OCTOBER 2025 – ONGOING LITIGATION

The PosiGen Financial Crisis

$30 Million in Ratepayer Funds at Risk

CGB's subordinated position behind $600M Wall Street debt: How public funds became "first loss" capital to protect Brookfield Asset Management

$30,000,000
Connecticut Ratepayer Funds in Jeopardy – Junior Lien Behind Brookfield's $600M

What Happened: Financial Audit Summary

Fact Check: Not a Bankruptcy—But Worse

PosiGen is NOT in bankruptcy liquidation. Instead, it is in severe financial distress involving a default on $600 million in senior debt held by Brookfield Asset Management. CGB has filed a lawsuit alleging that Brookfield "manufactured" the default and is using it to seize control of PosiGen's assets—potentially wiping out CGB's $30 million subordinated position.

Case Details:
Connecticut Green Bank v. PosiGen, PBC et al.
U.S. District Court, District of Connecticut
Docket No. 3:2025cv01841 | Filed: October 30, 2025

The Central Conflict of Interest

🏛️

Connecticut Green Bank

Holds $30M subordinated debt

Ben Healey
2012-2019
Director of Clean Energy Finance
REVOLVING DOOR
2019
🏢

PosiGen

Negotiates with Brookfield

Ben Healey
2019-2025
CFO → President

The Conflict

Ben Healey, as PosiGen President, negotiated the Brookfield $600M senior facility that subordinated his former employer (CGB) to last position. He had insider knowledge of CGB's risk tolerance, decision-making processes, and political constraints from his 7 years designing their financing structures.

What Healey Knew:
  • CGB's underwriting standards
  • Board approval processes
  • Political pressures on CGB
  • Acceptable risk levels
What Healey Did:
  • Convinced CGB to stay subordinated
  • Negotiated $600M senior to Brookfield
  • Put ratepayer funds at bottom of stack
  • Benefited PosiGen/himself at CGB's expense
1

CGB finances PosiGen

with $30M second-lien credit agreement (subordinated debt)

2

Ben Healey leaves CGB (2019)

→ becomes PosiGen CFO, then President

3

Brookfield invests $600M

as senior lender via BID Administrator LLC

4

Brookfield allegedly "manufactures" default

to seize control of PosiGen assets

5

CGB files lawsuit (Oct 30, 2025)

alleging tortious interference and fraudulent transfer

6

Court denies CGB injunction (Nov 2025)

Brookfield proceeds with asset seizure

The Architecture of the Capital Stack: Engineering Public Loss

Moral Hazard: Public Funds as Private Insurance

The PosiGen case exemplifies "moral hazard" embedded in CGB's operating model: the financial structure was deliberately engineered to ensure that ratepayers lost first and Wall Street was protected. This was not an unfortunate accident—it was a contractual design that converted public funds into an insurance policy for private wealth.

Understanding the Capital Stack: Priority of Payment

In structured finance, the "capital stack" determines who gets paid in what order. The priority of payment dictates risk allocation. Senior lenders are paid first; junior lenders are paid last—if anything remains.

By accepting a subordinated position, CGB transformed $30 million in ratepayer funds into what the industry calls "first loss" capital—the money that absorbs all downside risk before private investors lose a single dollar.

🏦

SENIOR LENDER

First-Lien Position

$600M

Brookfield Asset Management

Rights & Protections:

  • ✓ Paid FIRST in liquidation
  • ✓ First lien on all solar assets
  • ✓ Control of foreclosure process
  • ✓ Absolute priority over junior debt
  • ✓ Full recovery before anyone else
1st
PAYMENT
PRIORITY
2nd
PAYMENT
PRIORITY
🏛️

JUNIOR LENDER

Second-Lien Position

$30M

Connecticut Green Bank
(Ratepayer Funds)

Risk Exposure:

  • ✗ Paid AFTER Brookfield made whole
  • ✗ Second lien (subordinated to senior)
  • ✗ No control over asset disposition
  • ✗ Loses everything if assets < $600M
  • "First Loss" capital

The Mathematical Certainty of Loss

IF PosiGen's assets are worth ≤ $600M:

Brookfield = $600M recovered
CGB = $0 recovered

This is not an accident. This is a structural design that ensures ratepayers absorb losses before Wall Street takes any hit.

The Capital Stack: Who Gets Paid First?

Senior Lender (1st Priority)

$600M
Brookfield Asset Management
(via BID Administrator LLC)
Gets paid FIRST in any liquidation

Junior Lender (2nd Priority)

$30M
Connecticut Green Bank
(Second-lien credit agreement)
Gets paid AFTER Brookfield

Why This Structure Is Reckless

In a subordinated position, CGB's $30 million only gets repaid AFTER Brookfield's $600 million is fully paid. If PosiGen's assets are worth less than $600M, ratepayers get ZERO. CGB effectively functioned as "first loss" capital—absorbing all downside risk to protect Brookfield's investment.

This is the opposite of CGB's mandate. Public funds should catalyze private investment, not subordinate taxpayer money to de-risk Wall Street.

CGB's Lawsuit: Allegations of Misconduct by Brookfield

1Manufactured Default

CGB alleges that Brookfield deliberately engineered a default by PosiGen in order to seize control of the company's assets (the "Backleverage Entities")—effectively stripping value away from junior creditors like CGB.

Legal Claim: Tortious interference with CGB's contractual rights and fraudulent transfer of assets.

2The "Bridge Loan" Trap

According to CGB's complaint, Brookfield forced PosiGen to accept a "Bridge Loan" that further encumbered the company's assets—diluting CGB's security interest and transferring value from PosiGen to Brookfield entities.

Impact: The Bridge Loan stripped equity value and made CGB's position even more subordinated, reducing the likelihood of recovery.

3Threats and Coercion

CGB claims a Brookfield executive threatened that CGB would be "dead to Brookfield" if they did not waive their contractual rights to restrict additional debt on PosiGen's balance sheet.

Allegation: Brookfield used its market power to pressure CGB into accepting terms that benefited Brookfield at ratepayers' expense.

The "Manufactured Default" Theory: Business Failure vs. Predatory Finance

A Critical Distinction

CGB's lawsuit alleges that PosiGen did not naturally fail due to market conditions or business mismanagement. Instead, CGB claims that Brookfield engineered a technical default to accelerate the debt and seize the collateral—the portfolio of solar assets worth hundreds of millions of dollars. This distinction between organic failure and predatory financial maneuvering is critical for understanding the legal liability and moral accountability.

How a "Manufactured Default" Works

Natural Business Failure

  • Revenue declines due to market forces
  • Operating expenses exceed income
  • Company cannot service debt obligations
  • Default occurs organically
  • All creditors harmed equally

Manufactured Default

  • Senior lender creates technical violations of loan covenants
  • Forces additional debt that company can't service
  • Declares default to trigger acceleration
  • Seizes collateral before junior creditors can react
  • Senior lender profits; junior lenders wiped out

CGB's Specific Allegations

  1. The Bridge Loan Maneuver: Brookfield allegedly forced PosiGen to accept a "Bridge Loan" that further encumbered assets, making it mathematically impossible for PosiGen to meet all debt obligations.
  2. Covenant Violations: Brookfield allegedly manufactured technical violations of loan covenants—minor contractual breaches that trigger default provisions despite the company being operationally viable.
  3. Acceleration of Debt: Once the "default" was declared, Brookfield accelerated the entire $600M debt obligation, making it immediately due and payable—a demand no company could meet.
  4. Asset Seizure: Under the senior lien, Brookfield took control of the "Backleverage Entities" (the holding companies that own the solar portfolios), effectively seizing $600M+ in assets.

The Financial Mechanics: How CGB's $30M Gets "Vaporized"

1
Pre-Default State:

PosiGen owns solar assets worth (estimate) $650M. Brookfield holds $600M senior debt; CGB holds $30M junior debt. If sold normally, CGB would recover $30M after Brookfield gets $600M.

2
Brookfield Manufactures Default:

Brookfield forces Bridge Loan and declares covenant violations. Accelerates $600M debt obligation. PosiGen cannot pay—triggering foreclosure process.

3
Brookfield Seizes Assets:

Under first-lien rights, Brookfield takes control of the Backleverage Entities (solar portfolios). Assets are now valued at foreclosure sale prices, typically lower than market value—often right around $600M.

4
CGB's $30M is Vaporized:

Assets are now controlled by Brookfield and valued near the $600M senior debt. CGB's second-lien position is worthless. Ratepayers lose $30 million. Brookfield is made whole; Wall Street wins; ratepayers lose.

The Key Insight: This Is Not Random Bad Luck

Because the assets are now under Brookfield's control and likely valued near or below the $600M senior debt amount, CGB's junior debt is effectively vaporized. This is not an unfortunate business failure—this is a predatory financial maneuver that transfers value from junior creditors (ratepayers) to senior creditors (Wall Street).

Why This Matters for Legal Liability

If CGB's allegations are true—that Brookfield manufactured the default rather than PosiGen naturally failing—then this is not merely a failed investment. It is a case of:

  • Tortious interference with CGB's contractual rights
  • Fraudulent transfer of assets to benefit senior lenders
  • Breach of fiduciary duty (if PosiGen management aided Brookfield)
  • Potential racketeering under RICO (if pattern of conduct exists)

This transforms the PosiGen loss from a governance failure into a criminal investigation—with implications for CGB's fiduciary responsibility to ratepayers and potential personal liability for board members who approved the subordinated structure.

The Three Fatal Failures by CGB

1Accepting Subordination

CGB accepted a junior/second-lien position behind Brookfield's $600 million senior debt. This means ratepayer funds were used to de-risk Brookfield's investment—public money protecting Wall Street.

Why This Matters: Ratepayer funds should NEVER be subordinated to private equity. The state's role is to catalyze investment, not to absorb all downside risk.

2Revolving Door: Ben Healey

Ben Healey spent 7 years at CGB designing financing structures. He then left to become PosiGen's CFO, then President—all while CGB continued expanding PosiGen's credit lines and agreeing to unfavorable subordination terms.

Why This Matters: Did insider relationships influence CGB's decision to stay in a losing position? Was there oversight of this conflict?
The Revolving Door Mechanism: Timeline of Insider Influence

The transition of Ben Healey from regulator to regulated entity creates a distinct appearance of impropriety. The timeline suggests a causal link between insider knowledge and the unfavorable debt structure.

Year Event Implication
2012-2019 Ben Healey directs Clean Energy Finance at CGB Gains intimate knowledge of CGB risk tolerance, underwriting standards, and political constraints.
2019 Healey exits CGB to become CFO/President of PosiGen "Revolving Door" turns; former regulator joins the regulated entity.
2020-2024 PosiGen negotiates debt facility with Brookfield Healey allegedly uses insider knowledge to keep CGB in a junior position while negotiating favorable terms for Brookfield.
Oct 2025 CGB files lawsuit (CT Green Bank v. PosiGen) Alleges Brookfield "manufactured" a default to wipe out CGB's subordinated position.
Nov 2025 Court denies injunction Assets seized by Brookfield; Ratepayer funds likely lost ($30M).

The Critical Question:

Did Healey use his 7 years of insider knowledge about CGB's decision-making processes, risk tolerance, and political pressures to structure a deal that benefited PosiGen and Brookfield at the expense of his former employer and Connecticut ratepayers?

3No Exit When Private Capital Arrived

When Brookfield invested $600M, it validated that private capital was available. CGB should have exited per its statutory mandate to "crowd in" private capital. Instead, it stayed subordinated.

Why This Matters: CGB's mandate is to attract private capital, then exit. Staying in after Brookfield's entry violated that mandate and exposed ratepayers to unnecessary risk.

Complete Timeline: From Relationship to Ruin

Phase 1: The Setup (2012-2019)

2012-2019

Ben Healey at Connecticut Green Bank

Position: Director of Clean Energy Finance (7 years)

Responsibilities:

  • Design CGB's residential financing products
  • Structure "Solar for All" partnerships for LMI households
  • Evaluate and recommend lending relationships
  • Help launch Inclusive Prosperity Capital (2018)
  • Participate in PosiGen credit facility approvals
Insider Knowledge Acquired:
  • CGB's underwriting standards and risk tolerance
  • How to structure deals to pass CGB Board approval
  • Relationships with key CGB decision-makers
  • CGB's priorities and political constraints
2019

Initial CGB-PosiGen Credit Facility

CGB authorizes initial credit line to PosiGen for residential solar financing targeting low-to-moderate income (LMI) households. Positioned as "mission-aligned" investment serving underserved markets.

Initial Amount: Millions in credit authorization (exact amount redacted in public minutes)

Justification: Fill market gap for LMI solar financing

Structure: Warehouse credit line for PosiGen's solar leases

Phase 2: The Revolving Door (2019)

Early 2019

Ben Healey Leaves CGB → Joins PosiGen

FROM:

Connecticut Green Bank

Director of Clean Energy Finance

Approving/designing PosiGen financing

TO:

PosiGen

Chief Financial Officer (CFO)

Receiving CGB financing

The Conflict of Interest

Before leaving: Healey participated in structuring the PosiGen relationship while at CGB

After leaving: Healey benefits from that same relationship as PosiGen executive

Ongoing: His former CGB colleagues continue approving PosiGen credit expansions

Questions This Raises:
  • Did Healey negotiate his PosiGen employment while still at CGB?
  • Did he structure CGB-PosiGen deals favorably knowing he'd benefit?
  • Did his CGB connections give PosiGen unfair advantage over competitors?
  • Did CGB extend extraordinary leniency to PosiGen because of personal relationships?
Healey's Public Statements at PosiGen

"I'm excited to join PosiGen...to expand access to clean energy for families who have been traditionally underserved."

— Ben Healey, PosiGen Press Release, 2019

No disclosure that he came directly from the entity providing PosiGen's financing. No acknowledgment of potential conflict.

Phase 3: Continued Expansion (2020-2022)

2020-2022

CGB Continues Supporting PosiGen (Healey Now Inside)

Despite Healey's departure creating obvious conflict, CGB Board continues approving modifications, extensions, and expansions to PosiGen's credit facilities.

Documented CGB Board Actions:
Date Action Healey's Role at PosiGen
Dec 2019 Credit facility renewal CFO (6 months in role)
2020 Facility modification CFO
2021-2022 Extensions approved Chief Commercial Officer
Where Was the Oversight?

No evidence that CGB Board:

  • Disclosed Healey's conflict to the public
  • Required independent valuation of PosiGen deals post-Healey
  • Implemented enhanced scrutiny due to revolving door issue
  • Considered whether relationship was now compromised

Result: Business as usual, despite obvious appearance of corruption

Phase 4: The Catastrophic Decision (2023-2024)

2023-2024

Brookfield's $600 Million Senior Loan

PosiGen secures massive credit facility from Brookfield Asset Management, one of the world's largest alternative asset managers ($1 trillion+ AUM).

Deal Structure:
  • Lender: Brookfield Asset Management (private equity giant)
  • Amount: $600 million senior secured credit facility
  • Priority: First lien (paid first in liquidation)
  • Collateral: All PosiGen assets, solar portfolios, customer contracts
  • Terms: Standard institutional rates (undisclosed, but likely SOFR + 400-600bps)
What Brookfield's Investment Meant:
Market Validation Signal

When a sophisticated $1 trillion institutional investor deploys $600 million, it means:

  • PosiGen's business model has been thoroughly vetted
  • The LMI solar market is viable and profitable
  • Private capital is abundant and willing
  • There is NO market failure requiring public subsidy
What CGB Should Have Done:
Rational Response: EXIT

CGB's statutory mandate is to "crowd in" private capital. When Brookfield deployed $600M, the crowding-in was complete. CGB should have:

  1. Negotiated exit: Refinanced CGB's position into Brookfield facility
  2. Declared victory: "Mission accomplished—private capital engaged"
  3. Redeployed funds: Moved capital to actual market gaps
  4. Avoided subordination: Never accepted junior position behind massive private lender

Result: Ratepayer funds protected, mission fulfilled, no loss risk

2024

CGB Accepts Subordinated Position

Instead of exiting, CGB makes the catastrophic decision to STAY IN as a junior/subordinated lender.

The Subordination Structure:
SENIOR SECURED (Paid First)
Brookfield Asset Management
$600,000,000
100% collateral protection

If assets remain after Brookfield paid...

SUBORDINATED/JUNIOR (Paid Second)
Connecticut Green Bank (Ratepayer Funds)
~$30,000,000
ZERO protection (first-loss position)
What This Subordination Means in Plain English:

Scenario: PosiGen Goes Bankrupt

  1. Assets are sold: Solar panels, customer contracts liquidated (typically at 30-50% of book value in distress)
  2. Brookfield gets paid FIRST: Every dollar from sale goes to Brookfield until their $600M is satisfied
  3. IF anything is left over: (highly unlikely) CGB gets paid from remainder
  4. Reality: Distress sale rarely covers senior debt. Junior debt = total loss.
Example Math:
PosiGen Assets (Book Value): $700 million
Distress Sale Value (40% recovery): $280 million
Brookfield Claims: $600 million
Shortfall: -$320 million
CGB Recovers: $0
Who Benefits from This Structure?
Brookfield Benefits:
  • $30M cushion below them (de-risked)
  • If PosiGen succeeds: collect interest + principal
  • If PosiGen fails: CGB absorbs first $30M of loss
CGB (Ratepayers) Exposed:
  • If PosiGen succeeds: modest interest (below market)
  • If PosiGen fails: 100% loss of $30M
  • Asymmetric risk: all downside, little upside

Conclusion: CGB used ratepayer money to subsidize Brookfield's risk. This is not "crowding in" private capital—it's protecting private equity at public expense.

Ben Healey's Role at This Time

Position in 2024: President of PosiGen (promoted from CCO)

Healey, the former CGB executive who designed these financing structures, is now President of the company receiving this subordinated public financing from his former colleagues.

Critical Question: Did CGB's willingness to accept this terrible subordinated position have anything to do with Healey's presence at PosiGen?

Phase 5: The Collapse (2025)

August 4, 2025

PosiGen Defaults

PosiGen subsidiaries default on required interest payments to the "Backleverage Entities" controlled by Brookfield.

Trigger Event: Missed debt service payments

Brookfield's Response: Exercise control rights as senior lender

CGB's Position: Powerless to intervene (junior lender has no say)

Aug-Oct 2025

Brookfield Seizes Control

As senior secured lender, Brookfield:

  • Appoints independent manager to PosiGen
  • Initiates "Bridge Loans" with super-priority status
  • "Primes" existing debt (pushes CGB further down payment waterfall)
  • Prepares for restructuring that will wipe out junior creditors

CGB watches helplessly as private equity firm executes standard distressed playbook. Ratepayer funds have zero protection.

October 30, 2025

CGB Files Lawsuit (Desperate Hail Mary)

Case: Connecticut Green Bank v. PosiGen PBC, Case No. 3:25-cv-01841, U.S. District Court, District of Connecticut

CGB's Claims:
  • Breach of contract
  • Violation of "PBC Debt Restrictions"
  • Brookfield acting in "willful and wanton disregard" of junior creditors
  • Request for Temporary Restraining Order (TRO) and Preliminary Injunction
From CGB's Own Complaint:

"Without court intervention, CGB's position will be 'wiped out' and left 'dead' to Brookfield."

— CGB Complaint, Oct 30, 2025

CGB's own lawyers admit in federal court that ratepayer funds are about to be obliterated. This admission comes months AFTER they accepted the subordinated position.

November 12, 2025

Court Denies CGB's Injunction

U.S. District Court Judge denies CGB's request for preliminary injunction.

Court's Implicit Message:

"You voluntarily agreed to be a subordinated creditor. You cannot ask the court to rescue you from your own bad decisions when the consequences arrive."

November 2025

PosiGen Files Chapter 11 Bankruptcy

PosiGen PBC files for bankruptcy protection. CGB's subordinated debt is effectively unsecured.

Impact on CGB/Ratepayers:

Outstanding CGB Debt at Bankruptcy: ~$2 million principal (after Jan 2025 repayment)

Total CGB Exposure (all time): ~$30 million

Expected Recovery: $0 - $0.10 on the dollar (0-10%)

ESTIMATED TOTAL LOSS:

$30,000,000 of ratepayer funds

Additional Risk: Preferential Transfer Clawback

In January 2025, PosiGen repaid ~$12 million to CGB following Brookfield facility upsizing. CGB defenders claim this shows "prudent risk management."

11 U.S.C. § 547 - Bankruptcy Code

Payments made within 90 days of bankruptcy (or 1 year for "insiders") can be clawed back by bankruptcy trustee if:

  • Debtor was insolvent at time of payment
  • Payment gave creditor more than they'd get in bankruptcy
Is CGB an "Insider"?

Given Ben Healey's CGB→PosiGen career path and ongoing governance connections (Bert Hunter on both CGB and IPC boards, IPC's PosiGen relationship), bankruptcy trustee could argue CGB is an "insider" qualifying for 1-year look-back.

Result: CGB may be forced to return the $12M, increasing total loss to $42 million+

The Revolving Door: Ben Healey's Career Path

2012-20197 YEARS

Connecticut Green Bank

Director of Clean Energy Finance

What He Did:
  • Designed CGB's residential financing programs
  • Structured "Solar for All" LMI partnerships
  • Evaluated lending relationships (including PosiGen)
  • Participated in launching IPC (2018)
  • Built relationships with solar installers and financiers
Knowledge/Leverage Gained:
  • CGB's underwriting criteria
  • Board approval processes
  • Risk tolerance thresholds
  • Personal relationships with decision-makers
  • Political/strategic priorities

Early 2019

LEAVES PUBLIC SERVICE → JOINS PRIVATE BENEFICIARY

Unanswered Questions:

  • When did PosiGen recruitment begin?
  • Was Healey negotiating while still at CGB?
  • Did he recuse from PosiGen matters before leaving?
  • What was his final involvement in PosiGen approvals?
2019-20256+ YEARS

PosiGen

CFO → CCO → President

What He Did:
  • As CFO (2019-2022): Managed finance, secured Brookfield deal
  • As CCO (2022-2024): Oversaw commercial operations
  • As President (2024-2025): Led entire company until bankruptcy
How CGB Connections Benefited PosiGen:
  • Continued CGB financing approvals (2020-2024)
  • Trust/relationships with former colleagues
  • Insider knowledge of how to structure acceptable deals
  • Possible preferential treatment due to personal ties

Healey's Public Statements: No Disclosure of Conflict

PosiGen Press Release, 2019

"I'm excited to join PosiGen in their mission to expand access to clean energy for families who have been traditionally underserved..."

What He Didn't Say:

  • I just left the Connecticut Green Bank
  • CGB is one of PosiGen's primary financiers
  • I participated in structuring that financing relationship
  • My former colleagues will continue approving PosiGen credit

Authority Magazine Interview, 2023

"The future is green...PosiGen is leading the way in making solar accessible to all income levels..."

— Ben Healey, "The Future Is Green" interview

Still No Disclosure: Years later, still no acknowledgment of the revolving door or potential conflicts arising from his CGB tenure.

The Ethical and Legal Questions

1. Timing of Employment Negotiations

Q: When did PosiGen approach Healey about employment?

If negotiations began while he was still at CGB and involved in PosiGen matters, that's a clear conflict of interest.

Q: Did Healey properly recuse himself from PosiGen decisions before leaving?

No public record of recusal. CGB Board minutes from late 2018/early 2019 are heavily redacted.

2. Use of Insider Knowledge

Q: Did Healey use CGB insider knowledge to structure PosiGen deals?

He knew exactly what CGB would accept, what risk tolerance was, who to influence. This gave PosiGen unfair advantage over competitors.

Q: Did PosiGen's ability to secure favorable terms depend on Healey's connections?

Other LMI solar installers did not get same access or terms from CGB. Why was PosiGen special?

3. Continued Preferential Treatment

Q: Did CGB extend extraordinary leniency to PosiGen because of Healey?

Even as PosiGen showed signs of distress (2024-2025), CGB continued supporting it. Was this because of personal loyalty to former colleague?

Q: Would CGB have accepted subordinated position behind Brookfield for any other company?

This decision was financially irrational. Did personal relationships cloud judgment?

4. No Cooling-Off Period

Current CT Law: No statutory cooling-off period for quasi-public agency executives joining companies they regulated/financed.

What's Needed: Mandatory 2-year prohibition on joining entities that received financing from CGB within prior 5 years.

What Should Have Happened: Fiduciary Best Practices

What Actually Happened

  1. 2019: Initial PosiGen financing

    Acceptable as market gap

  2. 2019: Healey leaves CGB → joins PosiGen

    Creates conflict, no cooling-off period

  3. 2020-2022: Continue financing PosiGen despite Healey conflict

    No enhanced scrutiny or independence

  4. 2023-2024: Brookfield invests $600M (market validated)

    CGB should EXIT but doesn't

  5. 2024: Accept $30M subordinated position behind Brookfield

    Ratepayer funds as first-loss capital

  6. Aug 2025: PosiGen defaults

    Predictable outcome of subordination

  7. Nov 2025: Bankruptcy, $30M lost

    Total fiduciary failure

What Should Have Happened

  1. 2019: Initial PosiGen financing

    Fill genuine market gap ✓

  2. 2019: Healey announces PosiGen employment

    Immediate recusal from all PosiGen matters; 2-year cooling-off period enforcement

  3. Post-Healey: Independent review of PosiGen relationship

    Third-party valuation to ensure no favoritism

  4. 2023-2024: Brookfield invests $600M

    EXIT IMMEDIATELY - Mission accomplished, private capital engaged

  5. Alternative 2024: If CGB had stayed in

    Demand pari passu (equal) status with Brookfield, never subordinate

  6. 2024: If unable to get pari passu

    REFUSE to participate - don't accept subordination

  7. Outcome: Ratepayer funds protected

    $30M deployed to actual market gaps (storage, deep retrofits, etc.)

Legislative Reforms to Prevent Future PosiGens

Reform #1: Revolving Door Ban

Proposed Statute:

"No person who has served as an officer, director, or senior executive of the Connecticut Green Bank shall, for a period of two (2) years following termination of service, serve as an officer, director, employee, or consultant of any entity that has received financing, grants, or other financial assistance from CGB within the preceding five (5) years."

Penalty for Violation: Forfeiture of CGB retirement benefits + civil fines

Reform #2: Subordination Ban

Proposed Statute:

"CGB shall be prohibited from holding subordinate debt or equity positions in any transaction where a private institutional lender holds a senior position exceeding ten times (10x) the Green Bank's investment amount."

Rationale: If Brookfield has $600M and CGB has $30M (20:1 ratio), CGB is clearly being used as first-loss capital to de-risk private equity.

Reform #3: Mandatory Exit Trigger

Proposed Statute:

"When a CGB-supported entity secures senior private financing exceeding 10x CGB's investment, CGB must either: (a) exit the transaction within 12 months, OR (b) convert its position to pari passu (equal priority) status with the private lender."

Effect: Forces CGB to declare victory and exit when private capital validates the market, fulfilling the "crowd in" mandate.

Reform #4: Enhanced Conflict Disclosure

Proposed Statute:

"Any CGB financing or contract modification involving an entity where current or former CGB officials (within 5 years) hold executive positions must be:

  • (a) Publicly disclosed 30 days before Board vote
  • (b) Approved by independent third-party valuation
  • (c) Certified by DEEP Commissioner as free from conflict

The Bottom Line

The Facts Are Undeniable:

  • $30 million in ratepayer funds lost to bankruptcy
  • Ben Healey left CGB to lead PosiGen while CGB financed it
  • CGB accepted subordinated position behind $600M private lender
  • CGB stayed in deal after Brookfield validated market
  • Court rejected CGB's injunction - no legal remedy
  • PosiGen bankrupt - ratepayer recovery near zero

The Questions That Must Be Answered:

  • Why did CGB accept subordination when it had no legal or economic benefit?
  • Did personal relationships with Ben Healey influence continued PosiGen support?
  • Why didn't CGB exit when Brookfield's $600M proved market viability?
  • Who at CGB approved the catastrophic subordination decision?
  • Will anyone be held accountable for this $30 million loss?

The Inescapable Conclusion:

The PosiGen disaster is not a "market risk" story. It's a story of reckless governance, revolving door corruption, and fiduciary betrayal. Ratepayer funds were gambled away to subsidize private equity, with no oversight, no exit strategy, and no accountability.

This must never happen again. The reforms above are not optional—they are essential to protect Connecticut ratepayers from future Green Bank catastrophes.