Bulletin 3225 - December 12, 2025

The Department of Banking News Bulletin

Bulletin # 3225 - Week Ending December 12, 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.

CONSUMER CREDIT INVESTMENTS DIVISION ACTIVITY

Nations Client Resolution, LLC

On December 9, 2025, the Commissioner entered into a Consent Order with Nations Client Resolution, LLC (NMLS # 2003957), ("NCR"), Miami, Florida. The Consent Order was based on an investigation by the Consumer Credit Division which stemmed from the routine examination of a licensee. As result of such investigation, the Commissioner alleged that NCR acted as a consumer collection agency in this state without the required license since at least January 1, 2025 to present, in violation of Section 36a-801(a) of the Connecticut General Statutes. As part of the Consent Order, NCR paid $10,000 as a civil penalty.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY

Ondo Capital Management LLC (CRD No. 325197) and Ondo I LP

On December 12, 2025, the Banking Commissioner entered into a Stipulation and Agreement (No. ST-M2024-22-S) with investment adviser Ondo Capital Management LLC and its affiliate Ondo I LP. Both entities are located at 500 West Putnam Avenue, Suite 400, Greenwich Connecticut 06830. Ondo Capital Management LLC previously claimed that it was an exempt reporting adviser under federal law. Subsequently, the firm became registered as an investment adviser with the Securities and Exchange Commission.

The Stipulation and Agreement alleged that Ondo Capital Management LLC failed to properly advise the Commissioner of its status as a federal exempt reporting adviser between May 17, 2023 and March 29, 2024, and that it later failed to timely file the notice required of SEC-registered investment advisers. Such conduct allegedly violated Orders issued by the Commissioner in 2011 and 2017 as well as Section 36b-6(e) of the Connecticut Uniform Securities Act.

Ondo Fund I LP is a private investment fund advised by Ondo Capital Management LLC. Ondo Fund I LP allegedly sold interests solely to Qualified Purchasers in reliance on Rule 506(c) of Regulation D under the Securities Act of 1933. At least ten investors were involved. The Stipulation and Agreement alleged that Ondo Fund I LP was delinquent in making the state filing required for issuers relying on Rule 506 of Regulation D. Such conduct constituted a violation of Sections 36b-16 and 36b-21(e) of the Act. The deficiency has since been cured.

The Stipulation and Agreement required that both parties refrain from regulatory violations. In addition, the Stipulation and Agreement fined Ondo Capital Management LLC $1,000 and Ondo 1 LP $500.

Dated: Tuesday, December 16, 2025

Jorge L. Perez
Banking Commissioner