DOB: News Bulletin 2374 - August 21, 2009

The Department of Banking News Bulletin 

Bulletin # 2374
Week Ending August 21, 2009

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 Howard F. Pitkin, Banking Commissioner, at the Connecticut Department of Banking, 260 Constitution Plaza, Hartford, CT 06103-1800 or via E-mail. Written comments will be considered only if they are received within ten days from the date of this bulletin.

Consent Order
On June 26, 2009, the Banking Commissioner entered a Consent Order with respect to Silver Oak Securities, Inc., a Connecticut-registered broker-dealer having its principal office at 3339 North Highland Avenue, Jackson, Tennessee.  The Consent Order alleged that from early 2008 forward, the firm violated Section 36b-6(d) of the Connecticut Uniform Securities Act by transacting business from three unregistered branch offices in the state.  The branch offices were located at 100 Great Meadows Road, Wethersfield, Connecticut; 6 North Main Street, Wallingford, Connecticut; and 146 Hopmeadow Street, Simsbury, Connecticut.   All three branch offices are currently registered.  The Consent Order directed the firm to cease and desist from regulatory violations and to implement revised supervisory and compliance procedures.  In addition, the Consent Order required that the firm remit $5,000 to the department.  Of that amount, $3,000 constituted an administrative fine and $2,000 would be applied to defray the Divisionís examination and investigative costs associated with the matter.
Order to Cease and Desist from Regulatory Violations;
Notice of Intent to Fine and Notice of Right to Hearing Issued
On August 19, 2009, the Banking Commissioner issued an Order to Cease and Desist, Notice of Intent to Fine and Notice of Right to Hearing with respect to Daniel Charles Allegrini, a former broker-dealer agent of Wachovia Securities, LLC.  The action alleged that 1) from at least November 2002 to February 2004, the respondent violated Section 36b-6(c) of the Connecticut Uniform Securities Act by transacting business as an investment adviser while unregistered; 2) in 2003, the respondent violated Section 36b-16 of the Act by selling approximately $17,700 in unregistered promissory notes to one or more Connecticut investors; 3) the respondent violated the antifraud provisions in Section 36b-4(a) of the Act by failing to disclose, in connection with the promissory note sales, any risk factors associated with the investment, financial information concerning the respondent or the fact that the respondent had filed for bankruptcy; and 4) in effecting promissory note sales outside the scope of his employment with Wachovia Securities, LLC, the respondent violated Section 36b-31-6(e) of the Regulations under the Act by engaging in private securities transactions absent prior written notice to his employing firm.   The respondent was afforded an opportunity to request a hearing on the Order to Cease and Desist.  A hearing on the Notice of Intent to Fine has been scheduled for September 24, 2009.
Stipulation and Agreement
On August 19, 2009, the Banking Commissioner entered into a Stipulation and Agreement with Maxim Group LLC, a Connecticut-registered broker-dealer.  The firm maintains its principal office at 405 Lexington Avenue, New York, New York.  The Stipulation and Agreement alleged that from November 2005 forward, the firm employed Jared Ross Greenbaum as an agent at a time when Greenbaum was not registered under the Connecticut Uniform Securities Act.  Jared Greenbaum has since become registered as an agent of the firm in Connecticut.  Pursuant to the Stipulation and Agreement, Maxim Group LLC agreed to comply with all statutory requirements governing the registration of affected personnel as broker-dealer agents; review and revise its supervisory procedures as necessary to ensure regulatory compliance; and pay $4,700 to the department.  Of that amount, $3,500 constituted an administrative fine, $200 represented reimbursement for past due agent registration fees; and $1,000 would be applied to defray Division investigative costs.
       Dated:  Tuesday, August 25, 2009
       Howard F. Pitkin
       Banking Commissioner