STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS DIVISION OF CONSUMER SERVICES INTRODUCTION I. FACTUAL ALLEGATIONS

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1 IN THE MATTER OF DETERMINING Whether there has been a violation of the Consumer Loan Act of Washington by: PENSIONS, ANNUITIES AND SETTLEMENTS, LLC, STATE OF WASHINGTON DIVISION OF CONSUMER SERVICES Res ondent. INTRODUCTION No.: C SC01 STATEMENT OF CHARGES and NOTICE OF INTENTION TO ENTER AN ORDER TO CEASE AND DESIST, PROHIBIT FROM INDUSTRY, IMPOSE FINE, AND REFUND FEES AND INTEREST Pursuant to RCW and RCW 1.0., the Director of the Department of Financial Institutions of the State of Washington (the Director) is responsible for the administration of chapter 1.0 RCW, the Consumer Loan Act (the Act). After having conducted an investigation pursuant to RCW 1.0.1, and based upon the facts available as of the date of this Statement of Charges, the Director, through his designee Director Deborah Bortner, institutes this proceeding and finds as follows: I. FACTUAL ALLEGATIONS 1.1 Pensions, Annuities and Settlements, LLC (Respondent) is known to have conducted business from 00 Von Karman Avenue, Suite, Irvine, California 2, and from East Coast Highway, #, Corona del Mar, California. Respondent has never been licensed by the Washington State Department of Financial Institutions (the Department) to conduct business as a consumer loan company in the State of Washington Unlicensed Activity. Between at least December and the date of this Statement of 2 2 Charges, Respondent conducted the business of a consumer loan company in at least loan transactions when it was not exempt from licensing and did not possess a valid license. Respondent STATEMENT OF CHARGES No.: C SCOI Pensions, Annuities and Settlements, LLC I SO Israel Rd SW PO Box 10 Olympia, WA 0-10 (0) 02-0

2 1 offered consumer loans to at least Washington residents and collected a fee for those services. A 2 list of Washington consumers with whom Respondent conducted business as a consumer loan company, and the amount of the loan and associated interest, fee, or other charge, is appended hereto and incorporated herein by reference On-Going Investigation. The Department's investigation into the alleged violations of the Act by Respondent continues to date. II. GROUNDS FOR ENTRY OF ORDER 2.1 Definition of Loan. Pursuant to RCW 1.0.0( ) and WAC --0, a "Loan" means a sum of money lent at interest or for a fee or other charge and includes both open-end and closed-end loan transactions. 2.2 Definition of Making a Loan. Pursuant to RCW 1.0.0(1) and WAC --0, 1 "Making a Loan" means advancing, offering to advance, or making a commitment to advance funds to 1 a borrower for a loan Requirement to Obtain and Maintain a License in Accordance with the Act. Based on the Factual Allegations set forth in Section I above, Respondent is in apparent violation of RCW and WAC --20 for engaging in the business of making secured or unsecured loans to Washington residents without first obtaining and maintaining a license in accordance with the Act or meeting an exemption from the Act under RCW Prohibited Practices. Based on the Factual Allegations set forth in Section I above, Respondent is in apparent violation of RCW (2) and () for engaging in an unfair or deceptive practice toward any person and for obtaining property by misrepresentation. II 1 At least 2 of the Washington consumers are either retired or disabled military veterans. STATEMENT OF CHARGES No.: C SCOI Pensions, Annuities and Settlements, LLC 2!0 Israel Rd SW PO Box 10 Olympia, WA 0-10 (0) 02-0

3 1 III. AUTHORITY TO IMPOSE SANCTIONS 2.1 Authority to Issue an Order to Cease and Desist. Pursuant to RCW 1.0.0()(a), the Director may issue an order directing any person subject to the Act to cease and desist from conducting business in a manner that is injurious to the public or violates any provision of the Act..2 Authority to Prohibit from Industry. Pursuant to RCW 1.0.0(), the Director may issue an order prohibiting from participation in the conduct of the affairs of any licensee, any person subject to this chapter for a violation of RCW or failure to obtain a license for activity that requires a license.. Authority to Impose a Fine. Pursuant to RCW 1.0.0(), the Director may impose fines of up to one hundred dollars per day, per violation, upon any person subject to the Act for any violation of the Act. 1. Authority to Order Refund of Fees and Interest. Pursuant to RCW 1.0.0(2) and RCW ()(b), the Director may issue an order directing the refund of all fees and interest charged in any transaction violating RCW 1.0.0( 1 ). IV. NOTICE OF INTENTION TO ENTER ORDER Respondent's violations of the provisions of chapter 1.0 RCW and chapter - WAC, as set forth in the above Factual Allegations, Grounds for Entry of Order, and Authority to Impose Sanctions, constitute a basis for the entry of an Order under RCW 1.0.0, RCW 1.0., and RCW Therefore, it is the Director's intention to ORDER that:.1.2 Respondent Pensions, Annuities and Settlements, LLC immediately cease and desist from making consumer loans to Washington state residents until such time as Respondent obtains a license in accordance with the Act from the Department or qualifies for an exemption from licensing as delineated in the Act; Respondent Pensions, Annuities and Settlements, LLC be prohibited from participation, in any manner, in the conduct of the affairs of any consumer loan business subject to licensure by the Director under chapter 1.0 RCW for a period of five () years; STATEMENT OF CHARGES No.: C SCOI Pensions, Annuities and Settlements, LLC 0 Israel Rd SW PO Box 10 Olympia, WA 0-10 (0) 02-0

4 1 2.. Respondent Pensions, Annuities and Settlements, LLC pay a fine which as of the date of this Statement of Charges totals $,000; and Respondent Pensions, Annuities and Settlements, LLC refund all fees and interest to all Washington borrowers who paid fees or interest in the amounts set forth in Appendix A and in any additional amount(s) determined at hearing. V. AUTHORITY AND PROCEDURE This Statement of Charges is entered pursuant to the provisions of RCW 1.0.0, RCW 1.0., RCW 1.0.2, and RCW 1.0., and is subject to the provisions of chapter.0 RCW (The Administrative Procedure Act). Respondent may make a written request for a hearing as set forth in the NOTICE OF OPPORTUNITY TO DEFEND AND OPPORTUNITY FOR HEARING accompanying this Statement of Charges. Dated this 1. day of May, Presented by:. :~.. - Director Department of Financial Institutions 0 Israel Rd SW PO Box 10 Olympia, WA 0-10 (0) 02-0

5 1 WASHINGTON CONSUMERS 2 Borrower Loan Total Effective Payment Term for Fee, and Other Charge A.C. $,00 $,00 $,0 01/02/1 0 A.W. $,00 $, $1,1 0/02/1 0 A.M. $,00 $0,00 $0,00 0/01 0 A.P.* $1,00 $,21.0 $,1.0 02/01 1 A.P.* $,00 $,.0 $2,.0 02/01 1 B.M. $,00 $2,0 $,0 /02/1 0 B.A. $,00 $,00 $,0 0 0 C. H. $2,00 $,0 $0,10 01/1 0 C. G. $,00 $2, $,0 0/ D.F.* $,00 $, $1,.0 0/02/1 0 1 D.F.* $1,00 $,0 $2,00 0/02/1 0 D.G.W. $1,00 $, $2, /01 0 D.M. $,00 $2,0 $,0 0/0/1 0 D.R.* $00 $1,.0 $1,.0 0/02/1 1 D.R.* $,0 $0,.0 $0,.0 0/02/1 1 1 D.M.W. $,00 $2,00 $,0 //1 0 E.C. $,00 $2,000 $2,00 0/02/1 1 E.T. $,00 $,0.0 $2,0.0 02/0/ 1 G.C. $,00 $,0 $, 0/02/1 2 G.G.* $,000 $1, $, 0/0 1 2 G.G.* $,000 $0,000 $,000 0/01/ 1 2 *Washington consumers with the same initials are borrowers with multiple loans. A-1

6 1 Borrower Loan Total Effective Payment Term for 2 Fees, and Other Charges G.S. $,00 $1,00 $,0 /0 1 H.B.* $,00 $, $,0 01/01/1 0 H.B.* $,0 $2,00 $,00 0/0 0 J.C.* $,00 $,2. $,2. 0/2/1 0 J.C.* $1,00 $,.0 $2,.0 0/2/1 0 J.F.R. $,00 $1,00 $,0 // 1 J.L.R. $,00 $1,00 $, /0 1 J.D. R. $1,00 $, $2, 0/01/1 0 J.G.G. $,00 $, $1,1 0/02/1 0 J.M.* $,1. $,.0 $,1. 2/1 0 1 J.M.* $,2. $,1.0 $1,0.1 2/1 0 1 J.S. $1,00 $, $2, /01 0 J.B. $,00 $2,0 $,0 0/02/1 0 J.L.G. $,0 $,00 $2,00 02/01 0 K.V. $,00 $,00 $, K.A.S. $,00 $,0 $, 0/01 1 K.K. $1,00 $2,. $2,0. 0/0 1 K.R. $,00 $, $1,1 0/02/1 0 K.S.* $0,000 $,00 $,00 0/0/ 0 K.S.* $,000 $,0 $,0 0/0/ 0 2 L.C. $,00 $1, $,0 0/02/1 0 2 L.S.* $,00 $,.0 $,.0 0/02/1 0 2 *Washington consumers with the same initials are borrowers with multiple loans. A-2

7 1 Borrower Loan Total Effective Payment Term for 2 Fees, and Other Charges L.S.* $,00 $,2. $,. 0/02/1 0 L.F. $,00 $2,0 $,0 /02/1 0 L.J. $,00 $,0 $,00 /1 0 M.W. $,00 $2,0 $,0 0/01 0 M.D. $1,00 $, $2, 0/02/1 0 M.F. $,00 $2,0 $,0 0/2/1 0 M.O. $,00 $1,00 $,0 02//1 1 M.P.R.* $,00 $1,1.0 $,1.0 0/02/1 0 M.P.R.* $00 $2,0. $1,2. 0/02/1 0 M.R.* $0,000 $,.0 $,.0 0/ 1 1 M.R*. $0,000 $,2. $,2. 02/0/ 1 1 M.P. $,00 $,00 $,00 2/1 0 M.V. $,00 $,00 $,0 0/0/1 0 N.F. $,00 $2,0 $,0 /01 0 N.N. $,00 $, $,2 01/01 P.L.L. $,00 $,00 $,0 0/ P.D.* $,0 $,. $,. 0 0 P.D.* $1,00 $,0.0 $2,.0 01/01/1 0 P.A.D. $,000 $,.0 $,.0 /0/ 1 P.I.L. $,00 $, $1,1 0/02/1 0 2 P.R. $,00 $, $1,1 //1 0 2 R.C. $,00 $0,00 $2,00 0//1 0 2 *Washington consumers with the same initials are borrowers with multiple loans. A-

8 1 Borrower Loan Total Effective Payment Term for 2 Fees, and Other Charges R.S. $,00 $2, $, 0/0/1 0 R.R. $,00 $2, $,0 /01/1 0 R.R.H. $,00 $, $1,1 /02/1 0 R.I. $1,00 $,0 $2, 02/02/1 0 R.D.H. $,00 $,0 $,0 0/01/ 0 R.E.H. $,00 $, $1,1 0/01/1 0 R.F.M.* $,0 $2, $,0 0/02/1 0 R.F.M.* $ $,2 $,0 0/02/1 0 R.L. $1,00 $, $2, /02/1 0 R.G.* $,0 $2,. $,. // 1 1 R.G.* $,00 $2,.0 $,.0 1/ 1 1 R.A.M. $,00 $0,00 $2,00 0/01/1 0 S.V. $,00 $,00 $,0 0/02/1 0 S.R. $,000 $, $2, 0/0 1 s.s. $,00 $,0 $,00 0/01 0 S.L.H. $,0 $0, $,1 0/ S.D.H. $,00 $, $1,1 0/02/1 0 S.B. $1,00 $, $2, 0/02/1 0 S.G. $,00 $,00 $,0 0/01 0 T.E.W. $,000 $2,.0 $1,.0 /0 0 2 T.T. $1,00 $,1 $, /0 0 2 T.D. $,00 $, $,0 /01/ 0 2 *Washington consumers with the same initials are borrowers with multiple loans. A-

9 1 Borrower Loan Total Effective Payment Term for 2 Fees, and Other Charges T.P. $,00 $,00 $,00 1/1 0 T.M.* $,00 $,00 $2,0 02/02/1 1 T.M.* $,000 $,000 $,000 02/02/1 1 T.N. $,00 $,00 $,0 /02/1 0 T.R. $,00 $, $1,1 0/02/1 0 T.L.W. $,00 $,00 $,0 01/01/1 0 Y.J. $,00 $, $1,1 0/0/ *Washington consumers with the same initials are borrowers with multiple loans. A-

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