REYNOLDS, J.
Proceeding pursuant to article 78 of the CPLR to review a determination of the respondent, the Commissioner of Motor Vehicles, which ordered a 45-day suspension of petitioner's registration as an automobile dealer pursuant to section 415 Veh. Traf. of the Vehicle and Traffic Law. This case must be remitted for further findings. First the Commissioner's "Order of Suspension" states as the basis for suspension only "Failure to comply with rules and regulations of the Commissioner and violation of Section 417 Veh. Traf. of the Vehicle and Traffic Law." This terse statement is clearly not an adequate finding upon which to predicate intelligent judicial review ( Matter of Englert v. Hults, 22 A.D.2d 712; Matter of Moudis v. Macduff, 286 App. Div. 485) and under section 415 it is incumbent on the Commissioner to make findings of his own or at least adopt the findings of the hearing officer (compare Vehicle and Traffic Law, § 510). Here there was a finding that the certificate falsely represented adequate brakes when in fact such were dangerously defective but made no finding that petitioner in fact knew that the brakes were defective when it issued the certificate. Accordingly, a determination of the factual dispute centered on this essential question should be rendered on remand. Upon remittal, the respondent should also reconsider the measure of punishment imposed. We believe suspension in excess of 20 days is excessive under any view of the evidence. Determination annulled, with costs to petitioner, and matter remitted to the Commissioner of Motor Vehicles in accordance with the decision herein. Gibson, P.J., Herlihy, Reynolds, Staley, Jr., and Gabrielli, JJ., concur in memorandum by Reynolds, J.