Omnipoint Management Solutions LLC - Cease and Desist Order and $100,000 Penalty

• * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * IN THE MATTER OF: ORDER TO CEASE AND DESIST OMNIPOINT MANA GEMENT SOLUTIONS LLC AND NM LS # 180 1926 ORDER IMPOSING CI VIL PENALTY (“Respondent ”) I. PRELIMINARY STATEMEN T WHEREAS, th e Banking Commissione r (“Commiss ioner”) is charge d with the adm inistration of Part XII of Chapter 669, S ections 36a - 800 to 36a - 814, inclusive, of the Connecticut General Statutes, “Consumer Col lection Agencies”, as am ended, and the regula tions promulgat ed thereunde r, Sections 36a - 809 - 6 to 36a - 809 - 17, i nclusive, of t he Regulati ons of Connect ic ut State Agencies (“Reg ulations”); WHEREAS, p ursuant to the authority granted by Se ction 36a - 17 of the Connecticut General Statutes, the Commissione r, through the Consumer Credi t Division of t he Departme nt of Banking (“Department ”), has investigated the activities of Resp ondent to determine i f it ha d violated, was violatin g or was about to violate the provisions of the Connect icut Genera l Statutes or the Regulations within the jurisdiction of the Commissioner; WHEREAS, on January 6, 2026, the Commissioner issued a Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalt y and Notice of Righ t to Hearing (collectively, “ Notice”) agai nst Respondent, wh ich Notice is incor porated herein b y reference; WHEREAS, on January 7, 2026, the Notice was caused to be mailed b y certified mail, retu rn receipt reques ted, to Responden t (Certified Mail No. 7013302000 004226844 2);

WHEREAS, the Department rece ived confirmat ion that on Janua ry 16, 2026, th e Notice was delivered to Respondent; WHEREAS, th e Notice provided Responde nt with the opportunity for a hearing, a nd stated tha t if a hearing wa s not requested by R espondent within 14 days of its rece ipt or if Responde nt failed to a ppear at any such hearing, the allegation s against Re spondent contai ned in the Notic e would be dee med admitted a nd the Commissi oner would iss ue an order that Respondent ce ase and desist from violating Section 36a - 801(a) of the Connecticut General S tatutes, as amend ed by Public Act 2 5 - 115, Secti on 36a - 812 of the Connecticut G eneral Statute s, and Secti ons 36a - 809 - 9(d)(2) and 36a - 809 - 1 0 of the Regulations, and may order a civil penalt y in an amount not to exceed One Hundred Thousand Dollars ($100,000) p er violation be imposed upon Res pondent; WHEREAS, Respondent failed to r equest a hea ring within the prescribed t ime period; WHEREAS, th e Commissioner alleg ed in the Notice, with respect to the activity described therein, that Respondent ’s acting within t his state as a consumer col lection agen cy without a con sumer collection agency lice nse constitute s violations of Section 36a - 801(a) of the Connecticut General Statu tes in effect at such time. Such v iolations form the basi s to issue an order t o cease and desist ag ainst Responden t pursuant to S ections 36a - 804(b) and 36a - 52(a) of the Connecticut Gen eral Statutes, an d to impose a c ivil penalty upon Respondent pur suant to Sec tions 36a - 804(b) and 36a - 50(a) of the Con necticut General Statutes; WHEREAS, th e Commissioner also alleged in the No tice, with respect to the activity descri bed therein, that Respondent ’ s communic ating with perso ns other than the debtor or othe r authoriz ed party, without prior consent of th e debtor, in c onnection wit h the collect ion of a debt, constitutes a violation of Section 36a - 809 - 9(d)(2) of the Regula tions. Such viol ation form s the basis to issue an order to cease an d desist aga inst Respondent pursuant to Se ctions 36a - 804(b) a nd 36a - 52(a) of the Connecticut General Statutes, and to impose a c ivil penalty upon Respondent pursuant to Sections 36a - 804(b) and 36a - 50(a) of the Connecticu t General Statutes;

WHEREAS, th e Commissioner also alleged in the No tice, with respect to the activity descri bed therein, that Responde nt’ s engaging i n conduct the n atural cons equence of whic h is to harass, oppress or abuse any per son in connect ion with the col lection of a debt, constit utes a violati on of Section 36a - 809 - 10 of the Regulati ons. Such violatio n forms the basis to issu e an order to cease and desist against Respondent p ursuant to Se ctions 36a - 804(b) and 36a - 52(a) of the C onnecticut G eneral Sta tutes, and to impos e a c ivil penalty upo n Respondent pur suant to Se ctions 36a - 804(b) a nd 36a - 50(a) of the Connect icut General Statut es; WHEREAS, th e Commissioner also alleged in the No tice, with respect to the activity descri bed therein, that Responde nt’ s acting i n a manner tha t failed to com ply with 12 CFR Sections 1006. 14(a) and 1006.14(h)(1) of the Fair D ebt Collecti on Practice s Act, by engaging i n conduct the natural conse quence of which is to harass, oppress, or abu se a person in connect ion with the co llection of a debt, incl uding communica ting with hospit al staff thr ough the hospita l’s emerge ncy medical phone l ine after the hospital staff explaine d that it was an emergen cy medical phone l ine and requested that Responden t not call such line, constitutes violations of Section 36a - 812 of the Connecticut Gen eral Statutes. Such violati ons form the basis to issue an order to cease an d desist against Res pondent purs uant to Sect ions 36a - 804(b) a nd 36a - 52(a) of the Connect icut General Statutes, and to impose a civi l penalty upon Respondent purs uant to Sections 36a - 804(b) and 36a - 50(a) of the Connecticut General S tatutes; WHEREAS, Sectio n 36a - 52(a) of the Conne cticut Gene ral Statutes pr ovides, in pe rtinent part, that “[i]f the pe rson does not r equest a hea ring within the t ime speci fied in the notice. . . , the com missioner shall issue an ord er to cease and desi st against the perso n. No such order shall b e issued except in accordanc e with the provis ions of chapte r 54”; WHEREAS, Section 36a - 50(a)(2) of the Connecti cut General Statutes provides, in pertinent part, that “[i]f such p erson does not req uest a hearing with in the time specified in the notice . . . , the commissioner may, as the facts requi re, order that a civil penalty not exceeding one hundred thousa nd dollars per vi olation be im posed upon s uch person”;

WHEREAS, S ection 36a - 50(a)(3) of the Co nnecticut General S tatutes prov ides that “[e]ach actio n undertaken b y the commissi oner under this subsection sha ll be in ac cordance with the provisions of chapter 54”; AND WHEREAS, Section 36a -1- 31(a) of the R egulations pro vides, in per tinent part, that “[w] hen a party fails to req uest a hearing wit hin the time specified in the notice, the alleg ations again st the party may be deeme d admitted. W ithout furthe r proceedings or notice to the party, the com missioner sha ll issue a final decisio n in accordan ce with Section 4 - 1 80 of the Connecticut Gen eral Statutes an d Section 36a -1- 52 of the R egula tions of Connecticut S tate Agencies”. II. FINDINGS OF FA CT AND CONCLUSI ONS OF LAW 1. The Commissioner fi nds that the matters as serted, as set for th in paragraph s 6 through 1 5, inclusive, of Section II of the Notice, shall c onstitute findings of fact within the meaning of Section 4- 180(c) of the Con necticut General Stat utes, and th at the conclusions, as set fo rth in paragraph s 16 through 19, inclusive, of Section III of the Notice, shall constitute con clusions of law within the meaning of Section 4 - 180(c) of t he Connecticut General Sta tutes and Secti on 36a -1- 52 of the Re gulations. 2. The Commi ssioner finds t hat Respondent ha s engaged i n acts or conduct which forms the basis to issue an order to cease and desist against Respondent purs uant to Se ction 36a - 804(b) a nd 36a - 52(a) of the Connecti cut General Statutes and t o impose a c ivil penalty up on Respondent p ursuant to Se ctions 36a - 804(b) and 3 6a - 50(a) of the Con necticut General Stat utes. 3. The Commission er finds that th e Notice was given in co mpliance with Secti ons 36a - 52(a), 36a - 50(a) a nd 4 - 177 of the Connecticu t General Statut es.

III. ORDER Having read th e record, I HEREBY O RDER, pursuant to Sect ions 36a - 804(b), 36a - 52(a) and 36a - 50(a) of the Connect icut General Statutes, that: 1. O mnipoint Ma nagement Solutio ns LLC CEASE AND DESIST from violating Sectio n 36a - 801(a) of the Conn ecticut General S tatutes, as amend ed by Public Act 25 - 1 15, Section 36a - 812 of the Connecticut G eneral Statute s, and Sections 36a - 809 - 9(d)(2) and 36a - 809 - 1 0 of the Regulat ions of Connecticut Stat e Agencies; 2. A CIVIL PENALT Y of On e Hundred Thousand Doll ars ($ 1 00,000) be imposed upon Omnipoint Ma nagement Solutio ns LLC to be re mitted to the Department of Banking by electronic fund s transfer, cashi er’s check, certifi ed check or mon ey order made payabl e to “Treasurer, Stat e of Connecticut ”, no later than fo rty - five (45) days from the da te this Order is mailed; an d 3. This Order shall b ecome effective when mailed. Dated at Hartford, Connecticut, t his 10t h day of Februar y 202 6. _ /s/ _______________ ______________ _______ Jorge L. Perez Banking Com missioner This Order was sen t by certified mail, return receipt req uested, to Respondent o n February 11, 202 6. Omnipoint Ma nagement Solutio ns LLC Attention: Shawn Kelley, Member 2303 Union Rd West Seneca, NY 14 224 Certified Mail No. 7015 1730 0002 2411 3670