Bulletin # 2344
Week Ending January 23, 2009

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 Howard F. Pitkin, Banking Commissioner, at the Connecticut Department of Banking, 260 Constitution Plaza, Hartford, CT 06103-1800 or via E-mail. Written comments will be considered only if they are received within ten days from the date of this bulletin.

On January 15, 2009, the Commissioner entered a Consent Order with respect to Casimir Capital L.P., a Connecticut-registered broker-dealer located at 546 Fifth Avenue, Fifth Floor, New York, New York.  The Consent Order acknowledged Casimir Capital L.P.’s representation that the firm had decided in the summer of 2008 to cease retail securities brokerage operations, and that such operations had, in fact, ceased.

The Consent Order alleged that the firm 1) violated Section 36b-6 of the Connecticut Uniform Securities Act by employing at least one unregistered agent; 2) violated Section 36b-16 of the Act by selling non-exempt, unregistered securities in the state; 3) in contravention of FINRA Rule 1031, employed unregistered “cold callers” who pre-qualified customers; 4) failed to exercise adequate supervisory controls over its agents; and 5) failed to keep accurate books and records.

The Consent Order directed the firm to cease and desist from regulatory violations and required that it pay $15,000 to the department.  Of that amount, $12,500 constituted an administrative fine and $2,500 represented reimbursement for the Division’s investigative costs.  The Consent Order also required that the firm provide the department with at least thirty days advance written notice before the firm reestablished retail brokerage operations and conducted solicited, retail brokerage business in the accounts of Connecticut customers.

On January 20, 2009, the Commissioner entered a Consent Order with respect to Laidlaw & Company (UK) Ltd. f/k/a Sands Brothers International Ltd. of 41 Dover Street, London, England.  The firm had been a signatory to a November 29, 2004 Consent Order Conditioning Registration as an Investment Adviser Agent and Restricting Securities-Related Activities involving Martin Scott Sands, then a broker-dealer agent of Laidlaw & Company (UK) Ltd.'s predecessor and an investment adviser agent of Sands Brothers Asset Management LLC.  The 2004 Consent Order obligated Laidlaw & Company (UK) Ltd. to file periodic reports with the agency concerning disciplinary matters involving Martin Scott Sands.

On May 18, 2007, the Commissioner issued an Order to Cease and Desist, Notice of Intent to Fine and Notice of Intent to revoke Laidlaw & Company (UK) Ltd.’s Connecticut broker-dealer registration.  The May 18, 2007 action alleged that Laidlaw & Company (UK) Ltd. violated the 2004 Consent Order as well as Section 36b-23 of the Connecticut Uniform Securities Act by filing incomplete or inaccurate reports with the department regarding Martin Sands’ disciplinary background.

The January 20, 2009 Consent Order resolved the matters alleged in the May 18, 2007 Order to Cease and Desist, Notice of Intent to Fine and Notice of Intent to revoke the firm’s broker-dealer registration.  The 2009 Consent Order fined the firm $50,000 and required that it reimburse the department an additional $10,000 for investigative costs for a total of $60,000.  In addition, the 2009 Consent Order required that the firm retain an independent consultant to conduct semi-annual reviews of the firm’s supervisory procedures for two years.  The 2009 Consent Order also directed the firm to cease and desist from regulatory violations.

On January 21, 2009, the Commissioner entered a Consent Order with respect to Chapin, Davis, Inc., an applicant for broker-dealer registration located at 2 Village Square, Suite 200, Baltimore, Maryland.  The Consent Order alleged that, from at least July, 2003 forward, the firm 1) violated Section 36b-6(a) of the Connecticut Uniform Securities Act by effecting securities transactions for multiple Connecticut customers at a time when the firm was not registered as a broker-dealer in Connecticut; and 2) employed multiple unregistered agents in contravention of Section 36b-6(b) of the Act.

The Consent Order required that the firm remit $12,500 to the department.  Of that amount, $9,500 constituted an administrative fine, $1,500 represented past due registration fees; and $1,500 represented reimbursement for agency investigative costs.  In addition, the Consent Order directed the firm to implement revised supervisory procedures to improve regulatory compliance and to refrain from regulatory violations.

Chapin, Davis, Inc. became registered as a broker-dealer in Connecticut on January 22, 2009.

       Dated:  Wednesday, January 27, 2009