Bulletin 3201 - June 27, 2025

State of Connecticut
Department of Banking

The Department of Banking News Bulletin

Bulletin # 3201 - Week Ending June 27, 2025

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.

CREDIT UNION ACTIVITY

Name Change

On June 27, 2025,
Healthcare Financial Credit Union
, New Haven, Connecticut, a Connecticut credit union, filed a request for approval to amend its bylaws pursuant to Section 36a-437a(h)(3) of the Connecticut General Statutes to change its name to Unity Financial Credit Union .

CONSUMER CREDIT DIVISION ACTIVITY

Landmark Strategy Group, LLC

On June 25, 2025, the Commissioner entered into a Consent Order with Landmark Strategy Group, LLC (NMLS # 1835049) (“Landmark”), West Seneca, New York. The Consent Order was based on an investigation by the Consumer Credit Division. As a result of such investigation, the Commissioner alleged that Landmark acted as a consumer collection agency in this state without the required license since April 2023, in violation of Section 36a-801(a) of the Connecticut General Statutes. As part of the Consent Order, Landmark paid $10,000 as a civil penalty and $800 as back licensing fees.

Systems & Services Technologies, Inc. d/b/a SST

On June 25, 2025, the Commissioner entered into a Consent Order with Systems & Services Technologies, Inc. d/b/a SST (NMLS # 950746) (“SST”), Irvine, California. The Consent Order was based on an investigation by the Consumer Credit Division. As a result of such investigation, the Commissioner alleged that: (1) since January 2022, SST has engaged in the business of a sales finance company in Connecticut without a sales finance company license, in violation of Section 36a-536 of the Connecticut General Statutes, by receiving payments of principal and interest from retail buyers under retail installment contracts; and (2) since September 2024, SST has engaged in the business of a small loan company in Connecticut without a small loan company license, in violation of Section 36a-556(a)(4) of the Connecticut General Statutes, in effect at such time, by receiving payments of principal and interest in connection with at least 250 small loans made to Connecticut borrowers. As part of the Consent Order, SST paid $10,000 as a civil penalty and $800 as back licensing fees.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

CONNECTICUT UNIFORM SECURITIES ACT AMENDMENTS ANNOUNCED

On June 23, 2025, Governor Lamont signed into law Public Act No. 25-85, An Act Concerning the Connecticut Uniform Securities Act . The Public Act is effective upon passage.

The legislation creates a state broker-dealer registration exemption for merger and acquisitions broker-dealers who facilitate a change in control of private companies. The proposal substantially mirrors that adopted by Congress in December 2022 as part of the Consolidated Appropriations Act of 2023.

In addition, the legislation created a filing requirement for securities offerings made pursuant to Regulation A Tier 2. Regulation A, promulgated under the federal Securities Act of 1933, is a federal exemption from securities registration. Under Securities and Exchange Commission rules, offerings made pursuant to Tier 2 of Regulation A to qualified purchasers would be preempted from state review under Section 18(b)(3) of the Securities Act of 1933. However, state authority to impose notice filing and fee requirements for Tier 2 offerings was preserved. The Connecticut legislation added notice filing and fee requirements for offerings made pursuant to Tier 2 of federal Regulation A. Specifically, twenty-one calendar days before the initial sales of securities in Connecticut, affected issuers would file a Regulation A - Tier 2 notice fling form, a Consent to Service of Process and a $250 filing fee. Initial filings would be effective for twelve months following which they could be renewed.

The legislation also expanded the Commissioner's enforcement powers to enable the Commissioner to censure or bar a registrant, or any partner, officer, director or control person of a registrant based on grounds enumerated in Section 36b-15(a) of the Act and subject to the registrant’s right to request a hearing.

CFIG Investment Advisory Services, LLC f/k/a Continental Five Investment Group, LLC (CRD No. 148261)

On June 23, 2025, the Banking Commissioner entered a Consent Order (No. CO-25-202518-S) with respect to CFIG Investment Advisory Services, LLC , a Connecticut-registered investment adviser located at 1555 Post Road East, Suite 206, Westport, Connecticut 06880.

In 2018, the firm had been put on notice that its billing policies and bookkeeping practices were not consistent with regulatory requirements. The June 23, 2025 Consent Order alleged that the firm had not rectified the deficiencies on the date of the Division's later examination and that it was reluctant to provide critical information during the course of that examination. The Consent Order alleged that the firm violated Section 36b-31-6f(b) of the Regulations under the Connecticut Uniform Securities Act by failing to establish enforce and maintain an adequate supervisory system; that it violated Section 36-31-14f(b)(4) of the Regulations by failing to furnish access to certain areas of its investment advisory operations and otherwise facilitate he Division’s examination; violated Section 36b-23 of the Act by making statements regarding its affiliate that were false or misleading; and violated Section 36b-31-14b(a) of the Regulations by failing to keep true, accurate and current records in connection with an income statement provided to the Division in 2024.

The Consent Order fined the firm $10,000 and directed it to cease and desist from regulatory violations. In addition, the Consent Order directed the firm to retain a regulatory consultant for three years to evaluate its compliance programs and report back to the Division on its findings.

Ian Michael Pierce (CRD No. 6205487)

On June 26, 2025, the Banking Commissioner entered a Consent Order with respect to Ian Michael Pierce , a former broker-dealer agent located at 305 Tolland Stage Road, Tolland, Connecticut 06084-2919.

The Consent Order alleged that, from June 2018 through November 2024, Respondent Pierce transacted business as an investment adviser absent registration in violation of Section 36b-6(c)(1) of the Connecticut Uniform Securities Act, and that Respondent fraudulently obtained and/or misappropriated at least $164,000 from at least four Connecticut customers who received no money in return in violation of Section 36b-5(a) of the Act.

The Consent Order noted that Respondent Pierce had been the subject of a June 6, 2021 Order for Default Judgement and Order of Revocation (Docket No. FC 20- I 05) issued by the Connecticut Insurance Department revoking all of Respondent's insurance licenses and precluding Respondent from being issued any future insurance licenses. In addition, the Consent Order noted that on February 23, 2022, the Financial Industry Regulatory Authority (“FINRA”) entered into a Letter of Acceptance, Waiver, and Consent (A WC) with Respondent (Docket No. 2020066086301), which permanently barred Respondent due to Respondent’s converting a customer's funds, depositing them into his bank account, and preparing fictitious statements.

Respondent Pierce provided the agency with a sworn financial affidavit demonstrating that he was unable to reimburse the affected Connecticut customers $164,000 or to pay the $100,000 administrative fine that otherwise would have been imposed against him. In light of that fact, the Consent Order temporarily stayed collection of the $164,000 restitution amount and the $100,000 fine for three years. After three years, if Respondent still was unable to pay the fine, the fine would be waived. However, Respondent's restitution obligation would remain in effect after three years.

The Consent Order directed Respondent to cease and desist from regulatory violations and barred him from offering or selling securities in or from Connecticut; transacting business in or form Connecticut as a broker-dealer, agent, investment adviser or investment adviser agent and acting in any other capacity that required a license or registration from the Commissioner.

Dated: Tuesday, July 1, 2025

Jorge L. Perez
Banking Commissioner