By the Division of Banks


COMMONWEALTH OF MASSACHUSETTS

Suffolk, SS.

COMMISSIONER OF BANKS
FOREIGN TRANSMITTAL
AGENCY LICENSING
Docket No. 2012-039

FINDINGS OF FACT AND
ORDER TO CEASE AND DESIST

In the Matter of
DOUBLES BUILDING SOCIETY, LLC
d/b/a SMALL FINANCIAL ORGANIZATION

Worcester, Massachusetts

Foreign Transmittal Agency License No.: FT5741


The Commissioner of Banks ("Commissioner") having determined that DOUBLES BUILDING SOCIETY, LLC D/B/A SMALL FINANCIAL ORGANIZATION (Doubles Building society or the Company), located at 1078 West Boylston Street, Suite 204, Worcester, Massachusetts has engaged, or is engaged in, or is about to engage in, acts or practices constituting violations of Massachusetts General Laws chapter 169, and applicable regulations found at 209 CMR 44.00 et seq., hereby issues the following ORDER TO CEASE AND DESIST pursuant to General Laws chapter 169.

FINDINGS OF FACT

  1. The Division of Banks ("Division"), through the Commissioner, has jurisdiction over the licensing and regulation of persons engaged in the business of a foreign transmittal agency pursuant to Massachusetts General Laws chapter 169.
  2. Doubles Building Society is, and at all relevant times has been, a limited liability company conducting business in the Commonwealth of Massachusetts. Doubles Building Society’s main office is located at 1078 West Boylston Street, Suite 204, Worcester, Massachusetts.
  3. Bernard Kamiri is, and at all relevant times has been, the sole Member/Manager of Doubles Building Society.
  4. On September 26, 2007, License number FT5741 had been issued by the Division to authorize Doubles Building Society to conduct foreign transmittals at the Company’s 1078 West Boylston Street, Worcester, Massachusetts location.
  5. Doubles Building Society maintained an additional licensed office location at 604 Central Street, Lowell Massachusetts, from which the Company conducted its foreign transmittal business.
  6. On July 2, 2009, the Commissioner issued a FINDINGS OF FACT AND TEMPORARY ORDER TO CEASE AND DESIST, DOCKET No. 2009-114 (the "Temporary Order") against Doubles Building Society as a result of Doubles alleged failure to demonstrate and maintain the financial responsibility, character, reputation, integrity and general fitness that would warrant the belief that its foreign transmittal business will be operated honestly, fairly, and soundly in the public interest in violation of General Laws chapter 169, section 6 and the Division’s Regulation 209 CMR 44.03.
  7. On April 28, 2010 the Commissioner and Doubles Building Society entered into a STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER ("2010 Consent Order") for the purpose of settling the matters raised by the Temporary Order.
  8. On June 29, 2012, as a result of examination findings alleging substantial non-compliance with applicable state and federal statutes, rules, and regulations, the Commissioner and Doubles Building Society entered into a subsequent STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER ("2012 Consent Order") the terms of which required Doubles Building Society to surrender its Massachusetts foreign transmittal agency license, FT5741. The 2012 Consent Order also stated that Doubles Building Society was prohibited from reapplying for a license from the Division for a period of thirty six (36) months.
  9. On June 29, 2012, as required by the 2012 Consent Order, Doubles Building Society surrendered its Massachusetts foreign transmittal agency license, FT5741 by returning the original license certificate to the Division.
  10. On or about October 16, 2012 the Division received information that Doubles Building Society transmitted funds to a foreign country on September 28, 2012 for two Massachusetts consumers.
  11. The receipts indicate that Doubles Building Society was operating from 1077 West Boylston Street, Suite 203 Worcester, Massachusetts, a location for which Doubles Building Society has never obtained a license in Massachusetts.
  12. Additionally, the receipts indicated that the wrong license number was provided, as the Doubles Building Society license number was listed on the receipt as "FT5714" instead of the correct license number of "FT5741."
  13. As a result of information received on or about October 16, 2012, the Division has reason to believe that Doubles Building Society continues to engage in the activity of a foreign transmittal agency in violation of General Laws chapter 169, section 3, and the 2012 Consent Order

    ORDER TO CEASE AND DESIST

  14. After taking into consideration paragraphs 2 through 13 herein, it is hereby:
  15. ORDERED that DOUBLES BUILDING SOCIETY shall immediately cease from engaging directly or indirectly in the business of a foreign transmittal agency at 1078 West Boylston Street, Suite 204, Worcester, Massachusetts or at any other locations in the Commonwealth.
  16. IT IS FURTHER ORDERED that DOUBLES BUILDING SOCIETY shall provide the Division with a complete record of all monies received and transmitted by the Company during the period from June 29, 2012 through the effective date of this ORDER. The records to be produced in accordance with Massachusetts General Laws chapter 169, section 11 shall include, but are not limited to, all bank account records used in the transmittal of funds for individuals, the names and addresses of all individuals or customers for whom funds were transmitted, the names and addresses of all individuals who were involved in the transmission process of money or equivalents to foreign countries, the amount of each transmittal, the transaction numbers, and the total fees charged on each transaction.
  17. IT IS FURTHER ORDERED that DOUBLES BUILDING SOCIETY shall reimburse fees charged to all persons for whom a foreign transmittal of money was executed by the Company between June 29, 2012 and the effective date of this ORDER. Reimbursements shall be made to each person on a per transaction basis in an amount equal to the entire portion of the transmittal fee retained by the Company for such transaction. A record shall be provided to the Division of the names and addresses of all individuals who have deposited money with the Company for the purpose of foreign transmittal, the amount of each transmittal, the transaction numbers, the total fees charged on each transaction, the portion of the transmittal fee retained by DOUBLES BUILDING SOCIETY, check numbers of payments issued by the Company to evidence reimbursements made to consumers, and the amount reimbursed to each individual.

BY ORDER AND DIRECTION OF THE COMMISSIONER OF BANKS:

Dated at Boston, Massachusetts, this 24th day of December, 2012

By:
David J. Cotney
Commissioner of Banks
Commonwealth of Massachusetts