Connecticut Orders Set Forth LLC to Cease Unlicensed Debt Adjustment

• * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * ORDER TO MAKE RESTITUTION IN THE MATTER OF: NOTICE OF INTEN T TO ISSUE SET FORTH, LLC a/k/a FORTH, INC. d/b/a FORTH f/k/a SET FORTH, INC. f/k/a DEBT PAY GATE WAY, INC. O RDER TO CEASE AND DESIST NOTICE OF INTEN T TO IMPOS E CIVIL PENALTY NMLS # 139 6653 AND (“ F orth” or “ Respondent ”) NOTICE OF RIGHT T O HEARING I. LEGAL AUTHORIT Y AND JURISDIC TION 1. The Banking C ommissioner (“ Commissione r”) is charged w ith the adm inistration of Par t V of Chapter 668, Sections 36a - 595 t o 36a - 61 4, inclusive, of th e Connecticut Genera l Statutes, known as the “Money Transmis sion Act”, as amen ded, and Pa rt II of Chapter 669, Section s 36a - 655 to 36a - 665, inclusive, of the Connecticut Gen eral Statutes, “Debt Adjusters and Deb t Negotiation”, as amended. 2. Pursuant to the authority gra nted by Sec tions 36a - 17 and 36a - 608(a) of the Connecticut Gener al Statutes, the Commissione r, through the Consumer Credi t Division of t he Departme nt of Banking (“Department ”), has investigated the activities of Respondent to det ermine if it has violated, is violating or is about t o violate the pr ovisions of t he Connecti cut General Statutes withi n the jurisdic tion of the Commissione r (“Investiga tion”). 3. As a result of th e Investigation, the Co mmissioner has reaso n to believe th at Respondent has violate d Sections 36a - 597(a), 36a - 607(c)(2) and 3 6a - 656(a) of the Con necticut General St atutes. 4. As a result of th e Investigation, the conduct alleged b y the Commissioner for ms a basis to issue an order to ma ke restituti on against Responde nt pursuan t to Sec tions 36a - 608(c)(1), 36a - 657(b) and

36a - 50(c) of the Connecticut General Statutes, to cease an d desist again st Respondent pu rsuant to Section s 36a - 608(c)(1), 36a - 657(b) and 36a - 52(a) of the Connecticu t General Statutes, and to impose a civil penalty upon Res pondent pursuant to Sections 36a - 608(c)(1), 36a - 657(b) a nd 36a - 50(a) of t he Connecticut Gen eral Statutes. II. MATTERS ASSERT ED 5. Respondent is a Delaware limited liability company with an office at 150 N M artingale Rd, Su ite 1200, Schaum burg, I llinois. Respondent has been licensed as a money tran smitter in Pennsyl vania since May 19, 201 6. 6. On May 1 2, 2016, the Commonw ealth of Pennsyl vania Depar tment of Banking and S ecuritie s, Compliance Office entered into a Consent Agreemen t and Order with Respo ndent concernin g allegation s of unlicense d money transm ission in Pennsyl vania and pai d a fine of $52, 500. The order alleged that Respondent ac ted as a money t ransmitte r in Pennsylvania, including, but not limit ed to, by taki ng bank account, AC H or credit c ard informatio n from consum ers to faci litate the movem ent of funds fr om consumers to deb t settlement services co mpanies. 7. On September 29, 20 22, the State of Oregon Dep artment of Consu mer and Business Serv ices Division of Fin ancial Regulatio n issued an Order to Cease and Desist, Ord er Assessing Civ il Penalty, and Consent to E ntry of Order (“ 2022 Oregon Orde r ”) against Respond ent concerni ng allegations of unlicensed m oney transmi ssion in Orego n. The 2022 Oregon Order alleged that Respondent facilitated th e transmis sion of consume r funds to unre gistered debt m anagement 1 companies a nd ordered Respondent t o pay b ack $117,84 3. 43 o f fees collected fr om Oregon consum ers while engaged i n 1 Accordi ng to Ore gon Revis ed Statut es § 69 7.602, “d e bt m anageme nt service” is defined as “a n activit y for whic h a per son recei ves mone y or othe r valuabl e consi deration or expe cts to rec eive mo ney or ot her valua ble considera tion in ret urn for: (a) Receiving or offer ing to receive funds fr om a consumer for th e purpose of distrib uting the funds am ong the c onsumer ’s credit ors in f ull or pa rtial pa yment of the co nsumer’s debts, w hether or not the person hol ds the c onsumer’s funds; (b) Improving or offeri ng to im prove or preserve a consume r’s cre dit record, credi t histor y o r credi t rating; (c) Modif ying or o ffering t o modif y terms a nd condit ions of a n existi ng loan from or obli gation to a t hird part y; or (d) Obtainin g o r attemptin g t o obtai n a s a n intermediar y o n a consumer’ s behalf a c onces sion from a credi tor inclu ding, but not limi ted to, a reducti on in t he princi pal, inte rest, pe nalties or f ees associat ed wit h a debt. ”

unlicen sed money transmission a nd a civil pe nalty of $75,0 00, of which $70, 000 was suspe nded pending compliance with the terms of the 2022 Oregon O rder. 8. On December 2 8, 2023, the State of Oregon Department o f Consumer and Bu siness Services Division of Fin ancial Regulatio n issued an Order to Cease and Desist, Ord er Assessing Civ il Penalty, Order Reinstating Civil Penalty and Consent to Entry of Order (“2023 Oregon Orde r”) again st Respondent conc erning alle gations of conti nued unlice nsed money transm ission in Oregon a fter the 2022 Orego n Order. The 2023 Oregon Or der required R espondent to pa y back $20,913. 53 in fees c ollected from Oregon c onsumers while engaged in unli censed mone y transmis sion and levi ed a civil penalty of $40,000, of w hich $10,000 w as suspended pendi ng complia nce with the te rms of the 2023 O regon O rder. 9. On July 22, 2024, this Department receiv ed a whistleblo wer complaint agains t Respondent asserting, inter alia, that it engages in u nlicensed money tran smission in Connecticut, poses risk s to consumers through unfair, deceptive, or abusive acts and practices in contraventi on of the Dod d - Frank Wall Stree t Reform and Cons umer Protec tion Act of 2010 and operates an alle ged unlawful kickba ck scheme with deb t settlement compan ies by offering f ree (or subst antially disc ounted) Custom er Relationship M anagement (“CRM”) software to tho se debt settlemen t companies in return for exc lusively referring consu mers to Responde nt for unlicensed money transmiss ion and escrow servi ce s. a. Unlicensed Deb t Adjuster Activi ty 10. On January 6, 2016, t h e Department issu ed a memorandum advi sing that persons engaged in activities that meet the definition of both “ debt a djustment ” a nd “ money tran smission ” will be required t o obtain both of the resp ective licenses in Connectic ut effective Mar ch 1, 20 16, unless exempt from licensur e and that debt adjuster licen sure will not be required of thi rd - party p ayment processors l icensed as money trans mitters i n Connecticut tha t transmit funds solely in s upport of other entities duly l icensed to provide de bt adjustme nt or debt negot iation servic es in Connecti cut or exem pt from such lic ensure requirement s.

1. Section 36a - 655(5) of the Conn ecticut General Statu es defines “deb t adjustment” as “ for or with the expectat ion of a fee, commi ssion or other v aluable consider ation, receivin g, as agent of a debto r, money or evi dences there of for the purpos e of distrib uting such mone y or evidence s thereof among creditors i n full or partia l payment of o bligations of the debtor. ” 12. Fro m at least January 2022 thro ugh the present, Resp ondent acted as a third - party payment processor that p rocessed paymen ts for consumers enr olled in d ebt negotiatio n programs and specialized in providing d edicated accounts that allowed suc h consumer s to save funds to pa y down their de bts. In Connecticut, during such ti me period, Re spondent rece ived over $ 7 22,000 in fees in connection with the receipt and distribut ion of funds among c reditors to pa y outstanding debts on beh alf of thousan ds of Connect ic ut consumers e nrolled in debt negot iat i on progra ms. 13. Respondent is not curre ntly and has ne ver been lice nsed to engage in t he business of debt adjustment in this state, nor does Re spondent qualif y for an exemption fr om su ch licensur e. b. Unlicensed Mo ney Transmission Act ivity 14. At all times relevant h ereto, Responde nt has been registered as a m oney s ervices b usin ess with the Financial Cri mes Enforcemen t Network, M oney S ervices B usin ess Registrati o n Numb er 31000313157 732 and, according to its registration filing, acts as “money tran smitter” in vario us states, including Connecticut. 15. 31 CFR Secti on 1010.100 (ff)(5) defines “money transmitter ” as: (i) In general. (A) A perso n th at provides money tran smission services. The term “mon ey transmission serv ices” means the ac ceptance of currenc y, funds, or othe r value tha t substitute s for curren cy from one perso n an d the transmission o f currenc y, funds, or other value that substitutes fo r curren cy to another locati on or perso n by any means. “Any means” inc ludes, but is not limited t o, through a financial a gency or institution; a Federal Reserve Ban k or other fac ility of one or m ore Federal Reserv e Banks, the Board of Gove rnors of the Federal Reserve System, or both; an electronic funds transfer network; or an inf ormal value transfer system; or (B) Any other perso n engaged in th e transfer of fund s.

2. Section 36a - 596(1 3) of the C onnectic ut General Statutes, as amend ed by Public Act 25 - 66, defines “ money transmission ” as: “ engaging, dir ectly or thro ugh an authoriz ed delegate, in the busin ess of issuing or se lling payment instrument s or stored val ue, receiving m oney or monetary va lue for curre nt or future tr ansmission or the business of transmit ting money or monet ary value withi n the United St ates or to locations outs ide the Unit ed States by a ny and all me ans including, but not limited to, payment instrument, wire, facsimile, electronic transfer, virtual curr ency kiosk or digital wa llet, including, but not limited to, a digit al wallet utilized in connection wi th a consumer payment mo bile applicatio n Additionally, Section 36a - 597(a) of the Connecticut Gen eral Statutes requires licensure of any person who e ngage s in the business of money transmis sion in this state or ad vertise s or solicit s such services. 17. Responde nt is not curre ntly and has ne ver been lice nsed to engage i n the busines s of money transmiss ion in this state, nor does Re spondent qualif y for an exem ption from suc h licensure. Solicitatio n and Advert ising 18. From at least January 2022 thro ugh t he present, Responde nt solicited or adver tised money transmission services in Connecticut thr ough its webs ite, contracts and communicat ions with debt negotiator s and Connecti cut consumers. Both debt n egotiators a nd Connecticut consumers contr acted w ith Resp o nde nt for money transmission services, including, but not limite d to, the receipt of co nsum er money or mone tar y va lue for current or future mone y transmi ssion and transmission of su ch money or monetary va lue to creditor s and debt negot iators. 19. At all times relevant h ereto, Responde nt represent ed on its website that, “ FORTH Pay is a transaction man agement and acco unting platfo rm that offers ded icated account s for consumer management, facil itating the secure h andling o f deposits and disb ursements with ease.. . . ” and represent ed i n its agreements with debt negotiators, tha t Responde nt “ is i n the busines s of providing transaction man agement and p rocessing services an d on - line transac tion and account i nformation for clients (collectively, the “Services”), which Serv ices relate to FOR TH establishin g and maintaining

FDIC - insur ed cu stodial bank accou nts (“Accounts”) th at are for the pur pose of clients to accu mulate and disburse fund s in connectio n with the rep ayment of cl ient debts ”. Custody or Cont rol 20. At all times relevan t hereto, Responde nt rece ived monies or monetary value for current or future transm ission an d transmitted monie s or monetary value in Connecti cut by exerc ising ownership or control of ba nk accounts t hrough which Conne cticut cons umers’ funds we re transmitte d prior to disburseme nt to creditors and debt negot iators, a nd instructing a nd controlli ng the transm ission of funds to such credi tors and debt negot iators. Respondent’s agreement s with Connecticu t consumers stated th at Responden t open s account s for the consume r and initiate s ACHs on behalf of th e consumer. Responde nt received over $ 722,000 in fees for su ch services and a s of March 28, 2025, held ove r $2,176,826 for the benefit of 3,6 16 Connecticut con sumers in custodi al accounts at South State Bank (formerly know n as Atlantic Capit al Bank) (“Bank ”). 21. Consumer bank statements reflect A CH transfers in Respondent ’s name. Respondent init iated ACH transacti ons to transfer funds from prim ary bank accounts of consume rs to its custodial accounts and credite d the amount of the transfer s to consumer de dicat ed acco unts. Consumer ded icated accou nts represent beneficial interests in one or more of Re spondent’s cus todial acc ounts and do no t represen t individual ba nk accounts h eld at the Ba nk. 22. At all times relevant h ereto, Respond ent was an “account h older” of custodi al account s for beneficia l owners, includin g Connecticut residents, in as much a s it directly owne d or controlle d bank accounts tha t received a nd transmitt ed monies on beha lf of Connecti cut reside nts. Respondent a dmitted that from Decemb er 2022 to January 2025, i t co nducted 4,14 4 transactions, pro cessed at least $1,328,6 26 in payments on behalf of hundr eds of Connec tic ut consumers through a Zero Balance Account held in Respond ent ’s name at the Bank and collected $22,60 1 in fees for th e servi ces conducted through the account held in its name.

Bank Relat ionship 23. On behalf of Conne cticut cons umers, Respondent processed disbursements f rom its custodial accounts at the Ban k to debt negotiator s and creditor s and charged t he amount of such disbursem ents to the applicable co nsumer dedicat ed acco unt. T he Bank did not have any dir ect knowledge of in dividual consumers ’ tran sactions, nor wer e consumer s able to withdraw or transfer the ir funds on thei r own without the a uthorization of Respondent. Furthermore, Respondent directed con sumers to the consu mers ’ contract ed debt negotiator s if the consumer wanted to change the payment da te or amount. 24. Respondent’s ag reements with co nsumers stat ed t hat consumers’ mo nies w ould be h eld at a bank chosen by Responde nt and provid e d Responde nt w ith the authority to transfer a consumer’s ac count to an account at another FDIC – ins ured institution, at any time, and in the nam e of the consum er or in the name of Respondent. 25. Respondent ’s agree ment with th e B ank states, “ Bank will provide [Respondent ] with one or more custodi al accounts. . . for the benefit of [c] ustomer s, and will also p rovide certain f unds receipt a nd disbursement serv ices, accoun t services, and related banking servi ces to [Respondent]... . ” The Agreement also absolves the Bank of most re sponsibilit y and liabilit y relating to c onsumer account s, stating, in pertinent part: • Responde nt is the customer of th e Bank for purpose s of providing certain transacti on management and accounting services t o customer s through a proprieta ry software platform (“Prog ram ”) and th e a greement with the B ank, and Respondent ’s customers are not customer s of the Bank by virtue of participating in the Program; • Responde nt bears full responsibilit y for the off ering and use of Respondent ’s products and services to and by Respondent’ c ustomers in c onnection with t he Program or otherwise; an d • Respondent’s c ustomers will have no recourse again st th e Bank aris ing out of or r elating to the Disbursemen t Services or Respo ndent’s a greemen t with the Bank, where “Disbursemen t Services” means, in pertinent part, “. .. th e establishment and maintena nce by Bank of one or more custodi al and other a ccounts for Cl ient [Respondent ].. . ” 26. Respondent pr ovided monthly s tatement s to consumers indicating depos its, payments and current balance s of consumers ’ account s withou t any reference or i dentification of t he B ank at which such funds were he ld. Responde nt charged va rious and nume rous money transmissio n related service f ees to

Connecticut consumers, i ncluding, but n ot limited to, a Forth custo dial monthly fee of $10.95 a nd a DirectPay Disbu rsement Fee of $ 4.00 for each paymen t made from a con sumer’s account. c. Unfai r or Deceptiv e Acts and Pr actices 27. Responden t services both debt nego tiation provider s an d their consumer s and touts on its website that it s platform has settled over $8 Billion in debt. 28. Responden t is ref erred consumers by their contracted de bt negotiator s, where consumers generall y enroll with Responde nt at the same time as they contract with th e debt negotiato r and are not provide d with an option t o choose a n alternative dedicated a ccount provider w hen enrolling wi th a debt negotiator. 29. Responden t services the debt ne gotiation ind ustry by facili tating paym ents to debt neg otiation providers and offer ing its CRM software. The CRM so ftware assist s debt negotiators with va rious operations, in cluding, but not limited to, contact/lead manage ment, phone system int egration, sales scripts, w ebhooks and doc ument building (initial on - boarding). 30. Responden t referen ce s su ch ad ditional services o n its website, stat in g, We work closely wi th debt relief servic e providers (DRS Ps) through an integrated s uite of produc ts designed to s upport every stage of the customer journey. Our pl atform empowers DRSPs wit h tools for customer acquisition, marketing, automation, credit pulls, advanced data analytics, and d edicated accou nt administration. While DRSPs focus on negotiating a nd managing de bt relief progr ams, FORTH inde pendently administe rs the custodial accounts use d in those progr ams in partner ship with federa lly insured bank i ng institutions. 31. While Responde nt clai ms that it “ind ependently” admin isters the custo dial accounts, on at least one occasion, a debt negoti ator who referred consume rs to Respondent ’s custodial account services received a redu ction i n its CRM software fees by Respondent waiving its one - tim e bi lling fee of $2, 500, t hird p arty p ayment g atewa y f ees, and fees for r esource hours tota ling up to t housands of dolla rs. 16 CFR Sectio n 310.4(a) (5) (ii)(D) of t he Telemark eting Sales Rule requires that an entity administering a dedicated acco unt “ not give or a ccept any money or other com pensation in exc hange for refe rrals of business invo lving the debt relief se rvice ”.

1. Responden t misrep resented it s compliance with the Telemarket ing Sales Rule and its culture as bei ng compliance - focu sed to the public, making the following fal se or misleading stat ements on its websit e: • Is the company I enrolled with compliant? We take all con sumer complaint s very seriously at FORTH and only work with the most co mpliant debt reli ef service providers (DRSPs) in the debt settlement industry. Our company and all the compani es we service strictly adhere to the Federal Trade Commission (FTC) & Telemarketin g Sales Rule (TSR) gu idelines set forth fo r the debt settlemen t industr y. • Complianc e Simply stated, co mpliance comes first at FORTH. We operate wit hin the FTC’s Telemarketing Sales Rule guideli nes and routi nely review the operati ng procedures, marketing mater ials, client agreemen ts, sales scripts, legal actio ns and other materi als from debt rel ief service providers (DRSPs).. . . T he transactio ns we manage are regu lated by specific b anking rules and compliance stan dards set forth b y the Federal Trade Co mmission’s Telemarketing Sales Rule. Our services are fo cused on respecti ng the rights of cons umers involv ed in debt sett lement pr ograms; in this role, we are committed to protocols and p rocedures that are compliance - d riven, secure and t ransparent. III. STATUTORY B ASIS FOR ORD ER TO MAKE RESITU TION, ORDER TO CEASE AND DESIST A ND IMPOSITIO N OF CIVIL PENAL TY 33. Respondent eng ag ed in the busines s of money tr ansmission wi thout a licen se, as more ful ly described in p aragraphs 5 to 3 2, in clusive, in violation of Se ction 36a - 597(a) of the C onnecticut Ge neral Statutes. Such violation s form the b asis to issue an order to make res titution pursua nt to Sections 36a - 608(c) (1) and 36a - 50(c) of th e Connecticut General S tatutes, to cease an d desist against Respondent pursuant to S ections 36a - 608(c) (1) and 36a - 52(a) of the Connect icut General Statut es and to impos e a civi l penalty upon Re spondent pursua nt to Secti ons 36a - 608(c) (1) and 36a - 50(a) of t he Connecti cut General Statut es. Section 36a - 5 0(a) of the Conn ecticut General Statu tes authorizes the Co mmissioner to

impose a c ivil penalty upon R espondent in a n amount not to exceed One H undred Thousand Dollar s ($100,000) per viol ation. 34. Respondent adv ertis ed or solicit ed money tr ansmission servi ces without a license, as more fully descr ibed in paragrap hs 5 to 32, inclusive, in vi olation of Se ction 36a - 597(a) of the Conne cticut General Statut es. Such violation s form th e basis to issu e an order to make res titution pursuant t o Sections 36a - 608(c) (1) and 36a - 50(c) of th e Connecticut General S tatutes, to cease and desist against Respondent pursuant to S ections 36a - 608(c) (1) and 36a - 52(a) of the Connect icut General Statut es and to impos e a civil penalt y upon Respon dent pursuant t o Sections 36a - 608(c) (1) and 36a - 50(a) of the Con necticut General Statut es. Section 36a - 5 0(a) of the Conn ecticut General Statu tes authorizes the Co mmissioner to impose a c ivil penalty upon R espondent in a n amount not to exceed One H undred Thousand Dollar s ($100,000) per viol ation. 35. Respondent eng ag ed in the busines s of debt adju st ment without a licen se, as more fully describ ed in paragraphs 10 to 17, inclusive, in violat ion of Sectio n 36a - 656(a) of t he Connectic ut General Statutes. Such violation s form the b asis to issue an order to make res titution pursua nt to Sections 36a - 657(b) and 3 6a - 50(c) of the Connecticut General Statutes, to cease and d esist against Respondent pursuant to S ections 36a - 657(b) and 36a - 52(a) of the Connecticut Gen eral Statutes and to impos e a civil penalt y upon Respondent p ursuant to Se ctions 36a - 657(b) and 36a - 50(a) of the Conn ecticut General Statutes. Section 36a - 50(a) of the Connecticu t General Statut es authorizes th e Commissioner to impose a civil penalt y upon Respon dent in an amount not to exc eed One Hundred Tho usand Dollars ($100,000) pe r violation. 36. Responde nt, as a person re quired to be license d pursuant to Section 36a - 597(a) of the Connecticut Gen eral Statutes, directly or indirectly, engage d in unfair or decept ive practice s towar d consumer s in connection w ith money transmission by: (1) represen tin g its custodial p ractices as compliant when it was not comp liant with appl icable requirements, including money transmitter li censure requirements i n Connecticut, deb t adjustment licensu re requirement s in Connecticut and the Telemarketing Sales Rule; an d (2) representing th at it was independe nt from debt negoti ators, when i n

fact, it was not independent from debt negotiators a nd provided ki ckbacks to de bt negotiators for referr als of consumer accou nts through reduced CRM softwar e fees, as more fully des cribed in para graphs 5 to 3 2, inclusive, in violation of S ection 36a - 607(c)(2) of the Connecticu t General Statu tes. Such violation s form the basis to issue an order to make restitution purs uant to 36a - 608(c) (1) and 36a - 50(c) of the Connec ticut General Statut es, to cease and d esist against Res pondent pursuant t o Sections 36a - 608(c) (1) and 36a - 52(a) of the Connecticu t General Statut es and to impos e a civil pena lty upon Res pondent pursua nt to Sections 36a - 608(c) (1) and 36a - 50(a) of the Co nnecticut General Statu tes. Section 36 a - 50(a) of the Connectic ut General S tatutes authoriz es the Commi ssioner to impos e a civil pena lty upon Responde nt in an am ount not to exceed One Hundred Thous and Dollars ($100,000) per vi olation. V. ORDER TO MAKE RESTITUTI ON, NOTICE OF INTENT TO ISS UE ORDER TO CEASE AND DES IST, NOTICE OF INTENT TO IMPOS E CIVIL PENALTY AND N OTICE OF RIGHT T O HEARING W HEREAS, the Commissioner has reason to belie ve that Res pondent ha s engaged in acts or conduct which f orm the basis to issue an orde r to make re stitution agains t Responde nt p ursuant to Section s 36a - 608(c)(1), 36a - 657(b) and 36a - 50(c) of the Connecticut Gener al Statutes, to ceas e and desist against Re spondent pursua nt to Sections 36a -608(c)(1), 36a - 657(b) a nd 36a - 52(a) of the Connecticut General Statut es and to impose a civil pena lty upon Res pondent pursuant to Sections 36a -608(c)(1), 36a - 657(b) and 3 6a - 50(a) of the Connecticut Gen eral Statutes; THE COMMISSIO NER ORDERS, pursuant to Section 36a - 50(c) of the Connecticut General Statutes, that Set Forth, LLC a/k/a Forth, Inc. d/b/a Forth f/k/a Set F orth, Inc. f/k/a Debt Pay Gateway, In c. MAKE RESTITUTION of any sums obtained as a resu lt of Set Forth, LLC a/k/a Forth, Inc. d/b/a Forth f/k/a Set Forth, Inc. f/k/a Debt Pay Ga teway, Inc. violatin g Sections 36a - 5 97(a), 36a - 607(c)(2) and 36a - 656(a) of the Connecticut General S tatutes, plus interest at the legal rate set forth in Section 37 - 1 of the Connect icut General Statutes since March 1, 20 16. Specifically, the Commissioner O RDER S that: Not later than th irty (30) days from th e date this Order to Make Restitutio n becomes permanent, Set

Forth, LLC a/k/a Forth, Inc. d/b /a Forth f/k/a Set Forth, Inc. f/k/a Debt Pay Gatew ay, Inc. shall make restitution as follows: 1. Set Forth, LLC a/k/a Forth, Inc. d/b/a Forth f/k/a Set Forth, Inc. f/ k/a Debt Pay Gateway, In c. shall repay all amounts paid to i t as fees, plus interest, since March 1, 20 16, by any Connecticut consumer. Payments shall be made by cashier ’s check, cert ified check or money order; a nd 2. Provide evide nce of such re payments to Sw arupa Madhavan, Paralegal, Consumer Cre dit Division, De partment of B anking, 2 80 Trumbull Street, 16th Floor, H artford, Connecticut 06103, or sw arupa.madhavan@ ct.gov. NOW THEREFORE, notice is he reby given to R esponde nt tha t the Commis sioner intends to issue an order requ iring Respon de nt to CEASE AND DESIST from violating Sections 36a - 597(a), 36a - 607(c)(2) and 36a - 656(a) of the Connecticut Gen eral Statutes and to impose a CIVIL PENALTY upon Respon dent as set f orth herein, subject to R espondent ’s right to a hearing on the allegations set forth above. A hearing wi ll be granted t o Respondent i f a written r equest for a he aring is rec eived by the Department of Banking, Cons umer Credit Di vision, 2 8 0 Trumbull Street, 16th F loor, Hartford, Connecticut 06103 or subm itted by e - mai l to DOB.hear ingsupport@c t.gov within f ourteen (14) da ys following Respo ndent’s receipt o f this Order to Make Rest itution, No tice 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 - 50(c), 36 a- 52(a) and 36a - 50(a) of the Connecticu t General Statutes. This Order to M ake Restitution, Not ice of Intent to I ssue Order to Cease an d Desist, Notice o f Intent to Impose Ci vil Penalty and Notice of Rig ht to Hearing sh all be deemed recei ved on the earlier of the date of actual r eceipt, or seven (7) days after mail ing or sending. To request a he aring, comple te and return the enclosed Appearanc e and Request fo r Hearing Form to one of the a bove address es. If Respondent will not be represented by an attorney at the hear ing, please comp lete the Appearan ce and Request fo r Hearing Fo rm as “pro se”. If a hearing is req uested, it will b e held in person at t he Department’s o ffices. Once a written request for a heari ng is received, th e Commissioner may issu e a notificatio n of hearing and designation of

hearing officer that acknowledg es receipt of a req uest for a hearing, designates a hear ing officer and sets the date of the heari ng in accordan ce with Section 4 - 177 of the C onnecticut G eneral Statute s and Section 36a -1- 21 of the R egulations of Connectic ut State Agencies. At the discretio n of the Hearing O fficer, for good cause shown, the Heari ng Officer may a pprove requests for remote pa rticipation in the hearing by a Respondent, witn ess, or attorney. If such requests are ap proved by the Hearin g Officer, such remo te participa tion will be c onducted via vide oconference. If a hearing is requ ested, the hearing will be held on March 1 8, 2 02 6, at 10 a.m. If a heari ng is requeste d, it will be hel d in accorda nce with the provi sions of Chapte r 54 of the Connecticut Gen eral Statutes, u nless Respond ent fails to appear at t he requested hearin g. At such hearing, Re spondent will h ave the right t o appear and present evi dence, rebutta l evidence a nd argument on all issues of f act and law to be con sidered by the Commissi oner. R emote participation in a hearing will be held in accor dance with Secti on 1- 225a of the Conn ecticut General Statu tes, and th e Remote Hearing Guideli nes available o n the Department’s website at https://portal.ct.gov/do b. If Responde nt does not request a hearing with in the time period p rescribed or fails to appear at any such hearing, th e allegations herei n will be deemed ad mitted. Accord ingly, the Order to Make Restitution shall remain in effect and become per manent, and the Commissioner wil l issue an order th at Responde nt cease and desi st from violatin g Sections 36a - 597(a), 36a - 607(c)(2) and 36a - 656(a) of the Conne cticut General Statut es, an d may order a ci vil penalty in an amount not to exceed One Hundre d Thousand ($100, 000) p er violation be imposed upon Responde nt. So ordered at Hartford, Conne cticut, th is 13t h day of Januar y 202 6. ___ / s/ ____________ _________ ______________ _ Jorge L. Perez Banking Com missioner

CERTIFICATIO N I hereby cer tify that on this 1 5th day of Januar y 20 26, the foregoing Order to Make Restitution, Notice of Inten t to Issue Order to Cease and Desist, No tice of Intent to Impose Civil Penalty and Notice of Right to He aring was sent by certifi ed mail, return r eceipt requested to Set Forth, LLC a/k/a Forth, Inc. d/b/a Forth f/k/a Set Forth, Inc. f/k/a Debt Pay Ga teway, Inc., Attention: Juan Cahue, 150 N Ma rtingale Road, Suite 1 200, Schaumbur g, Illinois 60173, Certifie d Mail No. 7014 34 90 00002 3525 89 26. _ /s/ __________________ ___________ _________ Swarupa Madhav an Paraleg al