Bulletin # 3133 - Week Ending March 8, 2024

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.

CONSUMER CREDIT DIVISION ACTIVITY 

Notice of Automatic Suspension, Notice of Intent to Revoke Mortgage Lender License, Notice of Intent to Issue Order to Cease and Desist and Notice of Intent to Impose Civil Penalty

On February 26, 2024, the Commissioner issued a Notice of Automatic Suspension, Notice of Intent to Revoke Mortgage Lender License, Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing (“Notice”) in the Matter of: HOMETOWN LENDERS, INC. (NMLS # 65084) (“Respondent”), Huntsville, Alabama. The Notice was the result of an investigation by the Consumer Credit Division. The Commissioner alleges in the Notice that: (1) Respondent failed to maintain the minimum tangible net worth of Two Hundred Fifty Thousand Dollars ($250,000) required pursuant to Section 36a-488(a)(1)(A) of the Connecticut General Statutes; (2) Respondent failed to file with the Nationwide Multistate Licensing System and Registry (“NMLS”) or otherwise notify the Commissioner of the decrease in its tangible net worth from the minimum amount required pursuant to Section 36a-488(a)(1)(A) of the Connecticut General Statutes not later than the requisite fifteen (15) days of its occurrence, in violation of Section 36a490(c)(9) of the Connecticut General Statutes; (3) Respondent failed to designate a qualified individual who meets the requirements set forth in Section 36a-488(a)(1)(B) of the Connecticut General Statutes within thirty (30) days of a vacancy in the position; and (4) Respondent failed to file with NMLS or otherwise notify the Commissioner of the revocations of its licenses not later than the requisite fifteen (15) days of their occurrence, in violation of Section 36a 490(c)(3) of the Connecticut General Statutes. Respondent was afforded an opportunity to request a hearing with regard to the allegations set forth in the Notice.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

Keenan, LLC d/b/a Keenan Financial (CRD No. 285673)

On March 8, 2024, the Banking Commissioner entered a Consent Order (No. CO-24-202350-S) with respect to Keenan, LLC d/b/a Keenan Financial of 11 Beacon Street, 13th Floor, Boston, Massachusetts 02108. The firm is currently registered as an investment adviser with the Securities and Exchange Commission. The Consent Order alleged that, prior to becoming registered with the SEC, the firm violated Section 36b-6(c)(1) of the Connecticut Uniform Securities Act by transacting business as an unregistered investment adviser, and violated Section 36b-6(c)(3) of the Act by engaging an unregistered investment adviser agent.

The Consent Order directed the firm to cease and desist from regulatory violations and to remit $5,590 to the department. Of that amount, $5,000 constituted an administrative fine and $590 represented registration fees not previously paid.

      Dated:  Tuesday, March 12, 2024

      Jorge L. Perez
      Banking Commissioner