The Department of Banking News Bulletin 

Bulletin # 1987
Week Ending March 22, 2002

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 John P. Burke, Commissioner of Banking, at the Connecticut Department of Banking, 260 Constitution Plaza, Hartford, CT 06103-1800 or via E-mail to john.burke@ct.gov. Written comments will be considered only if they are received within ten days from the date of this bulletin.

BRANCH ACTIVITY
State Bank Activity

Section 36a-145 of the Connecticut General Statutes requires that each application for a branch, or for a limited branch at which loans will be made, be accompanied by a plan detailing how adequate services to meet the banking needs of all community residents will be provided. Plans are submitted when such applications are filed and are available for public inspection and comment at this Department for a period of 30 days. Questions concerning branch activity should be directed to the Bank Examination Division, (860) 240-8180.
Note: dates are listed in month/day/year format.

NOTICE OF INTENT TO AMEND REGULATIONS

Pursuant to Section 4-168(a) of the Connecticut General Statutes, the Commissioner is issuing a Notice of Intent to Amend Regulations concerning foreign banks. A copy of the proposed regulations is attached.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY
Investment Adviser Assessed $2,100 for Failing
to Make Investment Advisory Notice Filing

On March 19, 2002, the Commissioner entered into a Stipulation and Agreement with respect to Bridgewater Associates Inc., an SEC-regulated investment adviser located at One Glendinning Place, Westport, Connecticut. The Stipulation and Agreement was based on allegations that, from 1997 until February 12, 2002, the firm failed to make the notice filing required of SEC-regulated investment advisers by Section 36b-6(e) of the Connecticut Uniform Securities Act.

Pursuant to the Stipulation and Agreement, the firm agreed to remit $2,100 to the Department. Of that amount, $1,500 constituted an administrative fine and $600 represented reimbursement for past due notice filing fees.

Investment Adviser Assessed $1,450 for
Delinquent Investment Advisory Notice Filing

On March 19, 2002, the Commissioner entered into a Stipulation and Agreement with Henderson Global Investors (North America) Inc., an SEC-regulated investment adviser located at One Financial Plaza, 19th Floor, Hartford, Connecticut. The Stipulation and Agreement alleged that, from April 1999 until February 28, 2001, the firm failed to make the notice filing required of SEC-regulated investment advisers by Section 36b-6(e) of the Connecticut Uniform Securities Act.

Pursuant to the Stipulation and Agreement, the firm agreed to implement such supervisory and compliance procedures as were necessary to ensure compliance with state notice filing requirements. In addition, Henderson Global Investors (North America) Inc. agreed to pay $1,450 to the Department. Of that amount, $1,000 constituted an administrative fine and $450 represented reimbursement for past due notice filing fees.

Investment Adviser Assessed $4,550 for
Failure to Make Investment Advisory Notice Filing

On March 19, 2002, the Commissioner entered into a Stipulation and Agreement with Touchstone Capital, LLC of 411 West Putnam Avenue, Greenwich, Connecticut. The firm had been registered as an investment adviser with the Securities and Exchange Commission from February 24, 1999 until June 29, 2001, and had applied for registration under the Connecticut Uniform Securities Act when the amount of its assets under management no longer met federal eligibility requirements. The Commissioner alleged that, between February 24, 1999 and June 29, 2001, the firm failed to make the notice filing required of SEC-regulated investment advisers by Section 36b-6(e) of the Act, and failed to remit the associated fees.

Pursuant to the Stipulation and Agreement, the firm agreed to pay $4,550 to the Department. Of that amount, $3,500 constituted an administrative fine, $500 represented reimbursement for agency investigative costs, and $550 represented reimbursement for past due notice filing fees for calendar years 1999, 2000 and 2001.

Touchstone Capital, LLC became registered as an investment adviser under the Act on March 19, 2002.

Notice of Intent to Amend Regulations

     In accordance with Section 4-168(a) of the Connecticut General Statutes, and by the authority granted in Section 36a-428c of the Connecticut General Statutes, notice is hereby given that the Commissioner of Banking intends to amend regulations concerning foreign banks.

Text of Proposed Regulations:

Section 1. Section 36a-428c-1 of the Regulations of Connecticut State Agencies is amended to read as follows:

     The definitions contained in section 36a-2 of the general statutes shall govern the interpretation of sections 36a-428-1 to 36a-428n-1, inclusive, of the Regulations of Connecticut State Agencies. In addition thereto and except as otherwise required by context, as used in sections 36a-428-1 to 36a-428n-1, inclusive, OF THE REGULATIONS OF CONNECTICUT STATE AGENCIES:
     (a) "Adjusted liabilities" means all liabilities of a foreign bank appearing in the books, accounts and records of its licensed state agencies and licensed state branches as liabilities of such agencies and branches, including acceptances and such other liabilities, including contingent liabilities, as the commissioner shall determine, but excluding amounts due and other liabilities to other offices, agencies, branches and affiliates of such foreign bank, including unremitted profits.
     (b) "Deposit assets" means:
     (1) United States dollar deposits payable in the United States, other than certificates of deposit;
     (2) bonds, notes, debentures, or other obligations of the United States, or any agency or instrumentality thereof, or guaranteed by the United States, or of this state or of a county, city, town, village, school district, or instrumentality of this state or guaranteed by this state;
     (3) bonds, notes, debentures or other obligations issued by the Federal Home Loan Mortgage Corporation and by the Federal National Mortgage Corporation;
     (4) commercial paper payable in dollars in the United States, provided such paper is rated in one of the three highest rating categories by a rating service recognized by the commissioner. In the event that an issue of commercial paper is rated by more than one recognized rating service, it shall be rated in one of the three highest rating categories by each such rating service;
     (5) negotiable certificates of deposit that are payable in the United States and issued by: (A) an unaffiliated bank or out-of-state bank other than a foreign bank, or (B) a domestic office of an unaffiliated foreign bank PROVIDED SUCH CERTIFICATES OF DEPOSIT ARE OF EQUAL RANK WITH OTHER SENIOR LIABILITIES OF THE FOREIGN BANK AND ARE NOT SUBORDINATED IN PAYMENT TO ANY OTHER LIABILITIES OF THE FOREIGN BANK;
     (6) bankers' acceptances that are payable in the United States and issued by: (A) an unaffiliated bank or out-of-state bank other than a foreign bank, or (B) a domestic office of an unaffiliated foreign bank PROVIDED SUCH BANKERS' ACCEPTANCES ARE OF EQUAL RANK WITH OTHER SENIOR LIABILITIES OF THE FOREIGN BANK AND ARE NOT SUBORDINATED IN PAYMENT TO ANY OTHER LIABILITIES OF THE FOREIGN BANK AND THE METHOD AND MANNER OF REPAYMENT IS REFLECTED IN SUCH BANKERS' ACCEPTANCES;
     (7) reserves held at a Federal Reserve Bank; and
     (8) such other assets as determined by the commissioner upon written application. If the commissioner determines that an asset which otherwise qualifies under this section shall be valued at less than the amount otherwise provided in this section, the commissioner shall so notify the foreign bank which shall thereafter value such asset as directed by the commissioner.
     (c) "Depository" means a Connecticut bank, federal bank, or the Federal Reserve Bank of New York or Boston.
     (d) "Eligible assets" means any assets payable in the United States, or in United States funds, or with the prior approval of the commissioner, in funds freely convertible into United States funds, reduced by the amount of any specifically allocated reserves established on the books in connection with such assets, held in this state and recorded on the general ledger of a licensed state branch and licensed state agency of the foreign bank, subject to the following:
     (1) marketable debt securities shall be allowed at their principal amount or market value, whichever is lower;
     (2) restructured foreign debt bonds backed by United States Treasury obligations commonly known as "Brady Bonds", whether carried on the books of the licensed state branch or licensed state agency as loans or securities, shall be allowed at their book value or market value, whichever is lower;
     (3) equity securities shall be ineligible;
     (4) the balance from time to time of any assets classified loss, doubtful or substandard at the preceding examination by the commissioner, any other regulatory agency, outside accountants or the bank's internal loan review staff, shall be ineligible to the extent of [100 percent, 50 percent and 20 percent] ONE HUNDRED PER CENT, FIFTY PER CENT AND TWENTY PER CENT, respectively. Assets classified value impaired shall be ineligible to the extent of [100 percent] ONE HUNDRED PER CENT of the amount of allocated transfer risk reserve which would be required by the appropriate federal banking regulatory agency for such exposure at a domestically chartered bank and [20 percent] TWENTY PER CENT of any residual exposure. For assets classified at the preceding examination by the commissioner or any other regulatory agency, if the deficiency or defect giving rise to the classification shall be removed subsequent to the examination, the department shall, upon written request supported by appropriate documentation, reconsider the classification;
     (5) accrued income on assets classified loss, doubtful, substandard or value impaired shall be ineligible;
     (6) the balance from time to time of any other asset or asset category disallowed at the preceding examination or by direction of the commissioner for any other reason shall be treated as ineligible until the underlying reasons for the disallowance have been removed;
     (7) all amounts due from the home office, other offices and affiliates, including income accrued but uncollected on such amounts, shall be ineligible, except that with the commissioner's prior approval, all amounts due from other offices located within the United States shall be considered eligible;
     (8) precious metals shall be considered eligible to the extent of [75 percent] SEVENTY-FIVE PER CENT of the market value;
     (9) prepaid expenses and unamortized costs, furniture and fixtures and leasehold improvements shall be ineligible;
     (10) real estate located in this state and carried on the accounting records as an asset shall be considered eligible at net book value or appraised value, whichever is less.
     (e) "FRB" MEANS BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM.
     [(e)] (f) "Licensed state agency" means a state agency of a foreign bank licensed pursuant to section 36a-428a of the general statutes.
     [(f)] (g) "Licensed state branch" means a state branch of a foreign bank licensed pursuant to section 36a-428a of the general statutes.
     [(g)] (h) "Licensed representative office" means a representative office of a foreign bank licensed pursuant to section 36a-428g of the general statutes.
     (i) "ROCA" MEANS RISK MANAGEMENT, OPERATION CONTROLS, COMPLIANCE AND ASSET QUALITY, THE RATING SYSTEM USED BY THE FRB, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY AND STATE BANKING REGULATORY AUTHORITIES TO ASSESS THE CONDITION OF A BRANCH OR AGENCY, OR A COMMERCIAL LENDING SUBSIDIARY OF A FOREIGN BANK IN THE UNITED STATES; AND
     (j) "SOSA" MEANS STRENGTH OF SUPPORT ASSESSMENT, THE RATING SYSTEM USED BY THE FRB TO ASSESS A FOREIGN BANK'S ABILITY TO PROVIDE FINANCIAL, LIQUIDITY AND MANAGEMENT SUPPORT TO ITS UNITED STATES OPERATIONS.

Sec. 2. Section 36a-428c-4 of the Regulations of Connecticut State Agencies is amended to read as follows:

     (a) A foreign bank with a licensed state branch or licensed state agency shall keep deposit assets on deposit in accordance with section 36a-428c-6 of the Regulations of Connecticut State Agencies [, in an amount, based upon the lower of principal amount or market value, equal to the greater of (1) three percent of adjusted liabilities, excluding liabilities of international banking facilities maintained by such branches and agencies; (2) one percent of adjusted liabilities; or (3) $1 million.] AS FOLLOWS:
     (1) IF AT THE TIME THE FOREIGN BANK FILED ITS APPLICATION TO ESTABLISH THE LICENSED STATE BRANCH OR LICENSED STATE AGENCY, IT DID NOT HAVE AN EXISTING BRANCH OR AGENCY IN THE UNITED STATES: (A) FOR THE FIRST THREE YEARS THAT THE FOREIGN BANK MAINTAINS THE LICENSED STATE BRANCH OR LICENSED STATE AGENCY, AN AMOUNT, BASED UPON THE LOWER OF PRINCIPAL AMOUNT OR MARKET VALUE, EQUAL TO THE GREATER OF ONE MILLION DOLLARS, OR TWO PER CENT OF ADJUSTED LIABILITIES; AND (B) THEREAFTER, AN AMOUNT, BASED UPON THE LOWER OF PRINCIPAL AMOUNT OR MARKET VALUE, EQUAL TO THE GREATER OF ONE MILLION DOLLARS, OR TWO PER CENT OF ADJUSTED LIABILITIES UP TO A MAXIMUM OF ONE HUNDRED MILLION DOLLARS, PROVIDED SUCH AMOUNT SHALL BE SUBJECT TO ADJUSTMENT AS PROVIDED IN SUBSECTION (b) OF THIS SECTION;
     (2) IF THE FOREIGN BANK MAINTAINS IN THE UNITED STATES A BRANCH OR AGENCY THAT HAS NOT BEEN ENGAGED IN BANKING BUSINESS CONTINUOUSLY IN THE FOUR YEARS PRECEDING THE FILING OF THE APPLICATION BY THE FOREIGN BANK TO ESTABLISH THE LICENSED STATE BRANCH OR LICENSED STATE AGENCY: (A) FOR THE FIRST THREE YEARS THAT THE FOREIGN BANK MAINTAINS THE LICENSED STATE BRANCH OR LICENSED STATE AGENCY, OR THE FIRST FOUR YEARS THAT THE FOREIGN BANK MAINTAINS IN THE UNITED STATES A BRANCH OR AGENCY THAT HAS BEEN ENGAGED IN BANKING BUSINESS CONTINUOUSLY, WHICHEVER PERIOD IS SHORTER, AN AMOUNT, BASED UPON THE LOWER OF PRINCIPAL AMOUNT OR MARKET VALUE, EQUAL TO THE GREATER OF ONE MILLION DOLLARS, OR TWO PER CENT OF ADJUSTED LIABILITIES, AND (B) THEREAFTER, AN AMOUNT, BASED UPON THE LOWER OF PRINCIPAL AMOUNT OR MARKET VALUE, EQUAL TO THE GREATER OF ONE MILLION DOLLARS, OR TWO PER CENT OF ADJUSTED LIABILITIES UP TO A MAXIMUM OF ONE HUNDRED MILLION DOLLARS, PROVIDED SUCH AMOUNT SHALL BE SUBJECT TO ADJUSTMENT AS PROVIDED IN SUBSECTION (b) OF THIS SECTION;
     (3) IF THE FOREIGN BANK MAINTAINS IN THE UNITED STATES A BRANCH OR AGENCY THAT HAS BEEN ENGAGED IN BANKING BUSINESS CONTINUOUSLY IN THE FOUR YEARS PRECEDING THE FILING OF THE APPLICATION BY THE FOREIGN BANK TO ESTABLISH THE LICENSED STATE BRANCH OR LICENSED STATE AGENCY, AN AMOUNT, BASED UPON THE LOWER OF PRINCIPAL AMOUNT OR MARKET VALUE, EQUAL TO THE GREATER OF ONE MILLION DOLLARS, OR TWO PER CENT OF ADJUSTED LIABILITIES UP TO A MAXIMUM OF ONE HUNDRED MILLION DOLLARS, PROVIDED THIS AMOUNT SHALL BE SUBJECT TO ADJUSTMENT AS PROVIDED IN SUBSECTION (b) OF THIS SECTION.
     (b) (1) IF ANY OF THE FOLLOWING CRITERIA IS MET, THE COMMISSIONER MAY, IN THE COMMISSIONER'S SOLE DISCRETION, INCREASE THE MAXIMUM AMOUNT OF DEPOSIT ASSETS REQUIRED TO BE KEPT ON DEPOSIT TO FIVE HUNDRED MILLION DOLLARS, AND IF, IN ADDITION, THE ADJUSTED LIABILITIES ARE LESS THAN ONE HUNDRED MILLION DOLLARS, THE COMMISSIONER MAY, IN THE COMMISSIONER'S SOLE DISCRETION, REQUIRE THAT DEPOSIT ASSETS BE KEPT ON DEPOSIT IN THE MINIMUM AMOUNT OF TWO MILLION DOLLARS. IF TWO OR MORE OF THE FOLLOWING CRITERIA ARE MET, THE COMMISSIONER SHALL INCREASE THE MAXIMUM AMOUNT OF DEPOSIT ASSETS REQUIRED TO BE KEPT ON DEPOSIT TO FIVE HUNDRED MILLION DOLLARS, AND IF, IN ADDITION, THE ADJUSTED LIABILITIES ARE LESS THAN ONE HUNDRED MILLION DOLLARS, THE COMMISSIONER SHALL REQUIRE THAT DEPOSIT ASSETS BE KEPT ON DEPOSIT IN THE MINIMUM AMOUNT OF TWO MILLION DOLLARS:
     (A) THE LICENSED STATE BRANCH OR LICENSED STATE AGENCY RECEIVES A ROCA COMPOSITE RATING OF "3-FAIR" AT ITS MOST RECENT EXAMINATION;
     (B) THE FOREIGN BANK'S OPERATIONS IN THE UNITED STATES RECEIVE A ROCA COMPREHENSIVE COMPOSITE RATING OF "3-FAIR" BY THE FRB;
     (C) THE RATING OF ANY OUTSTANDING DEBT ISSUED BY THE FOREIGN BANK IS PLACED ON WATCH FOR A POSSIBLE DOWNGRADE TO BELOW INVESTMENT GRADE, BY A RATING SERVICE RECOGNIZED BY THE COMMISSIONER;
     (D) THE SOVEREIGN RATING OF THE HOME COUNTRY OF THE FOREIGN BANK IS PLACED ON WATCH FOR POSSIBLE BANK DOWNGRADE TO BELOW INVESTMENT GRADE, BY A RATING SERVICE RECOGNIZED BY THE COMMISSIONER;
     (E) THE SOSA RATING OF THE FOREIGN BANK IS "2"; OR
     (F) A FORMAL SUPERVISORY OR ENFORCEMENT ACTION IS ISSUED AGAINST THE FOREIGN BANK IN ANY JURISDICTION.
     (2) IF ANY OF THE FOLLOWING CRITERIA IS MET, THE MINIMUM AMOUNT OF DEPOSIT ASSETS THAT THE FOREIGN BANK SHALL KEEP ON DEPOSIT SHALL BE FIVE MILLION DOLLARS, IF ADJUSTED LIABILITIES ARE LESS THAN TWO HUNDRED FIFTY MILLION DOLLARS AND SHALL BE TWO PER CENT OF ADJUSTED LIABILITIES IF SUCH LIABILITIES ARE TWO HUNDRED FIFTY MILLION DOLLARS OR MORE:
     (A) THE LICENSED STATE BRANCH OR LICENSED STATE AGENCY RECEIVES A ROCA COMPOSITE RATING OF "4-MARGINAL" OR "5-UNSATISFACTORY" AT ITS MOST RECENT EXAMINATION;
     (B) THE FOREIGN BANK'S OPERATIONS IN THE UNITED STATES RECEIVE A ROCA COMPREHENSIVE COMPOSITE RATING OF "4-MARGINAL" OR "5-UNSATISFACTORY" BY THE FRB;
     (C) THE RATING OF ANY OUTSTANDING DEBT ISSUED BY THE FOREIGN BANK IS RATED BELOW INVESTMENT GRADE BY A RATING SERVICE RECOGNIZED BY THE COMMISSIONER;
     (D) THE SOVEREIGN RATING OF THE HOME COUNTRY OF THE FOREIGN BANK IS RATED BELOW INVESTMENT GRADE, BY A RATING SERVICE RECOGNIZED BY THE COMMISSIONER; OR
     (E) THE SOSA RATING OF THE FOREIGN BANK IS "3".
     [(b)] (c) A foreign bank opening its initial licensed state branch or licensed state agency shall keep deposit assets on deposit based upon the branch's or agency's projection of adjusted liabilities at the end of its first year of operation.
     [(c)] (d) If the commissioner determines that the protection of the public interest requires that a foreign bank should keep deposit assets on deposit in an amount greater than that required by [subsection (a) of] this section, the commissioner shall so notify the foreign bank, which shall immediately thereafter keep deposit assets on deposit in such greater amount.
     [(d)] (e) For purposes of this section, liabilities arising from securities repurchase agreements may be excluded from the calculation of adjusted liabilities, to the extent such liabilities are secured by collateral within the meaning of section 36a-428n(i)(2)(D) of the Connecticut General Statutes unless the licensed state branch or licensed state agency has been notified otherwise by the [Commissioner] COMMISSIONER.
     (f) (1) WITH THE APPROVAL OF THE COMMISSIONER, A FOREIGN BANK MAY SATISFY UP TO TWENTY-FIVE PER CENT OF THE AMOUNT THAT SUCH FOREIGN BANK IS REQUIRED TO KEEP ON DEPOSIT IN ACCORDANCE WITH THIS SECTION BY OBTAINING AND RETAINING A FIDELITY INSURANCE BOND FOR SUCH AMOUNT FROM A MONOLINE FIDELITY INSURANCE COMPANY THAT IS LICENSED BY THE INSURANCE DEPARTMENT TO SELL FIDELITY INSURANCE IN CONNECTICUT AND IS RATED IN THE TWO HIGHEST RATING CATEGORIES BY A RATING SERVICE RECOGNIZED BY THE COMMISSIONER. SUCH BOND SHALL BE IN A FORM SATISFACTORY TO THE COMMISSIONER, SHALL NAME THE COMMISSIONER AS THE BENEFICIARY AND PROVIDE THAT THE FIDELITY INSURANCE COMPANY ISSUING THE BOND SHALL MAKE PAYMENT ON THE BOND NOT LATER THAN TWENTY-FOUR HOURS AFTER THE COMMISSIONER PRESENTS AN ORDER TAKING POSSESSION OF THE BUSINESS AND PROPERTY OF THE FOREIGN BANK PURSUANT TO SECTION 36a-428n OF THE CONNECTICUT GENERAL STATUTES. THE FOREIGN BANK SHALL FILE THE FIDELITY INSURANCE BOND AND PROOF OF THE AUTHORITY OF THE FIDELITY INSURANCE COMPANY TO ENGAGE IN BUSINESS IN CONNECTICUT WITH THE COMMISSIONER.
     (2) IF A FIDELITY INSURANCE COMPANY THAT HAS ISSUED A FIDELITY INSURANCE BOND TO A FOREIGN BANK NO LONGER MEETS ANY OF THE REQUIREMENTS OF THIS SUBSECTION, SUCH FOREIGN BANK, NOT LATER THAN FIVE DAYS OF BECOMING AWARE OF THE FAILURE TO MEET SUCH REQUIREMENTS, SHALL NOTIFY THE COMMISSIONER OF SUCH FAILURE, AND OBTAIN A REPLACEMENT FIDELITY INSURANCE BOND FROM A FIDELITY INSURANCE COMPANY THAT MEETS SUCH REQUIREMENTS, OR PLACE ON DEPOSIT ASSETS AS REQUIRED BY THIS SECTION.
     (3) THE COMMISSIONER SHALL REVOKE ANY APPROVAL ISSUED UNDER THIS SUBSECTION IF THE COMMISSIONER DETERMINES THAT THE PROTECTION OF THE PUBLIC INTEREST SO REQUIRES.

Sec. 3. Subsections (f) to (h), inclusive, of Section 36a-428c-6 of the Regulations of Connecticut State Agencies are amended to read as follows:

     (f) Depository to furnish monthly statements of all transactions. The depository shall furnish to the foreign bank, at least once in each calendar month, a statement of all transactions in the special deposit account since the closing date of the previous such statement. The statement shall include a listing of the assets on deposit, as of the closing date of the statement. A copy of such statement shall be simultaneously forwarded by the [foreign bank] DEPOSITORY to the commissioner.
     (g) Depository may pay interest earned upon assets. The depository may pay to the foreign bank interest earned on assets [funds] deposited in accordance with such arrangements as may be made between the depository and the foreign bank. The commissioner is authorized to revoke this provision.
     (h) Responsibility of depository with respect to deposited securities. Except as provided in this subsection, a depository shall hold the securities deposited by a foreign bank under the deposit agreement separate and apart from all other securities and shall permit examination and comparison thereof by duly authorized representatives of the foreign bank or of the commissioner. A depository may utilize a central depository, clearing corporation or book entry system to hold securities deposited pursuant to a deposit agreement, provided the records of the central depository, clearing corporation or book entry system show that the securities are held for the depository as principal, [or as] agent OR CUSTODIAN for its customers. The depository shall maintain adequate records to demonstrate the disposition of such book entry deposits.

     Statement of Purpose: To amend the asset pledge requirements applicable to state branches and state agencies of foreign banks in Connecticut to ensure that there are adequate assets available for creditors in the event of liquidation based on a supervisory assessment of risk factors.

     All interested person who wish to submit data, views or arguments in connection with the proposed amendments to the regulations may do so in writing within thirty (30) days of the publication of this notice in the Connecticut Law Journal. Comments may be submitted to the Commissioner of Banking, Attention: Legal Division, Department of Banking, 260 Constitution Plaza, Hartford, Connecticut 06103-1800.