demonstrate that Respondent’s business will be conducted honestly, fairly, equitably, carefully and efficiently within the purposes and intent of Sections 36a-595 to 36a-610, inclusive, and in a manner commanding the confidence and trust of the community.  Such conduct constitutes grounds for the Commissioner to revoke Respondent’s license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) of the Connecticut General Statutes, as amended, and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes.
3.
Respondent’s “no” responses to Question 12(b) on the 2006 Renewal Application and 2007 Renewal Application in light of the Cease and Desist Order, as more fully described in paragraphs 3 through 5, inclusive, of the Matters Asserted, constitute Respondent knowingly making an incorrect statement of a material fact in an application made pursuant to Sections 36a-595 to 36a-610, inclusive, of the Connecticut General Statutes or Respondent knowingly omitting to state a material fact necessary to give the Commissioner any information lawfully required by the Commissioner, which constitutes sufficient grounds for the Commissioner to refuse to issue a license to engage in the business of money transmission in Connecticut, which constitutes grounds for the Commissioner to revoke Respondent’s license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) of the Connecticut General Statutes, as amended, and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes.
4.
Respondent’s failure to promptly notify the commissioner, in writing, of the Cease and Desist Order and Consent Agreement, as more fully described in paragraphs 3 through 8, inclusive, of the Matters Asserted, constitutes a failure to promptly notify the Commissioner, in writing, of any change in the information provided in the application for the most recent renewal of such license, in violation of Section 36a-598(b) of the Connecticut General Statutes, as amended.  Such violation constitutes grounds to revoke Respondent’s license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) of the Connecticut General Statutes, as amended, and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes, and forms the basis to issue an order to cease and desist pursuant to Section 36a-608(c) of the Connecticut General Statutes, as amended, and Section 36a-52(a) of the Connecticut General Statutes and impose a civil penalty pursuant to Section 36a-608(c) of the Connecticut General Statutes, as amended, and 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 Respondent in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a civil penalty upon Respondent not to exceed Ten Thousand Dollars ($10,000), subject to Respondent’s right to a hearing on the allegations set forth above.

 
IV.  FINDING AND STATUTORY BASIS FOR
TEMPORARY ORDER TO CEASE AND DESIST
 
The Commissioner finds that public welfare requires immediate action to issue a temporary order requiring Respondent to cease and desist from engaging in an unsafe or unsound practice pursuant to Section 36a-52(b) of the Connecticut General Statutes, in that the interests of purchasers are being materially prejudiced by Respondent’s failure to transmit money or monetary value received from purchasers or to return such money or monetary value to purchasers, and that the interests of additional purchasers also may be materially prejudiced.

 
V.  TEMPORARY ORDER TO CEASE AND DESIST, NOTICE OF INTENT
TO REVOKE LICENSE TO ENGAGE IN THE BUSINESS OF MONEY
TRANSMISSION, 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 Respondent has engaged in conduct which constitutes sufficient grounds for the Commissioner to revoke Respondent’s license to engage in the business of money transmission in Connecticut pursuant to Section 36a-608(b) of the Connecticut General Statutes, as amended, and subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes, and forms the basis to issue an order to cease and desist pursuant to Section 36a-608(c) of the Connecticut General Statutes, as amended, and Section 36a-52(a) of the Connecticut General Statutes and impose a civil penalty pursuant to Section 36a-608(c) of the Connecticut General Statutes, as amended, and Section 36a-50(a) of the Connecticut General Statutes.
 
THE COMMISSIONER THEREFORE ORDERS, pursuant to the authority granted in Section 36a-52(b) of the Connecticut General Statutes, that Envios R.D. Corp. d/b/a Pronto Envios immediately CEASE AND DESIST from engaging in an unsafe or unsound practice.  This Temporary Order shall become effective upon receipt by Envios R.D. Corp. d/b/a Pronto Envios 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 Temporary Order.
 
THE COMMISSIONER FURTHER ORDERS, pursuant to Section 36a-52(b) of the Connecticut General Statutes, that:

1.
Upon the effective date of this Temporary Order, Respondent, and any and all officers, directors, trustees, principal employees, shareholders and agents owning ten percent or more of outstanding stock of the applicant, shall immediately cease and desist from accepting money or monetary value for future transmission until the Commissioner has been satisfied that Respondent’s operational issues have been resolved.
2.
Respondent submit to Alan J. Cicchetti, Deputy Commissioner, by e-mail at alan.cicchetti@ct.gov, as soon as possible, but not later than fifteen (15) days after the effective date of this Temporary Order, a detailed report of each agent’s accounting of the number and amount of all transactions affected by Respondent suspending service, including but not limited to, transactions that were cancelled, reissued through another licensed money transmitter or remain unresolved as a result of Respondent suspending service.
3.
Respondent submit to Alan J. Cicchetti, Deputy Commissioner, by e-mail at alan.cicchetti@ct.gov, as soon as possible, but not later than fifteen (15) days after the effective date of this Temporary Order, a detailed report of each agent’s accounting of any damages caused to any purchaser or any intended recipient of monies or monetary value received for transmission as a result of Respondent suspending service, including but not limited to, any late charges incurred or penalties imposed on accounts.
4.
Respondent submit to Alan J. Cicchetti, Deputy Commissioner, by e-mail at alan.cicchetti@ct.gov, as soon as possible, but not later than fifteen (15) days after the effective date of this Temporary Order, a detailed report of each agent’s accounting of any monetary damages that an agent or correspondent agent may have incurred as a result of Respondent suspending service.
5. Upon the effective date of this Temporary Order, Respondent shall not pay or declare any dividend, salary or bonus, nor otherwise authorize any other material distribution of Respondent’s assets to any officer, director or owner of Respondent without the prior written approval of the Commissioner.  Respondent shall implement or revise its practices and procedures, as necessary, to ensure that Respondent’s financial books and records are accurately maintained, in a manner illustrating compliance with the provisions of this paragraph, and available for review by the Division’s examiners upon request.
 
FURTHER, notice is hereby given to Respondent that the Commissioner intends to REVOKE Respondent’s license to engage in the business of money transmission in Connecticut, issue an order requiring Respondent to CEASE AND DESIST from engaging in an unsafe or unsound practice and failing to promptly notify the Commissioner, in writing, of any change in the information provided in the application for the most recent renewal of such license, and impose a CIVIL PENALTY upon Respondent as set forth herein, subject to Respondent’s right to a hearing on the allegations set forth above.
 
A hearing will be granted to Respondent if a written request for a hearing is received by the Department of Banking, Consumer Credit Division, 260 Constitution Plaza, Hartford, Connecticut 06103-1800 within fourteen (14) days following its receipt of this Temporary Order to Cease and Desist, Notice of Intent to Revoke 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 as set forth in subsections (a) and (b) of Section 36a-51 of the Connecticut General Statutes and Section 36a-52(a) and 36a-50(a) of the Connecticut General Statutes.  This Temporary Order to Cease and Desist, Notice of Intent to Revoke 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 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 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 March 4, 2010, at 10 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 Respondent fails to appear at the requested hearing.  At such hearing, 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 Respondent does not request a hearing within the time prescribed, the Commissioner will issue an order revoking Respondent’s license to engage in the business of money transmission in Connecticut, issue an order that Respondent cease and desist from engaging in an unsafe or unsound practice, and may order a civil penalty in an amount not to exceed One Hundred Ten Thousand Dollars ($110,000) be imposed upon Respondent.
 
 
So ordered at Hartford, Connecticut
this 15th day of January 2010.      
                                                    ________/s/_________
                                                    Howard F. Pitkin
                                                    Banking Commissioner
 
 
 
CERTIFICATION
 
I hereby certify that on this 15th day of January 2010, the foregoing Temporary Order to Cease and Desist, Notice of Intent to Revoke 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 was sent by registered mail, return receipt requested to Rodger Zepka, President, Envios R.D. Corp. d/b/a Pronto Envios, 2 Bennett Avenue, 3rd Floor, New York, New York 10033, registered mail no. RB028036901US; and via facsimile to 212-928-2332.
 
 
                                                   ________/s/_________
                                                   Doniel Kitt
                                                   Prosecuting Attorney
 

Administrative Orders and Settlements