Myrna Lozada was sitting beside me when OCIF Commissioner Natalia Zequeira told me I did not need to inject additional capital into Euro Pacific Bank. Yet when OCIF later closed the bank for insufficient capital, Myrna refused to put what she had witnessed in writing. Myrna, of Goldman, Antonetti & Córdova, P.S.C., had represented the bank before OCIF since its move to Puerto Rico in 2017. We relied on her and her firm’s expertise to comply with OCIF’s requirements. At our November 2021 meeting with the Commissioner, I offered to inject $7 million. The Commissioner told me not to. She said the bank could continue operating with its existing capital while OCIF reviewed the proposed change of control. Once approved, the new owner would supply the additional capital needed to meet the regulatory minimum. Myrna subsequently spoke with another OCIF official who confirmed that understanding. This was no incidental remark. Capital was a central issue, I offered a concrete solution, and the Commissioner expressly told me that my proposed contribution was unnecessary. From that meeting until the bank’s closure on June 30, 2022, Myrna never sent me or anyone at the bank a single email advising that additional capital was required. She knew the bank’s capital position. Her conduct throughout those months was consistent with precisely what I remember: OCIF had agreed that the additional capital could wait for approval of the change of control. I believe OCIF subsequently used the very capital shortfall it had allowed as a pretext to close the bank, coordinating with the IRS and ATO to present the closure as a J5 victory against tax evasion and money laundering. The bank was never told that the Commissioner had changed her position or that my offer to contribute capital should be revisited. When the bank was closed, the law firm we had relied on refused to continue representing me, forcing me to find new counsel. When I later asked Myrna to sign an affidavit documenting the Commissioner’s assurance, she claimed she could not remember it. I find that explanation impossible to accept. She heard the assurance, discussed it with me, and obtained confirmation from another OCIF official. For months afterward, she never advised us to act contrary to it. Yet when documenting that assurance became critical, she said she could no longer recall it. I believe her refusal was about protecting her relationship with OCIF and the Commissioner, whose goodwill mattered to her future practice. In my view, she put that relationship ahead of the client who had relied on her for years. She accepted years of legal fees to help us comply with OCIF’s requirements. But when OCIF acted against the bank on an issue she had personally helped us address, she would neither continue representing us nor document what she had witnessed. That is why I regard her conduct as a profound betrayal.
