BOAR D O F GOVERNOR S O F TH E FEDERA L RESERV E SYSTE M 

WASHINGTON , D C 2055 1 

September 13, 2013 

Mr. Donald J. Vaccaro 

325 Clark Hill Road 

Glastonbury, Connecticut 06033 

Dear Mr. Vaccaro: 

The Board of Governors of the Federal Reserve System has 

considered the notice ("Notice") you filed on August 28, 2013, under the Change 

in Bank Control Act (12 U.S.C. § 1817(j» ("CIBC Act") to acquire 51 percent of 

the voting shares of Urban Financial Group, Inc. ("Urban Financial"), a bank 

holding company, and its subsidiary bank, The Community's Bank, 

(Footnote 1. The bank had approximately $26 million in total assets as 

of June 30, 2013. End footnote.) a state 

non member bank, both of Bridgeport, Connecticut. 

The Connecticut Department of Banking has requested, due to the 

condition of The Community's Bank, that the Board take expedited action on the 

Notice. For the reasons stated below, the Board has disapproved the Notice. In 

reaching this decision, the Board has considered all the information provided in the 

Notice and in related correspondence, information obtained by the Board from 

various independent sources, and information from consultations with other 

relevant banking regulators. 

Under the CIBC Act, the Board is required to review the financial 

condition, competence, experience, and integrity of persons acquiring shares of a 

bank holding company, as well as the proposal's competitive effects and potential 

effects on the federal deposit insurance funds. As part of this review, the Board is 

required to make an independent determination that the information filed as part of 

www.federalreserve.gov 
a CIBC Act notice is accurate and complete. 

(Footnote 2. 12 U.S.C. § 1817(j)(2)(B)(ii). End footnote.) The Board also is required to 

conduct an investigation of the notificant's competence, experience, integrity, and 

financial ability.(Footnote 3. 12 U.S.C. § 1817(j)(2)(B)(i). End footnote.) 

The Board is specifically authorized under the CIBC Act to 

disapprove a notice to acquire control of voting 

shares if any person neglects, fails, 

or refuses to furnish all the information required by the Board. 

(Footnote 4. 12 U.S.C. § 1817(j)(7)(E); 12 CFR 225.43(h)(1). End footnote.) 

In reviewing this case, the Board considered the efforts of the Federal 

Reserve Bank of New York ("Reserve Bank") and Board staff to obtain 

information from you concerning your proposed purchase of Urban Financial 

shares. Reserve Bank staff had an initial telephone conversation with you and your 

counsel on August 8, 2013; Reserve Bank and Board staff formally requested 

additional information from you and your counsel on September 4, 2013; and 

Reserve Bank and Board staff had subsequent telephone conversations with you 

and your counsel to discuss the Notice. 

Notwithstanding these efforts, the Notice remains incomplete in 

several respects that are material to the Board's consideration of the factors 

required to be considered under the CIBC Act. For example, your personal 

financial statements are incomplete and inadequately supported. You also have not 

provided a sufficient explanation for the inconsistencies between cash on hand and 

excess cash for prior years as reported on the Cash Flow Statement of your 

Interagency Biographical and Financial Report ("IBFR"). The business plan for 

The Community's Bank provided with the Notice included a substantial number of 

material deficiencies. For example, it did not identify new management or new 

directors; failed to describe proposed loan products; lacked supporting detail 

regarding management of the projected aggressive growth in loans; lacked 

supporting information to justify the bank's total risk-based capital ratios falling 

below well-capitalized levels; lacked an explanation regarding how nonperforming 

assets would be addressed; failed to address concerns regarding the proposed loanreferral relationships between the bank and other companies that you own or 

control; and failed to describe how The Community's Bank would meet all the 

requirements of its February 2010 consent order with the Federal Deposit 

Insurance Corporation ("FDIC"). 
In addition, the Board is required to consider your integrity. Your 

IBFR failed to fully disclose or explain your lengthy arrest history and the 

existence or resolution of several tax liens in the public record. You failed to 

provide sufficient follow-up information on these matters despite requests from 

Board staff and your representations that you would do so. You and the companies 

you own or control are currently involved in several investigations by federal and 

state authorities into their business practices. You did not provide an adequate 

explanation of these investigations, as requested by Board staff. 

The Board also is required to consider your managerial competence and 

experience. You do not have any experience in the banking industry and have not 

provided evidence of any formal training or education related to banking or the 

financial sector. You also have not identified any persons with banking experience 

whom you would recruit to take over key decisionmaking roles at The Community's 

Bank. 

The Connecticut Department of Banking has requested that the Board 

take expedited action on the Notice. The Board's regulations permit the Board to 

shorten or waive the public comment or newspaper publication requirements and to 

act on a notice before the expiration of a public comment period, if it determines in 

writing that an emergency exists or if delay until the expiration of the comment 

period would seriously threaten the safety or soundness of the bank to be acquired. 

(Footnote 5.12 CFR 225.43(c)(5).End footnote.) 

After consultation with the FDIC, the Board finds that the current condition of The 

Community's Bank requires immediate action and has waived the remainder of the 

period for receiving public comment on the notice. 

Based on the facts discussed above and all other facts of record, and 

after consultation with the FDIC, the Board finds that you have not provided 

material information that is required to be filed and that is necessary for the 

Board's review of and determination on the proposal under the CIBC Act. 

Accordingly, the Notice is disapproved. 
You may submit a written request for a hearing on the Board's 

determination within 10 days of receipt of this notice of disapproval. 

(Footnote 6. 12 U.S.C. § 18170(4). End footnote.) Such a 

request should be addressed to me, Robert deV. Frierson, Secretary of the Board, 

Board of Governors of the Federal Reserve System, Washington, DC 20551. 

Sincerely yours, 

(Signed by) Robert de V. Frierson Secretary of the Board 

cc: Ivan J. Hurwitz, Vice President 

Federal Reserve Bank of New York 

Daniel Frye, Area Director 

Federal Deposit Insurance Corporation 

Howard F. Pitkin, Commissioner 

Connecticut Department of Banking 

William W. Bouton III, Partner 

Hinckley, Allen & Snyder LLP