Bulletin # 2674
This bulletin constitutes the only official notification you will receive from this office concerning any of the following applications. Any observations you may have are solicited. Any comments should be in writing to Jorge L. Perez, Banking Commissioner, Department of Banking, 260 Constitution Plaza, Hartford, CT 06103-1800. Written comments will be considered only if they are received within ten days from the date of this bulletin.
CONSUMER CREDIT DIVISION ACTIVITY
Order to Cease and Desist and Order Imposing Civil Penalty
On May 6, 2015, the Commissioner issued an Order to Cease and Desist and Order Imposing Civil Penalty (“Order”) In the Matter of: Renaissance Legal Group APC a/k/a Renaissance Legal Group, Inc. d/b/a Salvation Law Group (“Salvation Law”), Costa Mesa, California, and Ronny Mor, Esq. (“Mor”) (collectively “Respondents”). The basis of the Order was that each Respondent engaged in debt negotiation in this state without obtaining the required license, in violation of Section 36a-671(b) of the Connecticut General Statutes. Each Respondent was ordered to cease and desist from violating Section 36a-671(b) of the Connecticut General Statutes, and to pay a civil penalty in the amount of $100,000. In addition, an Order of Restitution previously issued against Respondents on March 2, 2015, remains in effect and became permanent against Salvation Law on March 24, 2015 and against Mor on March 25, 2015.
On May 6, 2015, the Commissioner issued an Order to Cease and Desist and Order Imposing Civil Penalty (“Order”) In the Matter of: Mehdi Moarefian d/b/a Green Tree Financial Group a/k/a Greentree Financial Group (“Respondent”), Newport Beach, California. The basis of the Order was that Respondent engaged in debt negotiation in this state without obtaining the required license, in violation of Section 36a-671(b) of the Connecticut General Statutes. Respondent was ordered to cease and desist from violating Section 36a-671(b) of the Connecticut General Statutes, and to pay a civil penalty in the amount of $100,000. In addition, an Order of Restitution previously issued against Respondent on March 2, 2015, remains in effect and became permanent against Respondent March 25, 2015.
SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY
On May 19, 2015, the Banking Commissioner entered a Consent Order (No. CO-15-8221-S) with respect to M.M. Dillon & Co. LLC, a Connecticut-registered broker-dealer located in Greenwich, Connecticut. The Consent Order alleged that the firm violated Section 36b-6(b) of the Connecticut Uniform Securities Act by employing multiple unregistered agents from early 2009 until April 2015. M.M. Dillon & Co. has since taken curative measures to register the affected individuals as agents, with the last individual becoming registered on April 14, 2015. The Consent Order also alleged that the firm violated Section 36b-31-6f of the Regulations under the Act by failing to establish, enforce and maintain an adequate supervisory system.
The Consent Order directed the firm to cease and desist from violative conduct; establish, implement and maintain revised written supervisory procedures; and remit $4,050 to the department. Of that amount, $2,700 constituted an administrative fine and $1,350 represented payment for past due agent registration fees.
Order to Cease and Desist Issued
On May 20, 2015, the Banking Commissioner issued an Order to Cease and Desist and Notice of Right to Hearing (Docket No. CD-15-8202-S) against Greenberg International Law & Tax Advisory (“GILTA”), a purported law firm which held itself out as being located at One Constitution Plaza, Kinsley Street, Hartford, Connecticut. Also named in the Order were Mike James, a Senior Investment Recovery Manager and “broker” at the firm; Robert Dunn, the firm's Senior Tax Attorney; and Richard Fox, Senior Investment Recovery Manager. Online records of the State of Connecticut Judicial Branch do not appear to contain any reference to GILTA.
The Order to Cease and Desist alleged that 1) in or around November, 2014, Mike James, acting on behalf of GILTA, solicited the purchase of High Line securities from a Singapore resident; 2) on December 16, 2014, James communicated to the investor that, although James had sold the High Line securities, the investor would not receive the sales proceeds without paying a $5,200 registration fee to remove restrictions on the shares; 3) the sale was evidenced by a “Sell Confirmation” listing James as broker of record and describing the transaction as being “Brokered by Greenberg International”; and 4) the investor did not pay the registration fee but forwarded the documentation to the Division for investigation.
Similarly, the Order to Cease and Desist alleged that 1) on January 22, 2015, Richard Fox, acting on behalf of GILTA, solicited the purchase of 20,000 shares of Sports Kinetix Corp. from another Singapore resident for a price of $10.88 per share; 2) GILTA would receive a 2% commission or $4,352 on the transaction; 3) the Singapore resident was instructed to direct any questions to “your representative” at the firm’s Connecticut telephone number; 4) contrary to the representations of Fox, on behalf of GILTA, Sport Kinetix Corp. shares were not currently listed and/or traded on a securities exchange; and 5) ironically, the Singapore resident did not own any shares of Sports Kinetix Corp.
In addition, the Order to Cease and Desist alleged that GILTA and Robert Dunn violated Section 36b-23 of the Connecticut Uniform Securities Act by failing to disclose the scope of the firm's transactional activity to the Division. The action also alleged that 1) GILTA transacted business as an unregistered broker-dealer in violation of Section 36b-6(a) of the Act; 2) James and Fox violated Section 36b-6(a) of the Act by transacting business as unregistered agents; and 3) respondents GILTA, James and Fox violated the antifraud provisions in Section 36b-4(a) of the Act.
Each respondent was afforded an opportunity to request a hearing on the allegations in the Order to Cease and Desist.
Dated: Wednesday, May 27, 2015
Jorge L. Perez