The Department of Banking News Bulletin
Bulletin # 3175 - Week Ending December 27, 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 directed to Jorge L. Perez, Banking Commissioner. Written comments will be considered only if they are received within ten business days from the date of this bulletin.
BANK ACTIVITY
Branch Office Relocation
On December 26, 2024, Chelsea Groton Bank (Groton) submitted an application under Section 36a-145 of the Connecticut General Statutes to relocate its branch office from 300 Main Street, Norwich, CT 06360 to 55 Main Street, Norwich, CT 06360. The projected date for the relocation is around June 30, 2025. Questions or comments regarding the application can be sent to the Financial Institutions Division at 860 240-8180.
Main Office Relocation
On December 23, 2024, the Commissioner approved the application by Fieldpoint Private Bank & Trust (Greenwich) to relocate its main from One Greenwich Plaza, Suite A, Second Floor, Greenwich, CT 06830 to 130 Mason Street, Greenwich, CT 06830 pursuant to Section 36a-81 of the Connecticut General Statutes. As part of the move, the bank will operate from the temporary location of 3 Greenwich Off Park, Greenwich CT 06831 starting January 1, 2025, with the proposed relocation to the permanent address of 130 Mason Street, Greenwich, CT scheduled for the second quarter of 2025.
CONSUMER CREDIT DIVISION ACTIVITY
Consent Order
On December 26, 2024, the Commissioner entered into a Consent Order with Central Mortgage Funding, LLC (NMLS # 1699966) (“Central Mortgage Funding”), Southfield, Michigan. The Consent Order was based on an investigation by the Consumer Credit Division. As a result of such investigation, the Commissioner alleged that Central Mortgage Funding: (1) violated paragraphs 4, 5, 6 and 8 of the Consent to Entry of Sanctions within the April 2024 Consent Order by failing to implement adequate policies and procedures and provide required training on Connecticut laws and regulations, implement an effective compliance management system, and retain a full-time Chief Compliance Officer who reported directly to its managing member and had the authority, responsibilities and duties commonly understood for the position of a Chief Compliance Officer; (2) failed to disclose Telephone Consumer Protection Act class action litigation on its Company (MU1) Form filed on NMLS and inaccurately stated that it was not named in any pending financial services related civil actions, in violation of Sections 36a-490(c) and 36a-53a of the Connecticut General Statutes; (3) filed inaccurate Mortgage Call Reports on NMLS for Quarter 1 2024, in violation of Section 36a-534b(c) of the Connecticut General Statutes; (4) made false or misleading statements in connection with the April 2024 Consent Order, including that it: (i) had received two Connecticut mortgage loan applications in January, when in fact, Central Mortgage Funding received twelve Connecticut mortgage loan applications in January 2024; (ii) ceased mortgage loan originations in Connecticut as of January 31, 2024, when in fact, four Connecticut mortgage loan applications were not withdrawn until February 2024; and (iii) ceased advertising mortgage loan products, when in fact, it continued advertising mortgage loan products in Connecticut through August 2024, in violation of Section 36a-498e(a)(10) of the 2024 Supplement to the General Statutes; (5) continued to advertise the availability of mortgage loans in Connecticut on its website when Central Mortgage Funding had ceased mortgage loan activity in Connecticut, in violation of Section 36a-498d(b)(2) of the Connecticut General Statutes; (6) failed to comply with Sections 36a-485 to 36a-498d inclusive, 36a-498h, 36a-534a and 36a-534b of the Connecticut General Statutes or failed to comply with other state law, in violation of Section 36a-498e(a)(8) of the Connecticut General Statutes, in effect at such time; and (7) failed to establish, enforce and maintain policies and procedures reasonably designed to achieve compliance with Section 36a-498e(a) of the Connecticut General Statutes, in effect at such time, in violation of Section 36a-498e(b)(1) of the Connecticut General Statutes, in effect at such time. Additionally, as a result of such investigation, the Commissioner alleged that Kevin Kajy, the managing member and Qualified Individual of Central Mortgage Funding, failed to establish, enforce and maintain policies and procedures, at Central Mortgage Funding, reasonably designed to achieve compliance with Section 36a-498e(a) of the Connecticut General Statutes, in effect at such time, in violation of Section 36a-498e(b)(1) of the Connecticut General Statutes, in effect at such time. As part of the Consent Order, Central Mortgage Funding paid $50,000 as a civil penalty and agreed to the revocation and nonrenewal of its Connecticut mortgage correspondent lender license and Kevin Kajy agreed to the surrender of his Connecticut mortgage loan originator license.
Dated: Tuesday, December 31, 2024
Jorge L. Perez
Banking Commissioner