Global Fidelity, LLC; The Office of Financial Regulation (Consumer Finance) received a Petition for declaratory statement from Global Fidelity LLC. Global Fidelity LLC is considering providing services under contract to two foreign companies. These ...

 

DEPARTMENT OF FINANCIAL SERVICES

Finance

NOTICE IS HEREBY GIVEN that the Office of Financial Regulation has declined to rule on the petition for declaratory statement filed by Global Fidelity, LLC on January 3, 2017. The following is a summary of the agency's declination of the petition:

The Office of Financial Regulation (Consumer Finance) received a Petition for declaratory statement from Global Fidelity LLC. Global Fidelity LLC is considering providing services under contract to two foreign companies. These two foreign companies (the “Foreign Entities”) market services to military and government personnel based overseas; such services facilitate payments from the personnel’s US bank accounts to foreign vendors/merchants. For example, if a military officer rents an apartment or purchases a car overseas, the service provided by the Foreign Entities would facilitate their overseas car payments, rent payments, cable, etc. While the Foreign Entities market payment services to personnel in Europe and Asia, Petitioner’s only customers would be the two Foreign Entities. Petitioner would serve an administrative function in the U.S. for such Foreign Entities and would not offer, market or sell services to any other persons, nor would it interact directly with any consumer. The petitioner sought a declaratory statement on whether Petitioner’s proposed activities as an administrative service provider for the Foreign Entities would require licensing. On March 10, 2017 the Office issued a Final Order. The facts provided in the Petition are inadequate for the Office to make a determination whether Petitioner's proposed activities would require a money services business license.

A copy of the Order Declining of the Petition for Declaratory Statement may be obtained by contacting Agency Clerk, Office of Financial Regulation, P.O. Box 8050, Tallahassee, Florida 32314-8050, [phone], [e-mail], or online at:

https://real.flofr.com/ConsumerServices/SearchLegalDocuments/LDSearch.aspx#/searchLegalDocuments. Please refer all comments to: Agency Clerk, Office of Financial Regulation, P.O. Box 8050, Tallahassee, Florida 32314-8050, [phone], [e-mail].