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  State of Minnesota Department of Commerce vs Mediator Law Group, PC
  

  Commissioner of Commerce Grace Arnold (Commissioner) has determined as follows:

  
  

  1. The Commissioner has advised Mediator Law Group, PC (Respondent) that she is
  
  prepared to commence formal action pursuant to Minn. Stat. § 45,027 (2022), and other applicable law,
  
  based on the following allegations:

  
  

  a. Respondent engaged in unregistered debt settlement services activity in violation of
  
  Minn. Stat. § 3328.04 (2022).
  
  b. Respondent's contracts do not include required disclosures in violation of Minn. Stat.
  
  § 3328.06, subd. 4 (2022).
  
  c. Respondent's contracts allows for Respondent to terminate the agreement at any time
  
  by written notice in violation of Minn. Stat. § 3328,07, subd. 4(a) (2022).
  
  d. Respondent contracts for fees at a rate of 29 percent of the balance of all debts
  
  enrolled in its debt settlement program in violation of Minn. Stat. § 332B.09, subd. 2(1)
  
  (2022).

  
  

  2. Respondent acknowledges that they have been advised of the right to a hearing in this
  
  matter, to present argument to the Commissioner, and to appeal from any adverse determination after a
  
  hearing. Respondent hereby expressly waives those rights. Respondent further acknowledges that they
  
  have been represented by legal counsel throughout these proceedings or has waived that right.

  
  

  3. Respondent has agreed to informal disposition of this matter without a hearing.
  
  For purposes of Minn. Stat. § 16D.17 (2022), Respondent expressly waives the right to
  
  any notice or opportunity for a hearing on any civil penalty imposed by the Commissioner. Further, Minn.
  
  Stat. § 16D.17 (2022) allows the Commissioner to file and enforce the civil penalty imposed by this Order
  
  as a judgment against Respondent in district court without further notice or additional proceedings.

  
  

  4. For purposes of Minn. Stat. § 16D.17 (2022), Respondent expressly waives the right to
  
  any notice or opportunity for a hearing on any civil penalty imposed by the Commissioner. Further, Minn.
  
  Stat. § 16D.17 (2022) allows the Commissioner to file and enforce the civil penalty imposed by this Order
  
  as a judgment against Respondent in district court without further notice or additional proceedings.

  
  

  5. The civil penalty and/or any resulting judgment arising from this Order will be nondischargeable
  
  in any bankruptcy proceeding. See 11 U.S.C. 523 (a)(7) ("A discharge under section 727,
  
  1141, 1228(a), 1228(b) or 1328(b) of this title does not discharge an individual debtor from any debt... to
  
  the extent such debt is for a fine, penalty, or forfeiture payable to and for the benefit of a governmental
  
  unit, and is not compensation for actual pecuniary loss, other than a tax penalty...").

  
  

  6. The following Order is in the public interest.
  
  NOW, THEREFORE, IT IS HEREBY ORDERED, pursuant to Minn. Stat. Ch. 45 (2022) that:
  
  A. Respondent shall pay a civil penalty in the amount of $10,000 to the State of Minnesota.
  
  The Commissioner has stayed $5,000 of this penalty. The stayed portion of the civil
  
  penalty may be lifted if Respondent commits further violations of any law, rule, or order
  
  related to the duties and responsibilities entrusted to the Commissioner. If the
  
  Commissioner determines that Respondent has committed further violations of any law,
  
  rule, or order over which the Commissioner has authority, the stay shall be lifted and the
  
  stayed portion of the penalty shall become effective in addition to any additional
  
  administrative action the Commissioner deems appropriate for the new violation(s). If
  
  the Commissioner seeks to lift the stay, Respondent may request a hearing to challenge
  
  the factual basis for lifting the stay, but may not challenge the amount of the stayed
  
  penalty. If the stay has not been lifted by August 8, 2027, the stayed portion of the civil
  
  penalty will be vacated.
  
  B. Respondent shall cease and desist from violating any laws, rules, or orders related to the
  
  duties and responsibilities entrusted to the Commissioner under Minnesota Statute
  
  Chapters 332B and
  
  C. Respondent shall pay all investigative costs in the amount of $315.00 at the time the
  
  Consent to Entry of Order is signed pursuant to Minn. Stat. § 45.027, subd. 1(8) (2022).
  
  This Order shall be effective upon signature by or on behalf of the Commissioner.