The Department of Banking News Bulletin 

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 business days from the date of this bulletin.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

ARO Equity, LLC, Thomas David Renison (CRD No. 1863759) and Thomas James Renison (CRD No. 6039707) – Order to Cease and Desist, Order to Make Restitution, Notice of Intent to Fine and Notice of Right to Hearing Issued

On January 9, 2020, the Banking Commissioner issued an Order to Cease and Desist, Order to Make Restitution, Notice of Intent to Fine and Notice of Right to Hearing (Docket No. CRF-19-8426-S) against Thomas David Renison (the “Senior Renison”) of South Glastonbury, Connecticut, Renison’s son, Thomas James Renison (the “Junior Renison”), also of Glastonbury, and ARO Equity, LLC of 41 Pine Street, #17, Peabody, Massachusetts 01960. ARO Equity, LLC was a self-described “private investment fund” investing in small to medium business ventures. Among those ventures was a now-defunct Massachusetts electronics manufacturing company, a construction company and a healthcare company. The Senior Renison was an undisclosed principal of ARO Equity, LLC and the Junior Renison was a member and owner of the fund.

The action noted that the Senior Renison had been the subject of an October 22, 2012 Consent Order by the State of Maine Office of Securities; a June 2, 2011 federal criminal complaint alleging mail/wire fraud; a May 19, 2013 State of Connecticut Insurance Department Stipulation and Consent Order; a July 3, 2014 Securities and Exchange Commission Order Instituting Administrative Proceedings; and an August 13, 2014 Consent Order issued by the State of Florida Department of Financial Services. On February 11, 2019, the Junior Renison had been barred by FINRA from association with any FINRA member. The action added that, due to the Senior Renison’s disciplinary history, his involvement in ARO Equity, LLC was intentionally concealed.

The action alleged that from approximately August 2015, ARO Equity, LLC and the Senior Renison violated Section 36b-16 of the Connecticut Uniform Securities Act by offering and selling over $5.8 million of unregistered “fixed rate promissory notes” purportedly paying returns ranging from 8% to 12% to investors in Connecticut, Massachusetts, Tennessee and New Jersey. Many of those investors were elderly retirees who tapped their retirement savings to make the investments. The action also alleged that the Senior Renison transacted business as an unregistered agent of issuer in violation of Section 36b-6 of the Act.

In addition, the action alleged that ARO Equity, LLC and the Senior Renison violated the antifraud provisions in Section 36b-4(a) of the Act by failing to disclose, among other things 1) that, contrary to respondents’ representations concerning the use of investment proceeds, investor monies were really being used to pay off earlier investors as well as ARO Equity, LLC’s business expenses and the Senior Renison’s personal expenses; 2) the specific risk factors related to the investments; 3) the Senior Renison’s prior disciplinary history; and 4) the precise business and operating history of ARO Equity, LLC and its affiliates, including financial information on the respondents. The action also alleged that the Junior Renison materially aided the foregoing antifraud violations.

The action also alleged that the Junior Renison violated Section 36b-23 of the Act by making materially false or misleading statements in filings made with the Commissioner. More specifically, at the time the Junior Renison was registered as a broker-dealer agent in Connecticut, the Junior Renison failed to disclose his involvement with ARO Equity, LLC and the related compensation he received.

The action sought the entry of a permanent Order to Cease and Desist and a fine against all respondents and a restitutionary order against respondents ARO Equity, LLC and the Senior Renison. The respondents were afforded an opportunity to request a hearing on the allegations in the action.