On November 16, 2009, the Banking Commissioner entered an Order Imposing Fine against Resilient Partners, LLC of 318 North Carson Street, Suite 208, Carson City, Nevada, and Carlos M. Garcia, III of 143 Ironwood Road, Guilford, Connecticut.  Resilient Partners, LLC managed Paramount Equity Partners, LLC, an investment fund located in Connecticut and Nevada.  Carlos M. Garcia, in turn, was a member and manager of both Resilient Partners, LLC and Paramount Equity Partners, LLC.  The respondents had been the subject of a July 1, 2009 Order to Cease and Desist, Notice of Intent to Fine and Notice of Right to Hearing which was subsequently amended on July 23, 2009.  The July 23, 2009 and July 1, 2009 actions had alleged that, at various times between August 2002 and October 10, 2005, Resilient Partners, LLC, through respondent Garcia, rendered investment advisory services to Paramount Equity Partners, LLC and others at a time when 1) Resilient Partners, LLC was not registered as an investment adviser under the Connecticut Uniform Securities Act; and 2) Carlos M. Garcia was not registered as an investment adviser agent in Connecticut.  Since Resilient Partners, LLC and Carlos M. Garcia, III had not requested a hearing on the Amended and Restated Order to Cease and Desist, the Amended and Restated Order to Cease and Desist became permanent as to each of them on August 18, 2009 and August 12, 2009, respectively.

Since neither respondent appeared at the hearing on the Notice of Intent to Fine, the allegations against each respondent were deemed admitted under Section 36a-1-31(b) of the Regulations of Connecticut State Agencies.  Accordingly, the Commissioner found that, in transacting business as an unregistered investment adviser and engaging an unregistered investment adviser agent, Resilient Partners, LLC committed ten violations of Section 36b-6(c) of the Connecticut Uniform Securities Act, resulting in the imposition of a $1 million fine against Resilient Partners, LLC.  The Commissioner also found that, in transacting business as an unregistered investment adviser agent, Carlos M. Garcia, III committed nine violations of Section 36b-6(c)(2) of the Act, resulting in the imposition of a $900,000 fine against respondent Garcia.

       Dated:  Tuesday, November 24, 2009