In the latter half of last year, a Connecticut law went into effect enabling the Banking Commissioner to provide certain legally required notices to licensees by email. The Commissioner may electronically send both compliance letters (which are prerequisite to commencement of an administrative action to revoke or refuse to renew a license under the Administrative Procedures Act), and notices commencing administrative actions under title 36A of the Banking Law to cease and desist, to impose a civil penalty, and to revoke or refuse to renew a license. For company licensees, electronic notices constitute valid notice when sent by the agency to the individuals designated as primary contacts in the contact employee fields on the NMLS. For individual licensees, electronic notices constitute valid notice when sent to the email address identified by said individual on the system. Notices are deemed received on the earlier of the date of actual receipt by any individual to whom such notice was sent, or seven days after sending. As all consumer credit industries utilize the NMLS in Connecticut for licensure, it is imperative that licensees: (1) keep relevant email addresses up to date on the NMLS; and (2) ensure that such emails are monitored regularly.
