Final Order — 137531 (Formerly 120559b)

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STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re: Case Number: 137531
(Formerly Case No. 120559b)
STEPHEN CHENG,
Respondent.
FINAL ORDER
This cause came on for consideration and final agency action. Upon rev complete record, and being otherwise fully advised in the premises, the Office of Financial Regulation (the "Office") hereby finds:

1. The Office has jurisdiction over the subject matter of this case and the parties
   hereto.
2. The entry of the Final Order concludes the above-referenced matter.
   ORDERED:
   A. The Settlement Stipulation and Consent Agreement (Exhibit A) is hereby approved and incorporated by reference as if fully stated herein, and is adopted as the Office's Findings of Fact and Conclusions of Law. The parties shall comply with all terms of the Settlement Stipulation and Consent Agreement. DONE and ORDERED this 17-fi.. day of April, 2026, in Tallahassee, Leon County, Florida. Commissioner

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished via electronic mail to Jose Leon, Esq., counsel to Respondent Stephen Cheng, at jleon@grsm.com, on this \ ~ day of April, 2026. 2 A~ ~y￾Office of Financial Regulation Post Office Box 8050 Tallahassee, FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

Exhibit A
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
STEPHEN CHENG, Case Number: 120559b
Respondent.
STIPULATION AND CONSENT AGREEMENT
The State of Florida, Office of Financial Regulation ("Office") and STEPHEN CHENG ("Cheng" or "Respondent"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. At all times material to this matter, Wyre Payments, Inc. d/b/a Wyre
   ("Wyre") was a money services business as defined by section 560.103(23), Florida Statutes (2023), licensed and operating as a money transmitter pursuant to Part II, chapter 560, Florida Statutes, having been issued License Number FT230000231 by the Office on October 3, 2018. From September 9, 2021 until his resignation on June 15, 2023, Cheng served as Chief Compliance Officer ("CCO") of Wyre. From January 3, 2023 until his resignation on June 15, 2023. Cheng also served as interim Chief Executive Officer ("CEO") of Wyre. During these periods, Cheng was a "control person" and "employee" of Wyre and was, therefore, an "affiliated party" of Wyre, as those terms are defined in subsections 560.103(1) and (I0)(c), Florida Statutes (2023). Accordingly, Cheng's activities as an affiliated party of Wyre during both of these periods fall within the Office's jurisdiction and supervision pursuant to chapter 560, Florida Statutes. Subsequent to the Office's examination (#114866) of Wyre's business records and operations to ascertain compliance with chapter 560, Florida Statutes, and its related rules, grounds to initiate an action against Wyre and its affiliated parties were found. An Administrative Complaint was issued to Wyre and another affiliated party on February 27, 2024. The Administrative Complaint was later amended on March 20, 2024 to include an additional count and a third respondent, Cheng, who had

resigned as CEO and CCO of Wyre on or about June 15, 2023 ("Amended Complaint"). Each of the three respondents timely requested a hearing. While in the process of privately winding down its business affairs, Wyre (along with the other affiliated party) entered into a settlement agreement with the Office that resulted in Wyre's consent to a voluntary license revocation; this agreement was incorporated in Final Order Number 2024-464, which was issued by the Office on August 6, 2024 and resolved Case Numbers 120559 and 120559a. Meanwhile, Cheng's case (Case No. 120559b) still remained pending with the Office, prompting the remaining parties to continue to pursue settlement discussions to explore potential avenues of resolution and avoid further litigation. By this Stipulation and Consent Agreement, Respondent Cheng and the Office are fully resolving all issues related to this matter prior to, and in lieu of, referring the matter to the Division of Administrative Hearings for purposes of an administrative hearing.
2. Jurisdiction. Pursuant to section 560.105, Florida Statutes, the Office is charged with
the responsibility of administering and enforcing the provisions of chapter 560, Florida Statutes. The Office has jurisdiction to bring this administrative action against Respondent Cheng pursuant to
chapter 560, Florida Statutes.
3. Findings. For purposes of this Stipulation and Consent Agreement, Respondent
Cheng neither admits nor denies the allegations asserted by the Office in the Amended Complaint. In resolution of the matter, Cheng consents to the Office making the following findings:
a. Because Wyre, following the cancelation of its $2,000,000 surety bond in Florida in 2023, failed to maintain a bond or alternative collateral deposit in the required amount, Wyre violated sections 560.l 14(1)(a) and 560.209(5), Florida Statutes; and b. Because Wyre failed to file a financial audit report for fiscal year 2022, Wyre violated sections 560.l 14(1)(a) and 560.209(2), Florida Statutes.

4. Terms and Conditions. Respondent Cheng and the Office agree that the issues raised
   can be expeditiously resolved without a hearing and that further litigation can be avoided by the execution of this Stipulation and Consent Agreement. The parties acknowledge they have read this Stipulation and Consent Agreement and fully understand the rights, obligations, terms, duties, and responsibilities with respect to its contents. Therefore, in compromise and settlement of the foregoing findings and in consideration of the parties' forbearance from further litigation, Respondent Cheng agrees to the following terms and conditions:
   a. FUTURE COMPLIANCE. Respondent Cheng shall not engage in violations of chapter 560, Florida Statutes, and its corresponding rules, and shall comply with all provisions of
   chapter 560, Florida Statutes, and its corresponding rules.
   b. ADMINISTRATIVE FINE. Respondent Cheng shall pay the Office a total administrative fine of FOUR THOUSAND FIVE HUNDRED DOLLARS ($4,500.00), to be paid at the time of the execution and delivery of this Stipulation and Consent Agreement. The administrative fine shall be submitted in the form of a wire, cashier's check, or money order made payable to the "Office of Financial Regulation" and shall be sent to the attention of Agency Clerk - c/o Brandon Greenberg, Esq., Assistant General Counsel, Post Office Box 8050, Tallahassee, Florida 32314-8050. Regarding the deposit of monies, Respondent Cheng acknowledges and agrees that, in accordance with section 215 .31, Florida Statutes, (i) the tendered fine or settlement check proceeds may be deposited in advance of full execution or acceptance of the proposed Stipulation and Consent Agreement; and (ii) such deposit shall not be construed as a final acceptance of the Stipulation and Consent Agreement absent full execution thereof and entry of a Final Order adopting same.

c. FUTURE APPLICATION. Respondent Cheng shall not engage in any
activity (including as an affiliated party of a money services business) pursuant to chapter 560, Florida Statutes, which requires a license from the Office, unless such money services business is licensed with the Office and Cheng, as required by applicable law, has been disclosed on the license application (if, based on his title and/or ownership status as to that money services business, such disclosure is required by chapter 560, Florida Statutes). Nothing herein restricts Respondent Cheng from providing consulting, advisory, employment, or other professional services for compensation to any money services business that is i) not engaged in activities requiring licensure pursuant to
chapter 560, Florida Statutes, and/or ii) in the process of seeking such licensure from the Office.
5. Final Order. Respondent consents to the Office's entry of a Final Order which
incorporates the terms of this Stipulation and Consent Agreement. Respondent further understands and agrees that this Stipulation and Consent Agreement is subject to the final approval of the Office and the entry of the Final Order adopting such Agreement. Accordingly, in the event that a Final Order is not entered by the Office, this Stipulation and Consent Agreement shall be null and void. The Final Order incorporating this Stipulation and Consent Agreement constitutes final agency action by the Office, for which the Office may seek enforcement pursuant to the provisions of chapters 120 and 560, Florida Statutes.
6. Waiver. By Respondent's consent to the entry of a Final Order with respect to this
proceeding and which incorporates this Stipulation and Consent Agreement, Respondent knowingly and voluntarily waives:
a. Any right to issuance of separately stated Findings of Fact and Conclusions of Law; b. Any right to receipt of a Notice of Rights pursuant to chapter 120, Florida Statutes;
c. Any right to an administrative hearing or issuance of a Recommended Order
pursuant to chapter 120, Florida Statutes; and

d. Any right to contest in any administrative forum or judicial proceeding (including, but not limited to, an appeal pursuant to section 120.68, Florida Statutes) the validity of any term, condition, obligation, or duty expressly created in this Stipulation and Consent Agreement and the Final Order.
7. Releases. Upon full execution of this Stipulation and Consent Agreement, Respondent
waives, releases, and forever discharges the Office and its agents, representatives, and employees from any and all causes of action, in law or in equity, which Respondent may have arising from or relating to the subject matter hereof. The Office agrees to accept this release and waiver on behalf of itself and its agents, representatives, and employees without acknowledging, and expressly denying, that any such right or cause of action may exist.
8. Failure to Complv. Respondent acknowledges, concurs, and stipulates that
Respondent's failure to comply with any of the terms, obligations, and conditions of this Stipulation and Consent Agreement or the Final Order adopting it constitutes a violation of this written agreement and the Final Order entered pursuant to chapters 120 and 560, Florida Statutes. Such non￾compliance by Respondent may result in the Office's issuance of an emergency cease and desist order. However, nothing herein shall be construed to limit Respondent's right to contest any finding or determination of non-compliance by the Office.
9. Attornev's Fees. Each party herein shall be solely responsible for its separate costs
and attorneys' fees incurred in the prosecution, defense, or negotiations in this matter up to and including entry of the Final Order adopting this Stipulation and Consent Agreement.
10. Severabilitv. The parties agree that if any provision of this Stipulation and Consent
Agreement (or the application thereof to any person or circumstance) is held invalid, the Stipulation and Consent Agreement, as incorporated by the Final Order, will be given effect

without the invalid provision. To this end, the provisions of this Stipulation and Consent Agreement are declared severable.
11. Counterparts. This Stipulation and Consent Agreement may be executed in any
number of counterparts, and by the parties in separate counterparts, each of which will be deemed to be an original but all of which together will constitute but one Stipulation and Consent Agreement. Copies of this Stipulation and Consent Agreement transmitted by facsimile or electronic mail shall have the same validity as if bearing an original signature.
12. Entire Agreement. This Stipulation and Consent Agreement represents the entire
agreement by and between Respondent and the Office. Any alterations, variations, changes, modifications, or waivers of the provisions hereof shall be valid only when they have been reduced to writing, duly signed by the Office and Respondent hereto, attached to the original of this Stipulation and Consent Agreement, and subject to the approval of the Office.
13. This Stipulation and Consent Agreement is entered into and agreed upon by the
parties without any trial, adjudication, or court finding on any issue of fact or law, and the Office's findings therein are not based on a violation of any provision of Florida statutes or rules which prohibits fraudulent, manipulative, or deceptive conduct. WHEREFORE, in consideration of the foregoing, Respondent Stephen Cheng together with the Office of Financial Regulation execute this Stipulation and Consent Agreement for its incorporation and adoption by a Final Order to be entered by the Office and which shall take effect as of the last date executed below. [this section intentionally left blank, followed by signatures on next page]

STEPHEN CHENG
-::::::::=::}'==----~ C-< :J--- tsignature) (/'
Date: "3 - \ ....
State of Flo~i~ I
County of _f- \1/\Y"'\ - )uJ.G
Stephen Cheng, BEFORE ME by means of ~ysical presence or [ ] online notarization, has sworn (or affirmed) that he has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me this \ 2. Check the appropriate b/ Personally known 0 OR Produced Identification D N Type of identification produced D Driver's License 0 Passport 0 Other ______ _ (Do not include ID number) OFFICE OF FINANCIAL REGULATION id-~ C. ff?d.,.,, __ Gregory C. Oaks, Director Division of Consumer Finance 4/16/2026 Date: ---