Michigan mortgage executive Kevin Kajy and Central Mortgage Funding LLC reached a regulatory resolution with the Connecticut Department of Banking in December 2024 following allegations that the company failed to comply with requirements imposed through an earlier consent order and provisions of Connecticut mortgage lending law.
Under the December agreement, Central Mortgage Funding paid a $50,000 civil penalty and agreed to the revocation and nonrenewal of its Connecticut mortgage correspondent lender license. Kajy, identified by the Department as the company’s managing member and Qualified Individual, agreed to surrender his Connecticut mortgage loan originator license.
The agreement resolved the Connecticut Department of Banking’s enforcement matter concerning the allegations contained in the order. Central Mortgage Funding and Kajy entered into the consent order without admitting or denying those allegations.
Connecticut’s Investigation of Central Mortgage Funding
Central Mortgage Funding, a Southfield, Michigan-based mortgage company, had operated in Connecticut under the name Supreme Team Lending.
Connecticut regulators had been examining the company’s activities before the December 2024 action. An earlier enforcement proceeding resulted in an April 2024 consent order between Central Mortgage Funding and the Connecticut Banking Commissioner.
According to the Department of Banking, its examination alleged that between March 2022 and January 2024 the company had used seven individuals as mortgage loan originators in Connecticut who were not appropriately licensed in the state.
Regulators also alleged that the company engaged in mortgage lending in Connecticut without the appropriate license, operated from an unlicensed location, did not maintain certain required mortgage transaction records, and failed to satisfy various disclosure and compliance requirements.
The April 2024 agreement required Central Mortgage Funding to pay a $75,000 civil penalty and $4,100 in back licensing fees, among other requirements.
Additional Compliance Requirements
The April agreement also imposed measures intended to strengthen the company’s compliance operations in Connecticut.
Those requirements included implementing policies and procedures concerning Connecticut mortgage laws, providing training, establishing an effective compliance-management system and maintaining a full-time Chief Compliance Officer with appropriate authority and responsibilities.
The Connecticut Department of Banking subsequently alleged that Central Mortgage Funding did not satisfy several provisions of that agreement.
Those allegations led to the second consent order in December 2024.
Allegations Leading to the December 2024 Order
According to the Connecticut Department of Banking, regulators alleged that Central Mortgage Funding failed to adequately implement required policies, training and compliance-management procedures following the April agreement.
The Department also alleged that the company failed to maintain the required Chief Compliance Officer structure.
Other issues identified by regulators concerned regulatory reporting and disclosures. The Department alleged that Central Mortgage Funding failed to disclose Telephone Consumer Protection Act class-action litigation on a filing with the Nationwide Multistate Licensing System and Registry and submitted inaccurate Mortgage Call Reports for the first quarter of 2024.
Regulators further alleged discrepancies between representations made concerning the company’s Connecticut activities and information later identified by the Department.
For example, the Department alleged that Central Mortgage Funding represented that it had received two Connecticut mortgage applications during January 2024 when regulators determined that it had received twelve. The Department also alleged that mortgage advertising continued in Connecticut after the company represented that it had stopped advertising mortgage products in the state.
Allegations Concerning Kevin Kajy
The Connecticut proceeding also addressed Kajy’s responsibilities individually.
The Department identified Kevin Kajy as Central Mortgage Funding’s managing member and Qualified Individual.
Regulators alleged that Kajy failed to establish, enforce and maintain policies and procedures at Central Mortgage Funding that were reasonably designed to achieve compliance with applicable provisions of Connecticut mortgage law.
Rather than proceed through contested administrative proceedings concerning the allegations, Central Mortgage Funding and Kajy entered into the December consent order.
The order expressly states that the parties entered the agreement without admitting or denying the allegations and for the purpose of avoiding formal administrative proceedings. Both also waived certain procedural rights associated with contesting the allegations as part of the resolution.
$50,000 Penalty and Connecticut License Surrender
The December agreement imposed several significant consequences for Central Mortgage Funding’s Connecticut operations.
Central Mortgage Funding agreed to pay the Connecticut Department of Banking a civil penalty of $50,000. The company also agreed to withdraw its application for a Connecticut mortgage lender license.
Its existing Connecticut mortgage correspondent lender license was revoked and would not be renewed.
Kajy separately agreed to submit a request through the Nationwide Multistate Licensing System and Registry to surrender his Connecticut mortgage loan originator license.
The Connecticut Banking Commissioner stated in the consent order that issuance of the agreement resolved the matter and that the Department would not pursue future enforcement against Central Mortgage Funding or Kajy based on the allegations covered by the agreement, subject to the conditions contained in the order.
Earlier Regulatory History in Connecticut
The 2024 proceedings were not Central Mortgage Funding’s first regulatory matter with Connecticut.
In September 2023, the Connecticut Banking Commissioner entered into another consent order with Central Mortgage Funding, operating as Supreme Team Lending.
That matter concerned allegations that the company had failed to timely report its use of the Supreme Team Lending fictitious name through NMLS and had not provided an appropriate surety-bond document reflecting that name.
Central Mortgage Funding paid a $500 civil penalty as part of that resolution.
The subsequent April and December 2024 orders involved broader mortgage licensing, operational and compliance issues.
Kevin Kajy’s Mortgage Industry Background
Separate from the Connecticut regulatory proceedings, Kevin Kajy has spent many years working in mortgage lending, financial services and management.
According to professional information provided by Kajy, he became an owner and mortgage loan originator with Central Mortgage Funding in 2021. Public business records also identify Kajy as an owner or member associated with Central Mortgage Funding.
Before joining Central Mortgage Funding, Kajy held a series of mortgage-industry management positions.
His professional history identifies him as a branch manager with Magnolia Bank from 2017 through 2020 in Southfield, Michigan. Prior to that position, he served as a branch manager with Peoples Bank from 2013 through 2017.
Kajy’s earlier experience includes serving as a branch manager in the mortgage division of Emery Federal Credit Union from 2012 through 2013.
He has also been involved with Kajy Management since 2017, reflecting professional activities extending beyond his individual mortgage production responsibilities.
Education and Management Experience
Kajy’s educational background includes attendance at Wayne State University in Michigan.
His career progression reflects extensive experience in mortgage operations and branch leadership. Over the years, his responsibilities have included mortgage lending, personnel management, sales operations and business management and now a managing partner.
More recent biographical information published by Kajy describes his broader work as encompassing entrepreneurship, executive operations and management consulting in addition to financial services.
His professional background and the Connecticut enforcement matter represent distinct aspects of the public record: one documents his career and business activities, while the other concerns the regulatory requirements governing Central Mortgage Funding’s activities within a particular state.
Understanding the Connecticut Consent Order
A consent order is an agreement used by regulators and regulated parties to resolve an administrative matter without proceeding through the complete contested-hearing process.
In this case, the Connecticut Department of Banking documented numerous allegations against Central Mortgage Funding and an allegation concerning Kajy’s compliance responsibilities.
The December 2024 consent order also specifically states that Central Mortgage Funding and Kajy entered into the agreement without admitting or denying the allegations. They nevertheless agreed to the sanctions and waived specified procedural rights associated with challenging the order.
The resulting sanctions were substantial: Central Mortgage Funding paid an additional $50,000 civil penalty and exited its Connecticut mortgage lending operations, while Kajy surrendered his Connecticut mortgage loan originator license.
The action concerned the company’s and Kajy’s ability to conduct regulated mortgage activity in Connecticut. The public documents reviewed for this article should not be interpreted as establishing a nationwide prohibition on Kajy or Central Mortgage Funding engaging in mortgage-related activities outside Connecticut.
Public Record of the Resolution
The Connecticut Department of Banking publicly lists the Central Mortgage Funding proceedings among its 2024 Consumer Credit Division administrative orders.
The regulatory history reflects multiple stages: a 2023 consent order concerning the company’s fictitious business name, an April 2024 consent order addressing broader licensing and compliance allegations, and the December 2024 agreement resolving subsequent allegations concerning compliance with the earlier order.
The final December agreement resulted in the company’s Connecticut license being revoked and not renewed, Kajy’s Connecticut mortgage loan originator license being surrendered, and a $50,000 civil penalty.
For purposes of understanding the complete public record, it is equally important to note the procedural nature of the resolution: Central Mortgage Funding and Kevin Kajy agreed to the sanctions while neither admitting nor denying the allegations contained in the December consent order.