Bulletin 3233 - February 6, 2026

The Department of Banking News Bulletin

Bulletin # 3233 - Week Ending February 6, 2026

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

Trumbull Credit Union

On December 15, 2025, the Banking Commissioner issued a Consent Order against Trumbull Credit Union, Trumbull, Connecticut. Based on an examination of the credit union by the Financial Institutions Division, deficiencies were identified, and a Consent Order was issued pursuant to Section 36a-59 of the Connecticut General Statutes.

NEW BANK ACTIVITY

On February 6, 2026, Jason Pijinaker filed an application to organize One Forty Bank, with a main office in Stamford, Connecticut, as a Connecticut innovation bank pursuant to Section 36a-70 of the Connecticut General Statues. The public portion of the application is available for inspection at the Department of Banking.

CONSUMER CREDIT ACTIVITY

Meera Banta and First Bank Mortgage, Inc d/b/a Money Tree

On February 5, 2026, the Banking Commissioner and the Commissioner of Consumer Protection jointly entered into a Consent Order with First Bank Mortgage, Inc. d/b/a Money Tree (NMLS # 1291) ("Money Tree"), Stamford, Connecticut, a licensed mortgage correspondent lender, and Meera Banta, a licensed real estate broker and mortgage loan originator sponsored by Money Tree (NMLS # 1582629) ("Banta"). The Consent Order was based on a routine examination of Money Tree by the Consumer Credit Division of the Department of Banking, and subsequent investigation into the activities of Money Tree and Banta by the Department of Banking and Department of Consumer Protection.

As a result of the Department of Consumer Protection's investigation into the activities of Banta, the Commissioner of Consumer Protection alleged that between April 2022 and April 2023: (1) Banta failed to make the disclosure required by Section 20-325c of the Connecticut General Statutes, in effect at such time, prior to entering into a contract for mortgage brokering services in connection with three Connecticut residential real property transactions, in violation of Section 20-325c(c) of the Connecticut General Statutes in effect at such time; (2) the fee, commission, or other valuable consideration Banta received for negotiating, soliciting, arranging, placing or finding first mortgage loans in connection with four Connecticut residential real property transactions was not paid directly to the broker by the buyer, but rather was paid from the mortgage loan proceeds at the time of closing, in violation of Section 20-325c(b)(3) of the Connecticut General Statutes, in effect at such time; (3) Banta failed to execute a written agreement with buyers which met the requirements of Section 20-325c-3 of the Regulations of Connecticut State Agencies ("Regulations") in connection with four Connecticut residential real property transactions, in violation of Section 20-325c-3 of the Regulations; (4) Banta failed to base the fee, commission or other valuable consideration she received, for mortgage brokering services in connection with four Connecticut residential real property transactions, on a reasonable hourly rate, in violation of Section 20-325c-4 of the Regulations; and (5) Banta failed to maintain a written record of the amount of time spent in negotiating, soliciting, arranging, placing or finding a first mortgage loan for buyers and to provide an itemized invoice of the services rendered to buyers prior to the receipt of any fee, commission or other valuable consideration received in connection with four Connecticut residential real property transactions, in violation of Section 20-325c-5 of the Regulations. As part of the Consent Order, Banta agreed to pay $12,000 to settle this matter with the Department of Consumer Protection.

As a result of the Department of Banking's examination of the activities of Money Tree, the Banking Commissioner alleged that from at least April 2022 to April 2023, Money Tree 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 violation of Section 36a-498e(b)(1) of the Connecticut General Statutes, in effect at such time. As part of this Consent Order, Money Tree paid $4,000 as a civil penalty to the Department of Banking.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

Layered Financial, LLC (IARD No. 326418)

On February 2, 2026, the Banking Commissioner entered an Order Conditioning Registration as an Investment Adviser (Matter No. COND-2026-1-S) with respect to Layered Financial, LLC, a sole member investment adviser currently located at 520 12th Street S, #533, Arlington, Virginia 2202. Before relocating to Virginia in 2024, Layered Financial was located at 160 Dockerel Road, Tolland, Connecticut 06069.

The firm was last registered as an investment adviser in Connecticut from January 3, 2024 to November 11, 2024. The firm's earlier registration had been conditioned based on its failure to meet the experience requirement in Section 36b-31-7b of the Regulations under the Connecticut Uniform Securities Act.

On January 6, 2026, the firm applied anew for Connecticut investment adviser registration. The firm's structure and business activities were similar to those described in its earlier application and the firm continued to have no reported disciplinary history. The firm expressed an interest in serving Connecticut clients and possibly moving back to Connecticut. Since the earlier application, the firm had become registered with two additional states - Virginia and Texas - which provided it with a bit more experience but not enough to fulfill Connecticut requirements.

The 2026 Conditional Registration Order essentially resuscitated the terms and conditions in the prior 2024 conditional order. The only exception was that the time period for the conditions was reduced from three years to two years in light of the experience the firm achieved in the intervening time frame.

Layered Financial, LLC became registered as an investment adviser in Connecticut on February 2, 2026.

Summer Family Advisors, LLC (IARD 338026) and Maximilian Montagnino (CRD No. 8143568)

On February 5, 2026, the Banking Commissioner entered an Order Conditioning Registration as an Investment Adviser and as an Investment Adviser Agent (Matter No. COND-25-202534-S) with respect to Summer Family Advisors, LLC, an applicant for investment adviser registration located at 48 Union Street, 1C, Stamford, Connecticut 06906, and Maximilian Montagnino, control person of the firm. The firm's business would be limited to financial planning.

The Order alleged that the firm and its principal failed to meet the experience requirement set forth in Section 36b-31-7b of the Regulations under the Connecticut Uniform Securities Act. As a result, various conditions were imposed on the registrations.

Among other things, the Order precluded the respondents from having custody of client funds or securities for three years, required that the firm consult with a regulatory consultant to ensure its compliance with regulatory requirements and limited the securities products on which it could render advice.

On February 5, 2026, Summer Family Advisors, LLC became registered as an investment adviser in Connecticut and Maximilian Montagnino became registered as an investment adviser agent of the firm.

Dated: Tuesday, February 10, 2026

Jorge L. Perez
Banking Commissioner