Connecticut Banking Commissioner Jorge L. Perez has ordered Parking Revenue Recovery Service to stop collecting parking violation fees in the state without a license, refund amounts collected from Connecticut consumers with interest, and pay a $30,000 civil penalty.
The Findings of Fact, Conclusions of Law and Order concludes a contested case that began with a temporary cease-and-desist order issued July 1, 2025. The Department of Banking had sought a $200,000 penalty.
The Colorado-based company provides parking compliance services to lot operators across North America. Under a June 2023 contract covering a lot at 85 Whitney Avenue in New Haven, the company held an exclusive license to enforce lot rules and paid the owners 40% of adjusted gross revenue plus $7.50 for each violation fee collected.
The case stemmed from an August 2023 consumer complaint. A Connecticut resident reported receiving two notices seeking $89.50 each after his daughter parked at the lot on consecutive Sundays without paying. The unpaid parking fees were $6 and $12. Each notice identified the company as “issuer/creditor.”
The company argued that violation fees are distinct from parking fees and arise from a contract formed by posted signage, making it an original creditor rather than a collection agency. It also claimed a statutory exemption for loan and account servicers.
The Commissioner rejected both arguments. Citing the Seventh Circuit’s 2016 decision in Franklin v. Parking Revenue Recovery Services and a 2003 Washington federal court ruling in Hansen v. Ticket Track, the order found that violation fees are obligations arising from a consumer transaction and would not exist but for nonpayment of the parking fee. The order stated that substance and economic reality, not labels, determine whether a transaction falls under remedial consumer statutes.
The order also found the company failed to show it had engaged a third-party collector when the notices were sent. A master collection agreement entered into evidence was dated November 2023, after the July 2023 notices.
On the fee violation, the order found the $89.50 charges exceeded the 15% cap on collection fees, which would have limited the charges to $0.90 and $1.80.
