Allen Trevor M Sr Hearing Decision

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IN THE MATTER OF:

TREVOR M. ALLEN, SR.

("Respondent")

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FINDINGS OF FACT,

CONCLUSIONS OF LAW

AND

ORDER

DOCKET NO. CRF-17-8212-S

*Parenthetical references relate to exhibits entered into the hearing record by the Hearing Officer (“HO Ex.”) or the Department (“Dept. Ex.”). Transcript (“Tr.”) pages reflect where an exhibit was entered into the record or where relevant testimony was given.

INTRODUCTION

The Banking Commissioner (“Commissioner”) is charged with the administration of Chapter 672a of the Connecticut General Statutes, the Connecticut Uniform Securities Act (“Act”), and Sections 36b-31-2 to 36b-31-33, inclusive, of the Regulations of Connecticut State Agencies promulgated under the Act.

The above-referenced matter was initiated upon charges brought by the Commissioner to issue an order to cease and desist, order to make restitution and an order imposing fine upon Respondent, among others. On December 1, 2017, the Commissioner issued an Order to Cease and Desist, Order to Make Restitution, Notice of Intent to Fine and Notice of Right to Hearing (collectively, “Notice”) against Respondent. On December 4, 2017, the Notice was sent to Respondent by certified mail, return receipt requested. On December 26, 2017, the Department of Banking (“Department”) received a hearing request from Respondent.

On January 2, 2018, the Commissioner issued a Notification of Hearing and Designation of Hearing Officer stating that the hearing would be held on January 30, 2018, and appointing Attorney Stacey Serrano as Hearing Officer. After a continuance of the scheduled hearing date, a hearing was held at the Department on February 27, 2018. Attorney Paul A. Bobruff represented the Department at the hearing and Respondent failed to appear at the hearing. The hearing was conducted in accordance with Chapter 54 of the Connecticut General Statutes, the “Uniform Administrative Procedure Act”, and the Department’s contested case regulations, Sections 36a-1-19 to 36a-1-57, inclusive, of the Regulations of Connecticut State Agencies.

Section 36a-1-31(b) of the Regulations of Connecticut State Agencies provides, in pertinent part, that:

When a party fails to appear at a scheduled hearing, the allegations against the party may be deemed admitted. Without further proceedings or notice to the party, the presiding officer shall submit to the commissioner a proposed final decision containing the relief sought in the notice, provided the presiding officer may . . . receive evidence from the department . . . concerning the appropriateness of the amount of any . . . fine . . . sought in the notice.

Having read the entire record, including testimony of the witnesses and documentary evidence, I make the following findings of fact and conclusions of law based on the preponderance of evidence in the record.

FINDINGS OF FACT

1. On December 1, 2017, the Commissioner issued an Order to Cease and Desist, Order to Make Restitution, Notice of Intent to Fine and Notice of Right to Hearing against Respondent, among others. (HO Ex. 1; Tr. at 8.)

2. On December 26, 2017, the Department received a written request for a hearing from Respondent. (HO Ex. 2; Tr. at 8.)

3.
On January 2, 2018, the Commissioner appointed Attorney Stacey Serrano as Hearing Officer and scheduled the hearing for January 30, 2018. (HO Ex. 1.)

4. On January 25, 2018, the Hearing Officer e-mailed Respondent, reminding him that the hearing was scheduled for January 30, 2018, and that “pursuant to Section 36a-1-31(b) of the Regulations, ‘[w]hen a party fails to appear at a scheduled hearing, the allegations against the party may be deemed admitted.’” (Dept. Ex. 8; Tr. at 23-24.)

5.
On January 29, 2018, the Hearing Officer continued the hearing scheduled for January 30, 2018 to a date to be determined. (Dept. Ex. 10; Tr. at 25-26.)

6. On January 30, 2018, the Hearing Officer scheduled a conference call for February 13, 2018 and continued the hearing to 10 a.m. on February 27, 2018. (HO Ex. 8; Tr. at 10.)

7. On February 9, 2018, the Hearing Officer cancelled the conference call scheduled for February 13, 2018, because Respondent indicated he was “not available in office for conference call due to processing tied to international financial transaction in satellite system.” (Dept. Ex. 1, Tr. at 11-13.)

8. Subsequent to such date and prior to the hearing, no additional communications either requesting another conference call or objecting to the new hearing date were received from Respondent. (Tr. at 13.)

9. The hearing was held on February 27, 2018. (Tr. at 4.)

10. Attorney Paul A. Bobruff appeared at the hearing on behalf of the Department. (Tr. at 4-5.)

11. Respondent failed to appear at the hearing. (Tr. at 5.)

12. CE Capital Limited a/k/a CE Capital Ltd. (“CE Capital”) and its affiliate, GBI Financial Limited, are purported foreign business entities whose addresses last known to the Commissioner are: Level 19, Two International Finance Centre, 8 Finance Street, Central, Hong Kong SAR; and 555 West Country Club Lane, C354, Escondido, California 92026. (HO Ex. 1.)

13. Arthur Connolly (“Connolly”) is an individual whose address last known to the Commissioner is 43 Maple Street Extension, Kent, Connecticut 06757. Connolly was the Risk Management Officer of CE Capital and a Financial Limited Trustee of GBI Financial Limited. (HO Ex. 1.)

14. Respondent is an individual whose address last known to the Commissioner is 555 West Country Club Lane, C, Escondido, California 92026. Respondent was the Capital Account Signatory for CE Capital and the Financial Limited Asset Manager for GBI Financial Limited. (HO Ex. 1, HO Ex. 4; Tr. at 8-9.)

15. On Sunday, August 25, 2013, an investor executed a “Participation Agreement” with CE Capital (“Investor A”). Respondent and Connolly signed the Participation Agreement on behalf of CE Capital. (HO Ex. 1; Tr. at 37.)

16. The Participation Agreement provided that, in return for Investor A’s payment of $50,000, CE Capital would return that amount to Investor A in 31 days or less from receipt of Investor A’s payment of $50,000, and would include an additional “agreed Profit Participation” of $450,000 for a total return of $500,000. (HO Ex. 1, Dept. Ex. 11 at 4; Tr. at 32-34.)

17. The Participation Agreement states that the funds would be used to cover “emergency, miscellaneous operating expenses associated with expediting the transfer of . . . [CE Capital’s] clients [sic] humanitarian investment trade funds via ‘Server to Server’ transfer” as directed by Respondent and Connolly. No additional details were provided to Investor A regarding how his investment proceeds would be used. (HO Ex. 1, Dept. Ex. 11 at 4.)

18. The Participation Agreement also provided that if CE Capital failed to secure its clients’ humanitarian investment trade funds for any reason, Investor A would immediately receive a return of his $50,000. (HO Ex. 1, Dept. Ex. 11 at 4; Tr. at 36-37.)

19. The Participation Agreement represented that CE Capital’s client “has sufficient humanitarian investment trade funds ready for transfer and that . . . [CE Capital] has sufficient available Credit Line to pull from upon receipt of said humanitarian investment trade funds, and that . . . [CE Capital] has full capability to execute all the terms of this Participation Agreement.” (HO Ex. 1, Dept. Ex. 11 at 4.)

20. The Participation Agreement directed Investor A to transfer $50,000 to the bank account of The Law Offices of Brian M. Yard, LLC, Attorneys at Law (“Yard Law Firm”). (HO Ex. 1.)

21. Attorney Brian M. Yard has been a member of the Connecticut Bar since 1988. Brian M. Yard is the principal member of Yard Law Firm, which has its principal place of business at 21 South Street, Litchfield, Connecticut 06759-1571. The Yard Law Firm maintains an Interest on Lawyers Trust Account (“IOLTA”) which pools funds into a single, interest bearing account. (HO Ex. 1.)

22. On Sunday, August 25, 2013, the same day the Participation Agreement was executed, the Yard Law Firm entered into a “Paymaster Agreement” with CE Capital. The Paymaster Agreement stated that “[m]y firm is prepared to accept and disburse funds on your behalf to ensure the integrity of your upcoming transaction and to expedite your receipt of funds.” Respondent and Connolly executed the Paymaster Agreement on behalf of CE Capital, and Brian M. Yard executed the Paymaster Agreement on behalf of the Yard Law Firm. (HO Ex. 1, Dept. Ex. 12; Tr. at 38-39.)

23. The Paymaster Agreement also provided that: (i) the Yard Law Firm would receive CE Capital funds on CE Capital’s behalf “into my Attorney Trust Account and promptly disburse them in accordance with the terms of the Sub-Fee Agreement (to be prepared by you and/your attorney)”; (ii) funds disbursed by the Attorney Paymaster would be transmitted by bank wire-to-wire transfer “to the accounts provided this law firm by the signatories below”; and (iii) the paymaster fee would be “considered earned in full upon receipt of your funds into my Attorney Trust Account and will be deducted from the funds immediately.” (HO Ex. 1, Dept. Ex. 12.)

24. On August 26, 2013, Investor A transferred $50,000 into the Yard Law Firm Attorney Trust Account pursuant to the Participation Agreement. (HO Ex. 1.)

25. Pursuant to the Paymaster Agreement, Connolly directed the Yard Law Firm to disburse Investor A’s funds to the personal account of Respondent, among others. Of the $50,000, the Yard Law Firm transferred $8,000 to the personal account of Respondent. (HO Ex. 1, Dept. Ex. 13; Tr. at 39-41.)

26. On October 3, 2014, Investor A filed a complaint with the Connecticut Office of the Attorney General concerning the $50,000 he had wired to Attorney Brian Yard for the benefit of CE Capital on August 26, 2013. (Dept. Ex. 11; Tr. at 35.)

27. To date, Investor A has not received a return of his $50,000 investment or the promised Profit Participation of $450,000. (HO Ex. 1, Tr. at 42-43.)

28. The Participation Agreement and its accompanying guarantee of a set return constitute securities in the form of an investment contract, evidence of indebtedness and/or certificate of interest or participation in a profit-sharing agreement within the meaning of Section 36b-3(19) of the Act. Such securities were not registered under Section 36b-16 of the Act nor were they the subject of a filed exemption claim or claim of covered security status. (HO Ex. 1, Dept. Ex. 15; Tr. at 41, 43 44.)

29. Respondent was not registered as an agent of the issuer CE Capital under the Act. (HO Ex. 1, Dept. Ex. 16; Tr. at 41, 44.)

30. In connection with the offer and sale of the Participation Agreement securities, Respondent failed to disclose, inter alia, any financial information concerning Respondent or CE Capital; that Respondent was not registered as an agent of issuer or in any other capacity to sell securities in Connecticut; any specific risk factors related to the investment; the precise business and operating history of CE Capital and its affiliates; the remuneration to be paid to the directors, officers and/or principals of CE Capital; substantiating data explaining how a $50,000 investment could yield an additional return of $450,000 in 31 days or less; or precisely how the investment proceeds would be applied. Each of these omitted items was material to investors and prospective investors of CE Capital. (HO Ex. 1; Tr. at 45-46.)

31. The Department requested that a fine of $100,000 be imposed upon Respondent. (Tr. at 48-49.)

CONCLUSIONS OF LAW

1. Pursuant to Section 36a-1-31(b) of the Regulations of Connecticut State Agencies, the allegations made in the Notice against Respondent are deemed admitted.

2. Respondent offered and sold unregistered securities of CE Capital in or from Connecticut to at least one investor, which securities were not registered in Connecticut under the Act, in violation of Section 36b-16 of the Act, which forms a basis for an order to cease and desist to be issued against Respondent under Section 36b-27(a) of the 2018 Supplement to the General Statutes, an order that Respondent make restitution under Section 36b-27(b) of the 2018 Supplement to the General Statutes, and for the imposition of a fine upon Respondent pursuant to Section 36b-27(d) of the 2018 Supplement to the General Statutes.

3. Respondent, in connection with the offer, sale or purchase of CE Capital, directly or indirectly employed a device, scheme or artifice to defraud, made an untrue statement of a material fact or omitted to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, or engaged in an act, practice or course of business which operated or would operate as a fraud or deceit upon any person, in violation of Section 36b-4(a) of the Act, which forms a basis for an order to cease and desist to be issued against Respondent under Section 36b-27(a) of the 2018 Supplement to the General Statutes, an order that Respondent make restitution under Section 36b-27(b) of the 2018 Supplement to the General Statutes, and for the imposition of a fine upon Respondent pursuant to Section 36b-27(d) of the 2018 Supplement to the General Statutes.

4. Respondent transacted business as an agent of issuer in this state absent registration, in violation of Section 36b-6(a) of the Act, which forms a basis for an order to cease and desist to be issued against Respondent under Section 36b-27(a) of the 2018 Supplement to the General Statutes and for the imposition of a fine upon Respondent under Section 36b-27(d) of the 2018 Supplement to the General Statutes.

5. The issuance of an order to cease and desist, an order to make restitution and order imposing a fine is necessary and appropriate in the public interest and for the protection of investors and consistent with the purposes fairly intended by the policy and provisions of Sections 36b-2 to 36b-34, inclusive, of the Act.

6. The Commissioner complied with Sections 36b-27(a), 36b-27(b) and 36b-27(d) of the 2018 Supplement to the General Statutes and Sections 36b-31(b) and 4-177 of the Connecticut General Statutes.

ORDER

Having read the record, I hereby ORDER, pursuant to Sections 36b-27(a), 36b-27(b) and 36b-27(d) of the 2018 Supplement to the General Statutes, that:

1.	The Order to Cease and Desist issued against Trevor M. Allen, Sr. on December 1, 2017, be made PERMANENT with respect to violations of Sections 36b-16, 36b-4(a) and 36b-6(a) of the Act;

2.	The Order to Make Restitution issued against Trevor M. Allen, Sr. on December 1, 2017, be made PERMANENT;

3.	A FINE of One Hundred Thousand Dollars ($100,000) be imposed upon Trevor M. Allen, Sr., to be remitted to the Department of Banking by wire transfer, cashier’s check, certified check or money order, made payable to “Treasurer, State of Connecticut”, no later than forty-five (45) days from the date this Order is mailed; and

4.	This Order shall become effective when mailed.

Dated at Hartford, Connecticut, _____/s/____________

this 13th day of July 2018. Jorge L. Perez

Banking Commissioner

This Order was sent by certified mail, return receipt requested, to Respondent and hand delivered to Paul A. Bobruff, Esq., on July 16, 2018.

Trevor M. Allen, Sr.

555 West Country Club Lane, C

Escondido, California 92026

Certified Mail No. 7012 3050 0000 6999 5552

Administrative Orders and Settlements

1.	On December 1, 2017, the Commissioner issued an Order to Cease and Desist, Order to Make Restitution, Notice of Intent to Fine and Notice of Right to Hearing against Respondent, among others. (HO Ex. 1; Tr. at 8.)
2.	On December 26, 2017, the Department received a written request for a hearing from Respondent. (HO Ex. 2; Tr. at 8.)
3.	On January 2, 2018, the Commissioner appointed Attorney Stacey Serrano as Hearing Officer and scheduled the hearing for January 30, 2018. (HO Ex. 1.)
4.	On January 25, 2018, the Hearing Officer e-mailed Respondent, reminding him that the hearing was scheduled for January 30, 2018, and that “pursuant to Section 36a-1-31(b) of the Regulations, ‘[w]hen a party fails to appear at a scheduled hearing, the allegations against the party may be deemed admitted.’” (Dept. Ex. 8; Tr. at 23-24.)
5.	On January 29, 2018, the Hearing Officer continued the hearing scheduled for January 30, 2018 to a date to be determined. (Dept. Ex. 10; Tr. at 25-26.)
6.	On January 30, 2018, the Hearing Officer scheduled a conference call for February 13, 2018 and continued the hearing to 10 a.m. on February 27, 2018. (HO Ex. 8; Tr. at 10.)
7.	On February 9, 2018, the Hearing Officer cancelled the conference call scheduled for February 13, 2018, because Respondent indicated he was “not available in office for conference call due to processing tied to international financial transaction in satellite system.” (Dept. Ex. 1, Tr. at 11-13.)
8.	Subsequent to such date and prior to the hearing, no additional communications either requesting another conference call or objecting to the new hearing date were received from Respondent. (Tr. at 13.)
9.	The hearing was held on February 27, 2018. (Tr. at 4.)
10.	Attorney Paul A. Bobruff appeared at the hearing on behalf of the Department. (Tr. at 4-5.)
11.	Respondent failed to appear at the hearing. (Tr. at 5.)
12.	CE Capital Limited a/k/a CE Capital Ltd. (“CE Capital”) and its affiliate, GBI Financial Limited, are purported foreign business entities whose addresses last known to the Commissioner are: Level 19, Two International Finance Centre, 8 Finance Street, Central, Hong Kong SAR; and 555 West Country Club Lane, C354, Escondido, California 92026. (HO Ex. 1.)
13.	Arthur Connolly (“Connolly”) is an individual whose address last known to the Commissioner is 43 Maple Street Extension, Kent, Connecticut 06757. Connolly was the Risk Management Officer of CE Capital and a Financial Limited Trustee of GBI Financial Limited. (HO Ex. 1.)
14.	Respondent is an individual whose address last known to the Commissioner is 555 West Country Club Lane, C, Escondido, California 92026. Respondent was the Capital Account Signatory for CE Capital and the Financial Limited Asset Manager for GBI Financial Limited. (HO Ex. 1, HO Ex. 4; Tr. at 8-9.)
15.	On Sunday, August 25, 2013, an investor executed a “Participation Agreement” with CE Capital (“Investor A”). Respondent and Connolly signed the Participation Agreement on behalf of CE Capital. (HO Ex. 1; Tr. at 37.)
16.	The Participation Agreement provided that, in return for Investor A’s payment of $50,000, CE Capital would return that amount to Investor A in 31 days or less from receipt of Investor A’s payment of $50,000, and would include an additional “agreed Profit Participation” of $450,000 for a total return of $500,000. (HO Ex. 1, Dept. Ex. 11 at 4; Tr. at 32-34.)
17.	The Participation Agreement states that the funds would be used to cover “emergency, miscellaneous operating expenses associated with expediting the transfer of . . . [CE Capital’s] clients [sic] humanitarian investment trade funds via ‘Server to Server’ transfer” as directed by Respondent and Connolly. No additional details were provided to Investor A regarding how his investment proceeds would be used. (HO Ex. 1, Dept. Ex. 11 at 4.)
18.	The Participation Agreement also provided that if CE Capital failed to secure its clients’ humanitarian investment trade funds for any reason, Investor A would immediately receive a return of his $50,000. (HO Ex. 1, Dept. Ex. 11 at 4; Tr. at 36-37.)
19.	The Participation Agreement represented that CE Capital’s client “has sufficient humanitarian investment trade funds ready for transfer and that . . . [CE Capital] has sufficient available Credit Line to pull from upon receipt of said humanitarian investment trade funds, and that . . . [CE Capital] has full capability to execute all the terms of this Participation Agreement.” (HO Ex. 1, Dept. Ex. 11 at 4.)
20.	The Participation Agreement directed Investor A to transfer $50,000 to the bank account of The Law Offices of Brian M. Yard, LLC, Attorneys at Law (“Yard Law Firm”). (HO Ex. 1.)
21.	Attorney Brian M. Yard has been a member of the Connecticut Bar since 1988. Brian M. Yard is the principal member of Yard Law Firm, which has its principal place of business at 21 South Street, Litchfield, Connecticut 06759-1571. The Yard Law Firm maintains an Interest on Lawyers Trust Account (“IOLTA”) which pools funds into a single, interest bearing account. (HO Ex. 1.)
22.	On Sunday, August 25, 2013, the same day the Participation Agreement was executed, the Yard Law Firm entered into a “Paymaster Agreement” with CE Capital. The Paymaster Agreement stated that “[m]y firm is prepared to accept and disburse funds on your behalf to ensure the integrity of your upcoming transaction and to expedite your receipt of funds.” Respondent and Connolly executed the Paymaster Agreement on behalf of CE Capital, and Brian M. Yard executed the Paymaster Agreement on behalf of the Yard Law Firm. (HO Ex. 1, Dept. Ex. 12; Tr. at 38-39.)
23.	The Paymaster Agreement also provided that: (i) the Yard Law Firm would receive CE Capital funds on CE Capital’s behalf “into my Attorney Trust Account and promptly disburse them in accordance with the terms of the Sub-Fee Agreement (to be prepared by you and/your attorney)”; (ii) funds disbursed by the Attorney Paymaster would be transmitted by bank wire-to-wire transfer “to the accounts provided this law firm by the signatories below”; and (iii) the paymaster fee would be “considered earned in full upon receipt of your funds into my Attorney Trust Account and will be deducted from the funds immediately.” (HO Ex. 1, Dept. Ex. 12.)
24.	On August 26, 2013, Investor A transferred $50,000 into the Yard Law Firm Attorney Trust Account pursuant to the Participation Agreement. (HO Ex. 1.)
25.	Pursuant to the Paymaster Agreement, Connolly directed the Yard Law Firm to disburse Investor A’s funds to the personal account of Respondent, among others. Of the $50,000, the Yard Law Firm transferred $8,000 to the personal account of Respondent. (HO Ex. 1, Dept. Ex. 13; Tr. at 39-41.)
26.	On October 3, 2014, Investor A filed a complaint with the Connecticut Office of the Attorney General concerning the $50,000 he had wired to Attorney Brian Yard for the benefit of CE Capital on August 26, 2013. (Dept. Ex. 11; Tr. at 35.)
27.	To date, Investor A has not received a return of his $50,000 investment or the promised Profit Participation of $450,000. (HO Ex. 1, Tr. at 42-43.)
28.	The Participation Agreement and its accompanying guarantee of a set return constitute securities in the form of an investment contract, evidence of indebtedness and/or certificate of interest or participation in a profit-sharing agreement within the meaning of Section 36b-3(19) of the Act. Such securities were not registered under Section 36b-16 of the Act nor were they the subject of a filed exemption claim or claim of covered security status. (HO Ex. 1, Dept. Ex. 15; Tr. at 41, 43 44.)
29.	Respondent was not registered as an agent of the issuer CE Capital under the Act. (HO Ex. 1, Dept. Ex. 16; Tr. at 41, 44.)
30.	In connection with the offer and sale of the Participation Agreement securities, Respondent failed to disclose, inter alia, any financial information concerning Respondent or CE Capital; that Respondent was not registered as an agent of issuer or in any other capacity to sell securities in Connecticut; any specific risk factors related to the investment; the precise business and operating history of CE Capital and its affiliates; the remuneration to be paid to the directors, officers and/or principals of CE Capital; substantiating data explaining how a $50,000 investment could yield an additional return of $450,000 in 31 days or less; or precisely how the investment proceeds would be applied. Each of these omitted items was material to investors and prospective investors of CE Capital. (HO Ex. 1; Tr. at 45-46.)
31.	The Department requested that a fine of $100,000 be imposed upon Respondent. (Tr. at 48-49.)

1.	Pursuant to Section 36a-1-31(b) of the Regulations of Connecticut State Agencies, the allegations made in the Notice against Respondent are deemed admitted.
2.	Respondent offered and sold unregistered securities of CE Capital in or from Connecticut to at least one investor, which securities were not registered in Connecticut under the Act, in violation of Section 36b-16 of the Act, which forms a basis for an order to cease and desist to be issued against Respondent under Section 36b-27(a) of the 2018 Supplement to the General Statutes, an order that Respondent make restitution under Section 36b-27(b) of the 2018 Supplement to the General Statutes, and for the imposition of a fine upon Respondent pursuant to Section 36b-27(d) of the 2018 Supplement to the General Statutes.
3.	Respondent, in connection with the offer, sale or purchase of CE Capital, directly or indirectly employed a device, scheme or artifice to defraud, made an untrue statement of a material fact or omitted to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, or engaged in an act, practice or course of business which operated or would operate as a fraud or deceit upon any person, in violation of Section 36b-4(a) of the Act, which forms a basis for an order to cease and desist to be issued against Respondent under Section 36b-27(a) of the 2018 Supplement to the General Statutes, an order that Respondent make restitution under Section 36b-27(b) of the 2018 Supplement to the General Statutes, and for the imposition of a fine upon Respondent pursuant to Section 36b-27(d) of the 2018 Supplement to the General Statutes.
4.	Respondent transacted business as an agent of issuer in this state absent registration, in violation of Section 36b-6(a) of the Act, which forms a basis for an order to cease and desist to be issued against Respondent under Section 36b-27(a) of the 2018 Supplement to the General Statutes and for the imposition of a fine upon Respondent under Section 36b-27(d) of the 2018 Supplement to the General Statutes.
5.	The issuance of an order to cease and desist, an order to make restitution and order imposing a fine is necessary and appropriate in the public interest and for the protection of investors and consistent with the purposes fairly intended by the policy and provisions of Sections 36b-2 to 36b-34, inclusive, of the Act.
6.	The Commissioner complied with Sections 36b-27(a), 36b-27(b) and 36b-27(d) of the 2018 Supplement to the General Statutes and Sections 36b-31(b) and 4-177 of the Connecticut General Statutes.

Dated at Hartford, Connecticut,		_____/s/____________
this 13th day of July 2018.	Jorge L. Perez
Banking Commissioner

State of Connecticut Department of Banking