On April 1, the Connecticut Department of Banking issued a consent order against a collection agency and two control persons, vacating a February 10 order that had imposed a combined $140,000 in civil penalties for alleged unlicensed consumer collection activity and compliance and consumer protection violations (covered by InfoBytes here). Following the February 10 order, the respondents requested reconsideration under Section 4-181a(b) of the Connecticut General Statutes, which permits an agency to reverse or modify a final decision upon a showing of “changed conditions,” submitting purported evidence of such changed conditions, including communications to employees prohibiting contact with Connecticut consumers following a 2024 consent order and disciplinary action taken against employees who violated that policy.

Pursuant to the new consent order, the respondents are required to cease and desist from the alleged violations, and the collection agency is barred from acting as a consumer collection agency in Connecticut for five years. Additionally, all respondents must notify the department within ten days of any contact with a Connecticut consumer for a period of five years. The new consent order reduces the total civil penalty from $140,000 ($100,000 against the collection agency and $20,000 against each control person) to $50,000, payable jointly and severally by all respondents, along with $400 in back licensing fees. The restitution obligation imposed under the prior order was vacated, as respondents represented that no payments had been collected from Connecticut consumers since a 2024 consent order. The respondents did not admit or deny the allegations.