WHEREAS, the Banking Commissioner (“Commissioner”) is charged with the administration of Part I of Chapter 668, Sections 36a-485 to 36a-534c, inclusive, of the Connecticut General Statutes, “Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators”;

WHEREAS, Integrity is a Connecticut limited liability company that is currently licensed as a mortgage broker under Part I of Chapter 668, Sections 36a-485 et seq., of the Connecticut General Statutes;

WHEREAS, the Commissioner, through the Consumer Credit Division of the Department of Banking (“Department”), pursuant to the authority granted by Section 36a-17(a) of the 2012 Supplement to the General Statutes, as amended by Public Act 12-96, and Section 36a-498f of the Connecticut General Statutes, investigated the activities of Integrity to determine if it had violated, was violating, or was about to violate the provisions of the Connecticut General Statutes within the jurisdiction of the Commissioner;

WHEREAS, On October 26, 2012, as a result of the investigation, the Commissioner, acting pursuant to Sections 36a-494(b) of the 2012 Supplement to the General Statutes, as amended by Public Act 12-96, Section 36a-52(a) of the Connecticut General Statutes and Section 36a-50(a) of the Connecticut General Statutes, as amended by Public Act 12-96, issued a Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing (“Notice”) against Integrity, which Notice is incorporated herein by reference;

WHEREAS, the Commissioner alleged in the Notice that Integrity failed to file its fourth quarter mortgage call report for 2011 that was due on February 14, 2012, its financial condition report for 2011 that was due on March 30, 2012, its first quarter mortgage call report that was due on May 15, 2012, and its second quarter mortgage call report that was due on August 14, 2012, all in violation of Section 36a-534b(c)(3) of the 2102 Supplement to the General Statutes and/or Section 36a-534b(c)(3) of the 2012 Supplement to the General Statutes, as amended by Public Act 12-96, which such violations form the basis to issue an order to cease and desist pursuant to Section 36a-494(b) of the 2012 Supplement to the General Statutes, as amended, and Section 36a-52(a) of the Connecticut General Statutes, and to impose a civil penalty pursuant to Section 36a-494(b) of the 2012 Supplement to the General Statutes, as amended, and Section 36a-50(a) of the Connecticut General Statutes, as amended;

WHEREAS, on October 31, 2012, the Notice was sent by certified mail, return receipt requested, to Integrity (Certified Mail No. 70112000000247315966);

WHEREAS, on November 2, 2012, Integrity received the Notice;

WHEREAS, on November 2, 2012, Beth Goodfriend, sole owner and Vice President of Integrity (“Goodfriend”) contacted the Department regarding possible resolution of these matters;

WHEREAS, Section 4-177(c) of the Connecticut General Statutes and Section 36a-1-55(a) of the Regulations of Connecticut State Agencies provide that a contested case may be resolved by consent order, unless precluded by law;

WHEREAS, the Commissioner and Integrity now desire to resolve the matters alleged in the Notice; 

WHEREAS, the Notice contained two scrivener errors in the first paragraph of the Statutory Basis for Order to Cease and Desist and Imposition of Civil Penalty.  There was a typographical error in the first line, and the quoted statutory provision was not accurate.  Rather than amend the Notice at this juncture, corrected language is provided herein and expressly incorporated into the Notice by reference;

Section 36a-534b(c)(3) of the 2012 Supplement to the General Statutes, in effect prior to October 1, 2012, provided, in pertinent part, that:

WHEREAS, Goodfriend represents that she was the sole Connecticut licensed mortgage loan originator at Integrity and that she believed her mortgage loan originator license had expired or had not been renewed at the end of 2011 due to an issue that was under investigation by the Department concerning her ability to satisfy certain minimum qualifications for continued licensure;

WHEREAS, Goodfriend represents that she has not engaged in the business of a mortgage loan originator in Connecticut since January 1, 2012;

WHEREAS, Integrity represents that it has not engaged in the business of a mortgage broker in Connecticut since January 1, 2012;

WHEREAS, Integrity admits that it had not filed the reports described in the Notice, and Integrity and Goodfriend acknowledge that this Consent Order is a public record and is a reportable event for purposes of the regulatory disclosure questions on the Nationwide Mortgage Licensing System and Registry (“NMLS”), as applicable;

WHEREAS, Integrity voluntarily agrees to consent to the entry of the sanction described below, solely for the purpose of obviating the need for further formal administrative proceedings concerning the allegations contained in the Notice and set forth herein;

WHEREAS, Integrity agrees that the Notice may be used in construing the terms of this Consent Order and agrees to the language of this Consent Order;

AND WHEREAS, Integrity and Goodfriend, through execution of this Consent Order, voluntarily agree to waive any applicable procedural rights, including Integrity’s right to a hearing as it pertains to the allegations contained in the Notice and set forth herein, and voluntarily waive any right to seek judicial review or otherwise challenge or contest the validity of this Consent Order.

CONSENT TO ENTRY OF SANCTION

WHEREAS, Integrity through its execution of this Consent Order, consents to the Commissioner’s entry of a Consent Order imposing the following sanction:

CONSENT ORDER

NOW THEREFORE, the Commissioner enters the following:

Issued at Hartford, Connecticut
this 20th day of November 2012.        ________/s/_________
                                                     Howard F. Pitkin
                                                     Banking Commissioner

CONSENT TO ENTRY OF ORDER

I, Beth Goodfriend, state on behalf of Integrity Financial Group, LLC, that I have read the foregoing Consent Order; that I know and fully understand its contents; that I am authorized to execute this Consent Order on behalf of Integrity Financial Group, LLC; that Integrity Financial Group, LLC agrees freely and without threat or coercion of any kind to comply with the sanction entered and terms and conditions ordered herein; and that Integrity Financial Group, LLC  voluntarily agrees to enter into this Consent Order, expressly waiving the procedural rights set forth herein as to the matters described herein.                                           

                                            By:   ________/s/_________
                                                   Name:  Beth Goodfriend                      
                                                   Title:  Owner & Vice President          
                                                   Integrity Financial Group, LLC,

State of:  Connecticut

County of:  Hartford

On this the 16 day of November 2012, before me, Lisa A. Burnat, the undersigned officer, personally appeared Beth Goodfriend, who acknowledged herself to be the sole owner and Vice President of Integrity Financial Group, LLC, a limited liability company, and that she as such sole owner and Vice President, being authorized so to do, executed the foregoing instrument for the purposes therein contained, by signing the name of the limited liability company by herself as sole owner and Vice President.

In witness whereof I hereunto set my hand.

                                                   ________/s/_________
                                                   Notary Public  Lisa A. Burnat                                         
                                                   Date Commission Expires:  Apr. 30, 2016

I, Beth Goodfriend, state that I have read the foregoing Consent Order; that I know and fully understand its contents; that I agree freely and without threat or coercion of any kind to comply with the sanction entered and terms and conditions ordered herein; and that I voluntarily agree to enter into this Consent Order, expressly waiving the procedural rights set forth herein as to the matters described herein.

                                                    ________/s/_________
                                                    Beth Goodfriend

State of:  Connecticut

County of:  Hartford

On this the 16 day of November 2012, before me, Lisa A. Burnat, the undersigned officer, personally appeared Beth Goodfriend, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained.

In witness whereof I hereunto set my hand.


                                                    _________/s/_________
                                                    Notary Public  Lisa A. Burnat
                                                    Date Commission Expires:  Apr. 30, 2016

Administrative Orders and Settlements