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”.

Pursuant to the authority granted by Section 36a-17 of the Connecticut General Statutes and Section 36a-498f of the 2010 Supplement to the General Statutes, the Commissioner, through the Consumer Credit Division of the Department of Banking, has investigated the activities of Respondents to determine if they have violated, are violating or are about to violate the provisions of the Connecticut General Statutes within the jurisdiction of the Commissioner.

Section 36a-17(a) of the Connecticut General Statutes provides, in pertinent part, that:

Section 36a-498f(a) of the 2010 Supplement to the General Statutes, provides, in pertinent part, that:

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

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

1.	Nations Funding Source, Inc. (“Nations Funding”) was a Florida corporation with an office at 280 W. Prospect Road, Ft. Lauderdale, Florida.
2.	Nations Funding was licensed as a mortgage lender in Connecticut from February 2007 through September 2, 2010, when it requested surrender of its mortgage lender license on the Nationwide Mortgage Licensing System (“NMLS”), and such surrender request was accepted on the NMLS.
3.	On or about September 10, 2010, Nations Funding filed Articles of Dissolution with the Florida Department of State – Division of Corporations.
4.	Narain is an individual whose most recent mailing address is set forth in the Certification page incorporated herein.
5.	At all times pertinent hereto, Narain was President and 100 percent owner of Nations Funding.
6.	Narain was never registered as an originator in Connecticut and has never been licensed as a mortgage loan originator in Connecticut.
7.	Valerio is an individual whose most recent mailing address is set forth in the Certification page incorporated herein.
8.	Valerio was registered as an originator in Connecticut for a period of time ending in July 2008.  Valerio was not thereafter licensed as a mortgage loan originator in Connecticut.
9.	Czarniewski is an individual whose most recent mailing address is set forth in the Certification page incorporated herein.
10.	Czarniewski was licensed as a mortgage loan originator for the 2009 licensing period, although her license was “inactive” until November 20, 2009.  Czarniewski was licensed as a mortgage loan originator in Connecticut for the 2010 licensing period until November 2, 2010, when she requested surrender of her license on NMLS and such surrender request was accepted.
11.	Page is an individual whose most recent mailing address is set forth in the Certification page incorporated herein.
12.	Page was registered as an originator in Connecticut for a period of time ending in April 2003.  Page was licensed as a mortgage loan originator in Connecticut on September 22, 2010 for the 2010 licensing period.
13.	Hinkle is an individual whose most recent mailing address is set forth in the Certification page incorporated herein.
14.	Hinkle was never registered as an originator in Connecticut and has never been licensed as a mortgage loan originator in Connecticut.
15.	Irabor is an individual whose most recent mailing address is set forth in the Certification page incorporated herein.
16.	Irabor has never been registered as an originator in Connecticut and has never been licensed as a mortgage loan originator in Connecticut.
17.	Karat is an individual whose most recent mailing address is set forth in the Certification page incorporated herein.
18.	Karat was registered as an originator for a period of time ending in April 2005, and was licensed as a mortgage loan originator between December 17, 2008 and December 31, 2009.  Karat presently has an application for a mortgage loan originator license pending.
19.	Narain was identified as the interviewer on an initial Uniform Residential Loan Application on or about December 29, 2008, and again on a subsequent Uniform Residential Loan Application on or about April 16, 2009, both associated with a residential mortgage loan in Connecticut.
20.	Valerio was the actual interviewer of the borrower on behalf of Nations Funding in connection with the Uniform Residential Loan Applications described in paragraph 19 above.
21.	On or about July 22, 2009, Narain was identified as the interviewer on a Uniform Residential Loan Application associated with a residential mortgage loan in Connecticut.
22.	Narain was not the actual interviewer of the borrower on behalf of Nations Funding in connection with the Uniform Residential Loan Application described in paragraph 21 above.
23.	On or about June 4, 2009, Narain was identified as the interviewer on a Uniform Residential Loan Application associated with a residential mortgage loan in Connecticut.
24.	Czarniewski was the actual interviewer of the borrower on behalf of Nations Funding in connection with the Uniform Residential Loan Application described in paragraph 23 above.
25.	On March 18, 2009, Narain was identified as the interviewer on a Uniform Residential Loan Application associated with a residential mortgage loan in Connecticut.
26.	Page was the actual interviewer of the borrower on behalf of Nations Funding in connection with the Uniform Residential Loan Application described in paragraph 25 above.
27.	On each of the occasions described in paragraphs 19 to 26, inclusive, above and 29, 30 and 31 below, the Uniform Residential Loan Applications were presented to, and the loan closed with, third parties who were licensed as mortgage lenders in Connecticut, and commissions were paid to Nations Funding on each such loan.
28.	At all times pertinent hereto, Section 36a-496 of the Connecticut General Statutes prohibits the licensed mortgage lenders described in paragraph 27 from accepting applications or referrals of applicants from any originator who was required to be registered or mortgage loan originator who was required to be licensed but was not, if the mortgage lender has actual knowledge that the originator was not registered or mortgage loan originator was not licensed by the Commissioner.
29.	Hinkle was identified as the interviewer on behalf of Nations Funding on an initial Uniform Residential Loan Application on or about January 8, 2009, and again on a subsequent Uniform Residential Loan Application on or about March 11, 2009, both associated with a single residential mortgage loan in Connecticut.
30.	Irabor was identified as the interviewer on behalf of Nations Funding on Uniform Residential Loan Applications taken on or about February 19, 2009 and March 18, 2009, for residential mortgage loans.
31.	Karat was identified as the interviewer on behalf of Nations Funding on Uniform Residential Loan Applications taken on or about May 21, 2008, September 30, 2008, October 13, 2008, October 17, 2008, and November 4, 2008.

Prior to July 1, 2008, Section 36a-494(b) of the 2008 Supplement to the Connecticut General Statutes, as amended by Public Act 07-91, provided, in pertinent part, that:

On and after July 1, 2008, and until July 30, 2009, Section 36a-494(b) provided, in pertinent part, that:

Effective July 31, 2009, Section 36a-494(b) of the Connecticut General Statutes, as amended by Public Act 09-209, provides, in pertinent part, that:

Prior to July 1, 2008, Section 36a-485(8) of the 2008 Supplement to the General Statutes, as amended by Public Act 07-91, provided, in pertinent part, that:

On and after July 1, 2008, and until July 30, 2009, Section 36a-485(10), as amended by Public Acts 07-156 and 08-176, provided, in pertinent part, that:

Prior to July 1, 2008, Section 36a-486(b) of the 2008 Supplement to the General Statutes provided, in pertinent part, that:

On and after July 1, 2008, Section 36a-486(b), as amended by Public Acts 07-156, 08-176 and 09-208, and until July 30, 2009, provided, in pertinent part:

Prior to July 1, 2008, Section 36a-56 of the Connecticut General Statutes provided, in pertinent part, that:

On and after July 1, 2008, Section 36a-56 of the Connecticut General Statutes, as amended by Public Act 08-176, provides in pertinent part, that:

A.  Violations by Respondent Narain and Respondent Valerio

1.	Paragraphs 1 through 8, inclusive, 19, 20, 27 and 28 of the Matters Asserted, are incorporated and made a part hereof as if more fully set forth herein.
2.	Narain and Valerio misrepresented, concealed, suppressed, intentionally omitted or otherwise intentionally failed to disclose material particulars of mortgage loan transactions to lenders entitled to such information when Narain was identified as the interviewer on Uniform Residential Mortgage Loan Applications, as more fully described in paragraphs 19 and 20 of the Matters Asserted.  Such conduct formed the basis to issue an order to cease and desist and impose a civil penalty pursuant to Section 36a-494(b) of the then applicable Connecticut General Statutes, and presently forms the basis to issue an order to cease and desist pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes, and impose a civil penalty pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes 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 Narain and Valerio individually in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a civil penalty upon Narain and Valerio individually not to exceed Fifteen Thousand Dollars ($15,000) each, subject to Narain and Valerio’s respective rights to a hearing on the allegations set forth above.
3.	As set forth in paragraphs 7, 8, 19, 20, 27 and 28 of the Matters Asserted, Valerio acted as an unlicensed mortgage loan originator, in violation of Section 36a-486(b) of the then applicable Connecticut General Statutes.  Such violation formed the basis to issue an order to cease and desist and impose a civil penalty pursuant to Section 36a-494(b) of the then applicable Connecticut General Statutes, and presently forms the basis to issue an order to cease and desist pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes, and impose a civil penalty pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes 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 Valerio in an amount not to exceed One Hundred Thousand Dollars ($100,000) per violation.  The Commissioner intends to impose a civil penalty upon Valerio not to exceed Fifteen Thousand Dollars ($15,000), subject to Valerio’s right to a hearing on the allegations set forth above.

G.  Additional Violations by Respondent Narain

WHEREAS, the Commissioner has reason to believe that Narain has engaged in acts or conduct which forms a basis to issue an order to cease and desist against Narain pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes and to impose a civil penalty upon Narain pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-50(a) of the Connecticut General Statutes;

WHEREAS, the Commissioner has reason to believe that Valerio has engaged in acts or conduct which forms a basis to issue an order to cease and desist against Valerio pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes and to impose a civil penalty upon Valerio pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-50(a) of the Connecticut General Statutes;

WHEREAS, the Commissioner has reason to believe that Czarniewski has engaged in acts or conduct which forms a basis to issue an order to cease and desist against Czarniewski pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes and to impose a civil penalty upon Czarniewski pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-50(a) of the Connecticut General Statutes;

WHEREAS, the Commissioner has reason to believe that Page has engaged in acts or conduct which forms a basis to issue an order to cease and desist against Page pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes and to impose a civil penalty upon Page pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-50(a) of the Connecticut General Statutes;

WHEREAS, the Commissioner has reason to believe that Hinkle has engaged in acts or conduct which forms a basis to issue an order to cease and desist against Hinkle pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes and to impose a civil penalty upon Hinkle pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-50(a) of the Connecticut General Statutes;

WHEREAS, the Commissioner has reason to believe that Irabor has engaged in acts or conduct which forms a basis to issue an order to cease and desist against Irabor pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes and to impose a civil penalty upon Irabor pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-50(a) of the Connecticut General Statutes;

AND WHEREAS, the Commissioner has reason to believe that Karat has engaged in acts or conduct which forms a basis to issue an order to cease and desist against Karat pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-52(a) of the Connecticut General Statutes and to impose a civil penalty upon Karat pursuant to Section 36a-494(b) of the 2010 Supplement to the General Statutes and Section 36a-50(a) of the Connecticut General Statutes.

NOW THEREFORE, notice is hereby given to Respondents that the Commissioner intends to issue an order requiring:

1.	Narain to CEASE AND DESIST from violating Sections 36a-494(b) and 36a-56 of the applicable Connecticut General Statutes, and imposing a CIVIL PENALTY upon Narain as set forth herein, subject to Narain’s right to a hearing on the allegations set forth above;
2.	Valerio to CEASE AND DESIST from violating Sections 36a-494(b) and 36a-486(b) of the applicable Connecticut General Statutes, and imposing a CIVIL PENALTY upon Valerio as set forth herein, subject to Valerio’s right to a hearing on the allegations set forth above;
3.	Czarniewski to CEASE AND DESIST from violating Sections 36a-494(b) and 36a-486(b) of the applicable Connecticut General Statutes, and imposing a CIVIL PENALTY upon Czarniewski as set forth herein, subject to Czarniewski’s right to a hearing on the allegations set forth above;
4.	Page to CEASE AND DESIST from violating Section 36a-494(b) and 36a-486(b) of the applicable Connecticut General Statutes, and imposing a CIVIL PENALTY upon Page as set forth herein, subject to Page’s right to a hearing on the allegations set forth above;
5.	Hinkle to CEASE AND DESIST from violating Section 36a-486(b) of the applicable Connecticut General Statutes and imposing a CIVIL PENALTY upon Hinkle as set forth herein, subject to Hinkle’s right to a hearing on the allegations set forth above;
6.	Irabor to CEASE AND DESIST from violating Section 36a-486(b) of the applicable Connecticut General Statutes, and imposing a CIVIL PENALTY upon Irabor as set forth herein, subject to Irabor’s right to a hearing on the allegations set forth above; and
7.	Karat to CEASE AND DESIST from violating Section 36a-486(b) of the applicable Connecticut General Statutes, and imposing a CIVIL PENALTY upon Karat as set forth herein, subject to Karat’s 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, Consumer Credit Division, 260 Constitution Plaza, Hartford, Connecticut 06103-1800 within fourteen (14) days following each Respondent’s receipt of this 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 Sections 36a-52(a) and 36a-50(a) of the Connecticut General Statutes.  This 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 any 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 presiding 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 23, 2011, 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 Respondents fail to appear at the requested hearing.  At such hearing, Respondents 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 Narain does not request a hearing within the time prescribed, the Commissioner will issue an order that Narain cease and desist from violating Section 36a-494(b) and 36a-56 of the applicable Connecticut General Statutes, and may order a civil penalty not to exceed Ninety-five Thousand Dollars ($95,000) be imposed upon Narain.

If Valerio does not request a hearing within the time prescribed, the Commissioner will issue an order that Valerio cease and desist from violating Sections 36a-494(b) and 36a-486(b) of the applicable Connecticut General Statutes, and may order a civil penalty not to exceed Thirty Thousand Dollars ($30,000) be imposed upon Valerio.

If Czarniewski does not request a hearing within the time prescribed, the Commissioner will issue an order that Czarniewski cease and desist from violating Sections 36a-494(b) and 36a-486(b) of the applicable Connecticut General Statutes, and may order a civil penalty not to exceed Thirty Thousand Dollars ($30,000) be imposed upon Czarniewski.

If Page does not request a hearing within the time prescribed, the Commissioner will issue an order that Page cease and desist from violating Sections 36a-494(b) and 36a-486(b) of the applicable Connecticut General Statutes, and may order a civil penalty not to exceed Thirty Thousand Dollars ($30,000) be imposed upon Page.

If Hinkle does not request a hearing within the time prescribed, the Commissioner will issue an order that Hinkle cease and desist from violating Section 36a-486(b) of the applicable Connecticut General Statutes, and may order a civil penalty not to exceed Fifteen Thousand Dollars ($15,000) be imposed upon Hinkle.

If Irabor does not request a hearing within the time prescribed, the Commissioner will issue an order that Irabor cease and desist from violating Section 36a-486(b) of the applicable Connecticut General Statutes, and may order a civil penalty not to exceed Fifteen Thousand Dollars ($15,000) be imposed upon Irabor.

If Karat does not request a hearing within the time prescribed, the Commissioner will issue an order that Karat cease and desist from violating Section 36a-486(b) of the applicable Connecticut General Statutes, and may order a civil penalty not to exceed Fifteen Thousand Dollars ($15,000) be imposed upon Karat.

So ordered at Hartford, Connecticut
this 19th day of January 2011.                 ________/s/_________
                                                          Howard F. Pitkin
                                                          Banking Commissioner

---