Consent Order: Banta and First Bank Mortgage Inc.

• * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * WHEREAS, the Commis sioner of Consum er Protection is charged wi th the adminis tration of Chapter 392, Section 20 - 311 to 20 - 32 9 hh, inclusive, of the Connecticut General Statutes, “Real Es tate Licens e es”, and Sections 20 - 325c - 1 to 20 - 325c - 5, inclusive, of the Regulations of Connecticut State Agencies (“Regulation s”), “Fees Charge d by Real Estate Bro kers and Sal esmen ”; WHEREAS, Section 20 - 325c of the Conn ecticut General Statu tes, in effect prior to April 1, 2024, state d, in pertinent part: IN THE MATTER OF: MEERA BANTA REB.791691 NMLS # 1582629 (“Banta”) CONSENT ORDER FIRST BANK MOR TGAGE, INC. DCP Case Number 2 024 - 382 d/b/a MONEY TREE NMLS # 91291 (“Money Tree”) (collectively, “ Respondents”) Legal Authority and Jurisdiction (a) As used in th is section “residenti al real proper ty” means one to four - family residential real estate located in this state. (b) ... [N]o real estat e broker or r eal estate salesperso n, an d no person affiliated with such broker or sal esperson, wh o receives a fee, commission or other valuable con sideration fo r the sale of residential real property, ma y receive a f ee, commissi on or other valua ble considera tion for negotiati ng, soliciting, arrangi ng, placing or fi nding a firs t mortgage

l oan for the buy er in connection with the same sale un less disclosur e is made in accordan ce with the pro visions of subsect ion (c) of this section. Any fee, comm ission or othe r valuable cons ideration re ceived by such broker or salesp erson for negotiating, soliciting, arranging, placing or finding a first mo rtgage loan shal l (1) be related to th e services actua lly performed, as determine d by the Banking Com missioner by re gulations adopted purs uant to chapte r 54, (2) not be imposed for the referral of the bu y er to the mortgage lende r by such broker or salesperson, and (3) be paid directl y to the broker or salesperso n by the buyer r ather than fro m the mortgage loan proceeds at the time of closing. (c) Any disclosu re made pursuant to subsection (b) of this section shal l be made to a nd acknowledge d by the buyer pr ior to the tim e the buyer signs a contract wi th the real estate bro ker or salesper son for mortgage brokering services.. . . WHEREAS, th e determina tion made by the B anking Commi ssioner by regulat ions adopted pursuant to S ection 20 - 325c of the Connecticu t General Statu tes are contain ed within Sections 20 - 325c - 1 to 20 - 325c - 5, inc lusive, of t he Regulations, under the juri sdiction of the Commissioner of Consumer Protection; WHEREAS, the Banking Commissione r is charge d with the admini stration of P art I of Chapter 668, Sections 36a - 485 to 36a - 534b, inclusive, of the Connecticu t General Statu tes, “Mortgage Lenders, Corresp ondent Lend ers, Brokers and Loan Originat ors”, as amended; Matters Asserted W HEREAS, Ban ta has been licen sed as a real estate broker in C onnecticut under the juris diction of the Comm issioner of Cons umer Protec tion since May 7, 2018, and h as been licensed as a m ortgage loan origina tor in Connect icut under the jurisdiction o f the Banking Commissioner since August 1, 2017. At all times relevan t hereto, Ban ta was employed as a realtor for real est ate broker Kinar d Real Estate Services LLC d /b/a Better Homes an d Gardens Real Est ate, Shore & Coun try Properties, RE B.0791524, and was the Chief Ex ecutive Officer, th e Qualified Indi vidual and a s pons ored m ortgage l oan o riginator of Money Tre e; WHEREAS, Mo ney Tree is a Con necticut c orporat ion with a main offi ce at 43 Crescent Street Suite # 20, Stamf ord, Connecti cut, which has been licensed as a mort gage correspo ndent lender in Connecticut under the juris diction of t he Banking Co mmissioner since January 24, 2 022;

Investigation, Allegations and Enforcement Powers W HEREAS, the Department of Consu mer Protec tion conducted a n investigatio n into the act ivities of Banta purs uant to Section 20 - 320 of the Connecticut Gener al Statutes, to d etermine if she had v iolated, was violating o r was about to v iolate the provi sions of the Connecti cut General Stat utes or the Regulations within the juri sdiction of th e Commissi oner of Consume r Protec tion; WHEREAS, as a resu lt of such investigation, the Department of Consumer P rotection allege s that between A pril 2022 and April 2023: (1) Banta fail ed to make the disclosure re quired by Sectio n 20 - 325c of the Connecticut General Statutes, in effect at such time, prior to entering i nto a contrac t for mortgage brokering services in connection wi th three Connecticut residential real property transactions, in violation of Section 20 - 325c(c) of the Connecticut Gen eral Statutes in effect at such ti me; (2) the fee, commission, or other valua ble consider ation Banta re ceived for ne gotiating, sol iciting, arr anging, placi ng or finding first mortgage loa ns in con nection with f our Connecticut residen tial real proper ty transactions was no t paid directl y to the broke r by the buyer, but rather was paid from the mortgage loan pr oceeds at the time of closing, i n violation of Section 20 - 325 c(b)(3) of the Connecticut General Statutes in effect at such time; (3) Banta failed to execute a written agreement with buyers which met the r equirements o f Section 20 - 325c - 3 of the Regulations in c onnection wi th four Connecticut residential real property transactions, in viol ation of S ection 20 - 325c - 3 of the Re gulations; (4) Banta failed to base the fee, commissi on or other valuable consi deration she receiv ed, for mortgage broke ring service s in connection w ith four C onnecticut residential real property transacti ons, on a reasonable hourly rate, i n violation of Section 20 - 325c - 4 of the Regulations; and (5) Banta failed to maintain a written record o f the amount of time spent in negotiating, soliciting, a rranging, pla cing or findin g a first m ortgage loan for bu yer s and to provide an itemized invoice of th e services rendered to buyers prior to the r eceipt of any f ee, commission or other val uable considerat ion received i n connection wit h four Connecticut residential r eal property tr ansactions, in violation of S ection 20 - 325c - 5 of the Re gulations; WHEREAS, the Commissioner of Cons umer Prote ction believes t hat such al legation s would support initi ation of enforc ement proce edings against Banta, includi ng, without li mitation, pro ceedings to

• * * * * i ssue an order revo king Banta’s real est ate broker license pursuan t to Section 20 - 320 of the Connecti cut General Statut es, and to impose a civil penal ty of up to Five Thousand Dolla rs ($5,000) per v iolation upon Banta pursuant to Se ction 20 - 320 of the Connecticut General St atutes; WHEREAS, the Banking Commissione r, through the Consumer Credi t Division of t he Departme nt of Banking, c onducted an exa mination of t he activitie s of Money Tre e, pursuant to Section 36a - 17 of the Connecticut General Statutes, to determine if it had violated, was violating or wa s about to violate the provisions of the Connecti cut General Statutes wi thin the jurisdic tion of the Ba nking Commis sioner; WHEREAS, as a resu lt of such examin ation, and in connection wi th the allega tions against Banta, the Banking C ommissioner a lleges that from at least April 2022 to April 2023, Money Tree failed to establish, enfo rce and maintain policies and p rocedures reason ably designed to achieve complian ce with Section 36a - 498e(a) of the Connec ticut Genera l Statutes, in viol ation of Sec tion 36a - 498e(b)(1) of the Connecticut Gen eral Statutes, i n effect at such time; WHEREAS, th e Banking Comm issioner belie ves that suc h allegation woul d support init iation of enforcement p roceedings agai nst Money Tree, including, without limitation, proceedings to revoke Money Tree’s correspondent l ender licens e in Connect icut pursuant to s ubsections (a) and (b) of S ection 36a - 494 and s ubsections (a) and (b) of Sec tion 36a - 51 of the Connecticut Gener al Statutes, as amen ded by Public Act 25 - 115, to i ssue an order to cease and desist against Money Tree purs uant to Secti ons 36a - 494(b) and 3 6a - 52(a) of the C onnecticut G eneral Statut es, and to impos e a civil pena lty of up to One Hundred Thousa nd Dollars ($100,000) per vi olation upon Mone y Tree purs uant to Sections 36a - 494(b) and 36a - 50(a) of the Connecticut Gen eral Statutes; Representati ons WHEREAS, in itiation of such en forcement proceed ings would constitute a “cont ested case” within the meani ng of Section 4 - 166(4) of the Connecticut Gen eral Statutes. S ection 4 - 177(c) of the Conne cticut General Statut es and Section s 21a -1- 26a and 36a -1- 55(a) of the Regu lations provide th at a contested case may be res olved by consent order, un less precluded by law;

WHEREAS, th e Commissione r of Consume r Protection, the Banki ng Commissioner and Respondents acknowledg e the possible co nsequences of fo rmal administrativ e proceedings, and Respondents each voluntarily agree to consent to the entry of the s anctions im posed below without admitting or denying the al legation s set forth herein, and solely for the purpose of obv iating the need for formal administ rative proceedin gs concernin g the allegation s set fo rth herein; WHEREAS, th e Commissione r of Consume r Protection, the Ba nking Commiss ioner an d Respondents now desire to resolve the matters set forth herei n; WHEREAS, Money Tree represents that it has established policies and p rocedures reasonab ly designed to achiev e compliance with S ection s 20 - 325c and 36a -4 98e(a) of the Connecti cut General Statutes, and Secti ons 20 - 325c - 1 to Sec tion 20 - 325c - 5, inclusive, of the Regulatio ns, and represents t hat such policies an d procedures are no w and in th e future will be enforced and maintain ed; WHEREAS, Respondents each acknowledge tha t they have read this Consen t Order in its en tirety, that they have had the opportunity to consult w ith and be repr esented by in dependent couns el in negotiating a nd reviewing this Consent Order and that they execute this Consent Order freel y; WHEREAS, Ban ta waives any req uirement that the Consent Order contain a stateme nt of findings of fact and c onclusions of l aw and waives any furthe r procedure s under the Unif orm Administr ative Procedures Act, Chapter 54 o f the Connecticut Gener al Statutes, and acknowledges that this Consent Order shall have t he same force an d effect as an ord er entered after a f ull hearing; WHEREAS, Respondents each acknowled ge that this Consen t Order is a public reco rd and is a reportable event for purpo ses of the re gulatory disclo sure questi ons on the Nationwide Multistate Licensing System and Registry (“NM LS”), as applic able; AND WHEREAS, Respondents, through their respective execution of this Cons ent Order, voluntarily a gree to waive their procedural right s, including a right to a noti ce and an op portunity for a hearing as it pert ains to the allegatio n s set forth here in, and volunt arily waive their right to seek judicial review or otherwise challenge o r contest the validi ty of this Consent Ord er.

WHEREAS, Respondents, t hrough their execution of this consent order, c onsent to the ent ry of this Consent Orde r imposing the fol lowing sanc tion s: NOW THEREFORE, the Commissioner of Consu mer Protec tion and Banking Com missioner enter the f ollowing: CONSENT TO ENTRY OF SAN CTIONS 1. B anta shall volu ntarily cease from violating Section 20 - 325c of the Conne cticut Gene ral Statutes and Secti ons 20 - 325c - 3, 20 - 325c - 4 and 20 - 325c - 5 of the Regulations o f Connecticut S tate Agencies; 2. Money Tree shal l cease and desist fr om violating Section 36a - 498e(b)(1) of the Connecticut Gen eral Statutes, as a mended by Public Act 25 - 115; 3. No later than th e date this Consen t Order is executed b y Banta, she shal l remit to the Department of Consumer Prot ection by business check or bank ch eck made payable to “Treasurer, Stat e of Connecticu t”, the sum of Twelv e Thousan d Dollars ($12,0 00) to settle this matter, which wil l be deposite d into the cons umer protection e nforceme nt account (#35125) in a ccordance w ith Section 21a - 8a of the Connecticut General Statu tes, made payable in fo ur installm ents of Three T housand Dollar s ($3,000) as f ollows: the f irst payment due no l ater than t he date this Cons ent Order is executed by Ba nta, and the remaining pa yments due on or be fore Marc h 15, 2026, June 15, 2026, and Septembe r 15, 2026; and 4. Money Tree shall remit to the Departmen t of Banking by el ectronic fund s transfer, cashier’s che ck, certified ch eck or money o rder made payable t o “Treasurer, Stat e of Connecticut ”, the sum of F our Thousand Dollars ($ 4,0 00) as a civil penal ty pursuant to Section 36a - 50(a) of the Connecticut General Stat utes, made payable in four installme nts of One Thousand Dol lars ($1,000) as follows: the first payment due April 1, 2026, and t he remaining pa yments due on or be fore July 1, 2026, October 1, 2026, and January 1, 202 7. CONSENT ORDER 1. T he Sanctions set for th above be an d are hereby entered; 2. Upon issuance of this Cons ent Order by t he Commissioner of Consumer Pr otection and Banking Com missioner, this matter will be resolved and the Commissioner of C onsumer Protection a nd Banking Co mmissioner will not tak e any future enforcement a ction ag ainst Respondents based upon the allegation s s et forth herei n; provided tha t issuance of t his Consent Order is without prejudice to the right of either Commissioner to tak e enforcement actio n against Respondents base d upon a violati on of this Co nsent Order or t he matters underlying its entry, if either t he Commissione r of Consume r Protection or t he Banking Com missioner determine s that compliance wit h the terms he rein is not be ing observed or if any repre sentation made by Responde nts and re flected her ein is subseque ntly discove red to be untrue; 3. Subject to the foregoing, a nd so long as this Consent Or der is promptly di sclosed by Respondents and their control per sons on NMLS, a s applicable, nothing in the i ssuance of this

_ /s/ _______________ ______________ __________ __ /s/ _________ shall adversel y affect the abi lity of Respondents to apply for or obtain renewal licen ses under Chapter 392, Section 20 - 311 et seq. of the Connecticut General Statutes, or Part I of Chapter 668, Section 36a - 485 et seq. of the Connecticut Gen eral Statutes, pro vided that all legal requirement s for such licen ses are satisfied and the terms of this Co nsent Order are followed; 4. This Consent Order shall no t become a part of th e official record and shall not be effectiv e unless and until it is accepted an d executed by the Commissioner of Consumer Prot ection and Banking Com missioner, at which tim e it will be binding upon Banta and Money Tree and i ts successors an d assigns; and 5. This Consent Order sh all become final when issued by the Commissioner of Consumer Protection a nd Banking Co mmissioner. Issued at Hartfo rd, Connecticut This 5th day of Feb ruary 202 6. Bryan T. Cafferelli Commissione r of the Depar tment of Cons umer Protection _________ _______________ __ ___ Issued at Hartfo rd, Connecticut This 30th day of January 202 6. Jorge L. Perez Banking Com missioner

I, Meera Banta, state that I have r ead the foregoi ng Consent O rder; that I know a nd fully under stand its contents; that I agre e freely and wit hout threat or c oercion of a ny kind to compl y with the sa nctions entered and t erms and condi tions ordere d herein; and t hat I voluntar ily agree to e nter into this Consent Order, expres sly waiving the p rocedural righ ts set forth herein as t o the matters descri bed herein. By: _ /s/ __________________ ____________ _______ Meera Banta State of: Connecticut County of: Fairfield On this the 23r d day of January, 202 6, befor e me, Guy Bocicaut, the undersigned off icer, personally ap peared Meera Bant a, known to me (or satisfa ctorily proven) to be the per son whose name is subscribed with in the instrument and acknowledged that he/she execu ted the same for t he purposes therein conta ined. In witness whereof I hereunto set my h and. __ /s/ ______________ ______________ _________ Notary Public Date Commission Expires:

__ /s/ _ _____________ ______________ __________ I, Bhom Banta, state on behalf of First Bank Mort gage, Inc. d/b/ a Money Tree that I have read the foregoing Co nsent Order; that I know and f ully unders tand its content s; that I am authorized to e xecute this Consent Order on beh alf of First B ank Mortgage, I nc. d/b/a Money T ree; that First Bank Mortgage, Inc. d/b/a Mo ney Tree agree s freely and w ithout threat or coercion o f any kind to c omply with the sanctions e ntered and ter ms and conditions ordered her ein; and that First Ba nk Mortgage, Inc. d/b/a Money Tree volunt arily ag rees to ente r into this Conse nt Order, expre ssly waiving the procedural rights set forth herein as to the matters describ ed herein. By: _ /s/ _ __________________ _______________ _ Name: Bhom Banta Title: President First Bank Mor tgage, Inc. d/b/a Money Tre e State of: Connecticut County of: Fairfield On this the 23r d day of January, 202 6, befor e me, Guy Bocicaut, the undersigned off icer, personally ap peared Bhom Banta who acknowl edged himsel f /herself to be the President of First Bank Mortgage, Inc. d/b/a Money Tree, a c orporation, and t hat he /she as such as President, being authorized s o to do, execut ed the foregoi ng instrument for the purpo ses therei n contained, by signi ng the nam e of the corporation b y himself/herself as P resident. In witness whereof I hereunto set my h and. Notary Public Date Commission Expires: