Index: OFR 2026 - 544

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STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION

In Re:
VIAMERICAS CORPORATION,
Case Number: 132707
Respondent.

FINAL ORDER

The State of Florida, Office of Financial Regulation ("Office"), being authorized and directed to administer and enforce chapter 560, Florida Statutes, hereby enters this Final Order with Notice of Rights ("Final Order") as authorized by the provisions of chapters 120 and 560, Florida Statutes, against VIAMERICAS CORPORATION ("Respondent").

FINDINGS OF FACT

1. The Office has jurisdiction over the subject matter of this case and the parties hereto.

2. At all times material, Viamericas Corporation is and has been licensed in Florida as a Part II Money Services Business, having been issued license number FT20800102, pursuant to chapter 560, Florida Statutes.

3. The Office conducted an examination (No. 127733) to ascertain Respondent's compliance with chapter 560, Florida Statutes, and found that grounds existed to initiate a legal action against Respondent. As such, on September 17, 2026, the Office issued an Administrative Complaint ("Complaint") (Exhibit A) alleging violations of chapter 560, Florida Statutes, and seeking an appropriate administrative fine, and suspension of the Money Services Business license number FT20800102.

4. The Complaint contained a Notice of Rights, which fully advised Respondent that they had twenty-one (21) days after the receipt of the Complaint within which to petition the Office for an administrative hearing to contest the allegation set forth in the Complaint, in accordance with sections 120.569 and 120.57, Florida Statutes, including the following information:

TO PRESERVE THE RIGHT TO A HEARING, A WRITTEN RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION WITHIN TWENTY-ONE (21) DAYS AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. SAID RESPONSE MUST BE RECEIVED BY THE OFFICE NO LATER THAN 5:00 P.M. ON THE TWENTY-FIRST DAY AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. A FAILURE TO TIMELY RESPOND IN WRITING WILL CONSTITUTE A WAIVER OF THE LICENSEE'S RIGHT TO REQUEST A HEARING AND A FINAL ORDER MAY BE ENTERED WITHOUT FURTHER NOTICE.

5. Respondent was served the Complaint by U.S. Certified Mail on September 21, 2026 (Exhibit B). As such, a response was due no later than October 12, 2026. To date, the Office has not received any response to the Complaint.

6. Therefore, Respondent made no claim of equitable tolling.

7. The Findings of Fact alleged in the Complaint are hereby incorporated by reference and adopted as Findings of Fact in this Final Order.

CONCLUSIONS OF LAW

8. The Office is responsible for the administration and enforcement of chapter 560, Florida Statutes, and has jurisdiction over the subject matter and of Respondent pursuant to chapter 560, Florida Statutes.

9. The Findings of Fact that have been adopted herein serve as the basis of the entry of this Final Order against Respondent.

10. Section 120.569(2)(a), Florida Statutes, and Rule 28-106.111(2), Florida Administrative Code, require, among other things, that a response or a petition to an action which affects the substantial interests of a party be filed with the agency within 21 days of receipt of written notice of the action.

12. Section 120.569(2)( c ), Florida Statutes, provides that a petition for hearing shall be dismissed if it has been untimely filed (not within 21 days).

13. Pursuant to Rule 28-106.111(4), Florida Administrative Code, the failure of Respondent to timely respond to the Complaint constitutes a waiver of Respondent's right to an administrative proceeding.

14. The doctrine of equitable tolling can be applied in administrative cases when a party has been misled or lulled into inaction, i.e., has in some extraordinary way, been prevented from asserting his rights, or has timely asserted his rights in the wrong forum. Machules v. Dept. of Admin., 523 So. 2d 1132 (Fla. 1988).

15. Without any evidence of equitable tolling, it is appropriate for the Office to conclude there was none. Patz v. Dept. of Health, 864 So.2d 79, 80 (Fla. 3d DCA 2003).

16. When Respondent failed to submit a response to the Office on or before October 12, 2026, Respondent did not timely file a petition or any other document in response to the Complaint. Respondent also presented no claim, or evidence of equitable tolling. Therefore, it is appropriate for the Office to conclude there was no equitable tolling and Respondent waived their right to an administrative proceeding.

17. Based on the Findings of Fact adopted herein, the Office concludes that Respondent violated the specific statutes and rules charged in the Complaint and, as such, the specific charges in the Complaint are adopted in this Final Order as Conclusions of Law.

18. The Findings of Fact and Conclusions of Law that form the basis for the Complaint, together with the waiver of a hearing by Respondent, constitute grounds for the Office to suspend Respondent, VIAMERICAS CORPORATION, Money Services Business license number FT20800102 and impose an administrative fine against VIAMERICAS CORPORATION.

Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby

ORDERED:

A. Within thirty (30) days of the date of this Final Order, Respondent shall pay an ADMINISTRATIVE FINE of Twenty-Seven Thousand Six Hundred Dollars ($27,600.00).

B. Respondent shall submit the administrative fine in the form of a wire, money order or cashier's check made payable to the "Office of Financial Regulation." Such payment shall reference Case Number 132707 and shall be sent to the attention of Agency Clerk, c/o Bianca Lherisson, P.O. Box 8050, Tallahassee, FL 32314-8050.

C. Effective thirty (30) days from the date of this Final Order, Money Services Business license FT20800102 is hereby SUSPENDED for a period of seventy-four (74) days.

DONE and ORDERED this ~ day of November, 2026, in Tallahassee, Leon County, Florida.

Russell C. Weigel, III

Commissioner

NOTICE OF RIGHTS

A PARTY WHO IS ADVERSELY AFFECTED BY THIS FINAL ORDER IS ENTITLED TO JUDICIAL REVIEW PURSUANT TO SECTION 120.68, FLORIDA STATUTES. REVIEW PROCEEDINGS ARE GOVERNED BY THE FLORIDA RULES OF APPELLATE PROCEDURE. SUCH PROCEEDINGS ARE COMMENCED BY FILING THE ORIGINAL NOTICE OF APPEAL WITH THE AGENCY CLERK FOR THE OFFICE OF FINANCIAL REGULATION AS FOLLOWS:

By Mail, Facsimile or Email
Agency Clerk
Office of Financial Regulation
Office of General Counsel
P.O. Box 8050
Tallahassee, FL 32314-8050
Phone: (850) 410-9889
Fax: (850) 410-9663
Email: Agency.Clerk@flofr.gov
OR
By Hand Delivery
Agency Clerk
Office of Financial Regulation
Office of General Counsel
The Fletcher Building
101 East Gaines Street
Tallahassee, FL 32399
Phone: (850) 410-9889

A COPY OF THE NOTICE OF APPEAL, ACCOMPANIED BY THE FILING FEES AS REQUIRED BY LAW, MUST ALSO BE FILED WITH THE DISTRICT COURT OF APPEAL, FIRST DISTRICT, 2000 DRAYTON DRIVE, TALLAHASSEE, FLORIDA 32399-0950, OR WITH THE DISTRICT COURT OF APPEAL IN THE APPELLATE DISTRICT WHERE THE PARTY RESIDES. THE NOTICE OF APPEAL MUST BE FILED WITH BOTH THE AGENCY CLERK FOR THE OFFICE OF FINANCIAL REGULATION AND THE DISTRICT COURT OF APPEAL WITHIN 30 DAYS OF THE RENDITION OF THE ORDER TO BE REVIEWED.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order was furnished to Viamericas Corporation by U.S. Mail to 2100 Ponce De Leon Boulevard PH-2, Coral Gables, Florida 33134, and by electronic mail to jaime.castaneda@viamericas.com on this 6th day of November, 2026.

Agency Clerk
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:
VIAMERICAS CORPORATION,
Case Number: 132707
Respondent.

ADMINISTRATIVE COMPLAINT

The State of Florida, Office of Financial Regulation, ("Office") files this Administrative Complaint against VIAMERICAS CORPORATION ("Respondent"), alleging:

GENERAL ALLEGATIONS

1. Pursuant to sections 560.105 and 560.109, Florida Statutes, the Office is charged with administering and enforcing the provisions of chapter 560, Florida Statutes, and conducting examinations and investigations to determine whether any provision of chapter 560, Florida Statutes, has been violated.

2. Parts II, III, and IV of chapter 560, Florida Statutes, set forth the specific requirements of money services businesses and licensees.

3. Pursuant to section 560.114(1)(a), Florida Statutes, failure to comply with any provision of chapter 560, Florida Statutes, or related rule, constitutes grounds for disciplinary action.

4. Pursuant to section 560.103(1), Florida Statutes, an "affiliated party" is a control person, employee, or foreign affiliate of a money services business, or a person who has a controlling interest in a money services business.

5. Pursuant to section 560.114(1)(a), Florida Statutes, an “affiliated party” is responsible for, among other things, complying with all provisions of chapter 560, Florida Statutes, and its related rules.

6. Pursuant to section 560.103(10)(a), Florida Statutes, a “control person” is a person who holds the title of president, treasurer, chief executive officer, chief financial officer, chief operations officer, chief legal officer, or compliance officer for a money services business.

7. Pursuant to section 560.103(10)(b), Florida Statutes, a “control person” is any person who holds any of the officer positions named in the money services business's governing documents.

8. Pursuant to section 560.103(10)(c), Florida Statutes, a “control person” is a director of the money services business's board of directors.

9. Pursuant to section 560.103(23), Florida Statutes, "money services business" means any person located in or doing business in this state, from this state, or into this state from locations outside this state or country who acts as a payment instrument seller, foreign currency exchanger, check casher, or money transmitter.

10. Section 560.103(27), Florida Statutes (2023), defines a "money transmitter" as:

[A] corporation, limited liability company, limited liability partnership, or foreign entity qualified to do business in this state which receives currency, monetary value, a payment instrument, or virtual currency or the purpose of acting as an intermediary to transmit currency, monetary value, a payment instrument, or virtual currency from one person to another location or person by any means, including transmission by wire, facsimile, electronic transfer, courier, the Internet, or through bill payment services or other businesses that facilitate such transfer within this country, or to or from this country. The term includes only an intermediary that has the ability to unilaterally execute or indefinitely prevent a transaction.

11. Pursuant to section 560.103(29), Florida Statutes, a "payment instrument" means a check, draft, warrant, money order, electronic instrument, or other instrument, used for the payment of money or monetary value, whether or not negotiable.

12. Pursuant to section 560.103(11), Florida Statutes, a “corporate payment instrument" is a payment instrument on which the payee named on the instrument's face is other than a natural person.

13. Pursuant to section 560.103(12), Florida Statutes, "currency" means the coin and paper money of the United States or of any other country which is designated as legal tender, and which circulates and is customarily used and accepted as a medium of exchange in the country of issuance.

14. Section 560.103(6), Florida Statutes, defines a "check casher" as a person who sells currency in exchange for checks received, except travelers' checks.

15. Section 560.103(9), Florida Statutes, defines a "conductor" as a natural person who presents himself or herself to a licensee for purposes of cashing a payment instrument.

16. At all times material, Respondent, Viamericas Corporation, is and has been licensed as a Part II Money Services Business pursuant to chapter 560, Florida Statutes, operating as a money transmitter, payment instrument issuer, and check casher, holding license number FT20800102.

17. At all times material, Paul Dwyer ("Dwyer") is or has been Viamericas Corporation's Director, CEO, and President, and by operation of law, i.e., pursuant to sections 560.103(1), Florida Statutes, Dwyer is an affiliated party who is liable for all violations of Viamericas Corporation.

18. The Office conducted an examination (No. 127733) to ascertain Respondent's compliance with chapter 560, Florida Statutes, and the corresponding rules.

19. Pursuant to section 560.1141, Florida Statutes, the Office has adopted disciplinary guidelines that include ranges of designated penalties applicable to each ground for disciplinary action.

20. Pursuant to Rule 69V-560.1000(5), Florida Administrative Code, the range for a "B'' level administrative fine is between $3,500.00 and $7,500.00.

21. Pursuant to Rule 69V-560.1000(5), Florida Administrative Code, the range for a "B" level suspension of license is between 10 to 20 days.

22. Pursuant to section 560.114(1)(a), Florida Statutes, each money services business and its affiliated parties must comply with all provisions of chapter 560, Florida Statutes, and the Office may revoke a money services business license for failure to comply.

COUNT I

23. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein.

24. Pursuant to section 560.114(1)(y), Florida Statutes, a money services business is prohibited from violating 31 C.F.R. section 1022.210, which requires each money services business to develop, implement, and maintain an effective Anti-Money Laundering Program ("BSA/AML") that is reasonably designed to prevent the money services business from being used to facilitate money laundering and the financing of terrorist activities.

25. In accordance with 31 C.F.R. section 1022.210(d)(3), licensees must implement their BSA/AML policies and procedures as it relates to providing education and/or training of appropriate personnel concerning their responsibilities under the program.

26. As part of its examination, the Office reviewed Respondent's 2023 BSA/AML manuals and 2024 BSA/AML manuals, which required all employees to receive at least one annual BSA training.

27. As part of its examination, the Office reviewed Respondent's training records for four vendors.

28. The Office found that Respondent failed to maintain the BSA/AML training documentation for four vendors.

29. The Office found that:

a. Friendly Discount Beauty, a vendor, was added in 2023. Respondent failed to maintain training certifications for 2023 and 2024.

b. Taqueria Latina LLC, a vendor, was added in 2023. Respondent failed to maintain training certifications for 2023 and 2024.

c. Cargo Zone ETC Inc., a vendor, was added in 2016. Respondent failed to maintain training certifications for 2023 and 2024.

d. Service Plus Multiservice, a vendor, was added in 2023. Respondent failed to maintain a training certification for 2024.

30. Respondent violated 31 C.F.R. section 1022.210, and thereby section 560.114(1)(y), Florida Statutes, by failing to implement their BSA/AML policies and procedures as it relates to providing training.

31. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR- 560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 26, a licensee cited for a violation of section 560.114(1)(y), Florida Statutes, is subject to a "B" level administrative fine and a "B" level suspension of license.

32. Therefore, the Office is seeking a "B" level administrative fine, and a "B" level license suspension.

COUNT II

33. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein.

34. Pursuant to section 560.309(5), Florida Statutes, a licensee must report all suspicious activity to the Office in accordance with the criteria in 31 C.F.R. s. 1022.320.

35. Pursuant to Rule 69V-560.609(2), Florida Administrative Code, the Office has designated FinCEN as the appropriate regulator to receive the reports.

36. Pursuant to 31 C.F.R. section 1022.320(b), a suspicious transaction shall be reported by completing a Suspicious Activity Report ("SAR"), and collecting and maintaining supporting documentation as required. The SAR shall be filed in a location determined by FinCEN no later than thirty (30) calendar days after the date of the initial detection by the licensee of facts that may constitute a basis for filing a SAR.

37. As part of its examination, the Office reviewed Respondent's FinCEN report and five (5) SARs.

38. The Office found that in two (2) of the five (5) SARs, the licensee failed to file SARs with FinCEN within 30 calendar days after initial detection of the suspicious activity.

39. The Office found that:

a. The date range of suspicious activity was March 13, 2023, through May 21, 2024, in the amount of $13,722.00. The initial date of detection was September 19, 2023. The SARs filed on October 23, 2023, were filed four (4) days late.

b. The date range of suspicious activity was June 30, 2024, through December 9, 2024, in the amount of $23,184.00. The initial date of detection was December 16, 2024. The SARs filed on January 15, 2025, were filed one (1) day late.

40. Respondent failed to timely submit SARs in accordance with the criteria set forth in 31 C.F.R. s. 1022.320, in violation of section 560.309(5), Florida Statutes.

41. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR- 560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 86, a licensee cited for a violation of section 560.309(5), Florida Statutes, is subject to a "B" level administrative fine and a "B" level suspension of license.

42. Therefore, the Office is seeking a "B" level administrative fine, and a "B" level license suspension.

COUNT III

43. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein.

44. Pursuant to section 560.126(3), Florida Statutes, a licensee must report any change in the control persons of the licensee or changes in the form of business organization by written amendment in such form and such time as specified by rule.

45. Pursuant to Rule 69V-560.201(3), Florida Administrative Code, each person licensed under Chapter 560, Florida Statutes, that proposes to change any personnel listed in question 5G of Form OFR-560-01 that does not result in a change of controlling interest in the licensee, shall file an amendment on or before the effective date of the change or within two (2) business days after the date the licensee first received notice of the change. Persons not currently on file with the Office that have not complied with Section 560.141(1)(c), Florida Statutes, must comply with the fingerprinting requirements contained therein.

46. As part of its examination, the Office reviewed Respondent's license application and any subsequent amendments filed.

47. As part of its examination, on February 20, 2025, the Office sent an electronic communication to Respondent requesting that Respondent confirm whether the individuals listed on the amended application dated February 7, 2025, were either direct owners, executive officers, control persons, indirect owners, or qualifying individuals.

48. On February 20, 2025, Respondent responded to the Office's inquiry and stated that Joel Lamar Silva is a Director of Viamericas Corporation.

49. On March 31, 2025, Respondent filed an amended application in which Joel Lamar Silva was listed as Director, and Joel Lamar Silva acquired that title on June 6, 2024.

50. The Office found that Respondent reported the addition of Joel Lamar Silva as Director 298 days after the title or position was acquired.

51. Respondent failed to report a change in the control persons of the licensee by written amendment on or before the effective date of the change or within two (2) business days of the change, in violation of section 560.126(3), Florida Statutes, and Rule 69V-560.201(3), Florida Administrative Code.

52. Respondents were found to have violated section 560.126(3), Florida Statutes, in the past in Office of Financial Regulation Legal Case Number 120236, where a Final Order was entered on March 11, 2024.

53. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR- 560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 48, a licensee cited for a second violation of section 560.126(3), Florida Statutes, is subject to a “B” level administrative fine and a “B” level suspension of license.

54. Therefore, the Office is seeking a "B" level administrative fine, and a "B" level license suspension.

COUNT IV

55. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein.

56. Pursuant to 560.208(4), Florida Statutes, a licensee must place assets that are the property of a customer in a segregated account in a federally insured financial institution and shall maintain separate accounts for operating capital and the clearing of customer funds.

57. As part of its examination, the Office reviewed Respondent's Florida Money Transmission accounts.

58. As part of its examination, the Office issued a records request ("Records Request 25") on August 19, 2025, which sought an explanation for debits and credits identified in various bank accounts and the purposes of each bank account disclosed as Florida Money Transmission accounts.

59. In response to the records request, Respondent provided a flow of funds document for both collection and concentration of funds, and a written statement from a vendor that performs services on behalf or through Viamericas Corporation.

60. Respondent's statement indicates that both check cashing and money transmission transactions are swept via ACH to a Viamericas corporate account (# ending in 3209) at North American Bank on a daily basis, and the statement supports the commingling of funds received for check cashing and money transmission transactions to the ultimate parent accounts held by Viamericas Corporation.

61. The Office found that Respondent's Florida consumer funds transmission for remittance abroad are centralized in various "concentration accounts": Bank of America, N.A. account(# ending 6807), Wells Fargo Bank account(# ending 0393), Woodforest Bank account (# ending 5032), and North American Bank account(# ending 3209).

62. The Office found that funds are transferred to Respondent's Bank of America, N.A. zero balance "expense account" which may ultimately cover checks, business expenses, courier service fees and or transmission on behalf of other state transactions and/or correspondent bank account funding. At the end of each day, the remaining zero balance account balance is then transferred back to the concentration account.

63. Respondent failed to place funds received for transmission from customers into a segregated account in a federally insured financial institution, ultimately commingled consumer funds with its own funds and used consumer funds to pay operational/business expenses, in violation of 560.208( 4 ), Florida Statutes.

64. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR- 560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 51, a licensee cited for a violation of section 560.208(4), Florida Statutes, is subject to a "B" level administrative fine and a "B" level suspension of license.

65. Therefore, the Office is seeking a "B" level administrative fine, and a "B" level license suspension.

WHEREFORE, Respondent, VIAMERICAS CORPORATION, is hereby notified that the Office intends to enter an Order imposing an appropriate administrative fine against Viamericas Corporation, as well as suspension of money services business license number FT20800102.

[this space intentionally left blank with Notice of Rights appearing on the next page]

NOTICE OF RIGHTS

The Licensee is entitled to be represented by counsel or another qualified representative.

The Licensee also has the right to request a hearing pursuant to sections 120.569 and 120.57, Florida Statutes. Such request must comply with Rules 28-106.2015 and 28-106.104, Florida Administrative Code. An Election of Proceeding form is attached for your convenience.

Any such request must be filed as follows:

By Mail or E-Mail
OR Bv Hand Delivery
Agency Clerk
Office of Financial Regulation
Office of General Counsel
P.O. Box 8050
Tallahassee, FL 32314-8050
Phone: (850) 410-9889
Fax: (850) 410-9663
Email: Agency.Clerk@flofr.gov
Agency Clerk
Office of Financial Regulation
Office of General Counsel
The Fletcher Building, Suite 504
101 East Gaines Street
Tallahassee, FL 32399
Phone: (850) 410-9889

TO PRESERVE THE RIGHT TO A HEARING, A WRITTEN RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION WITHIN TWENTY-ONE (21) DAYS AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. SAID RESPONSE MUST BE RECEIVED BY THE OFFICE NO LATER THAN 5:00 P.M. ON THE TWENTY-FIRST DAY AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. A FAILURE TO TIMELY RESPOND IN WRITING WILL CONSTITUTE A WAIVER OF THE LICENSEE'S RIGHT TO REQUEST A HEARING AND A FINAL ORDER MAY BE ENTERED WITHOUT FURTHER NOTICE.

You may not make an oral request for an administrative hearing. With regard to a written request, if you fail to follow the outlined procedure, your request may be dismissed. Any request for an administrative proceeding received prior to the date of this notice is deemed abandoned and to be considered, must be timely renewed in compliance with the procedure set forth above.

Mediation of this matter pursuant to section 120.573, Florida Statutes, is not available.

NOTICE TO RESPONDENT

In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to participate in this proceeding should contact the Agency Clerk no later than seven (7) days prior to the filing deadline or proceeding, at the Office of Financial Regulation, The Fletcher Building, Suite 504, 200 East Gaines Street, Tallahassee, Florida 32399-0379, Phone: (850) 410-9889, or by Email: agency.clerk@flofr.gov.

By: Bianca Lherisson
Bianca Lherisson
Assistant General Counsel
Office of Financial Regulation
Office of General Counsel
Fla. Bar No. 119268
200 E. Gaines Street
Tallahassee, FL 32399-0370
Tel: (850) 410-9837
Email: Bianca.Lherisson@flofr.gov

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service via U.S. certified mail to Viamericas Corporation at 2100 Ponce De Leon Boulevard PH-2, Coral Gables, Florida 33134, on this 17th day of September, 2026.

Bianca Lherisson
9489 0090 0027 6620 8395 38
Bianca Lherisson
Assistant General Counsel

STATE OF FLORIDA
OFFICE Of FINANCIAL REGULATION

Case No: 132707
Viamericas Corporation
2100 Ponce De Leon Boulevard PH-2
Coral Gables, Florida 33134

ELECTION OF PROCEEDING

I have received and read the Administrative Complaint, including the Notice of Rights, filed by the Office of Financial Regulation ("Office") regarding the above-referenced Respondent, and I am requesting disposition as indicated below. PLEASE SELECT ONLY ONE OF THE OPTIONS:

OPTION #1: D I do not request a hearing in this matter. I .Q.Q.!lQ! dispute any of the Office's factual allegations and conclusions of law as stated in the Administrative Complaint. I understand that upon my waiving the right to a hearing, the Office may enter a final order adopting the findings of fact and conclusions of law in the Administrative Complaint, and Imposing the penalties sought in the Administrative Complaint.

OPTION #2: 0 I do not dispute any of the Office's factual allegations but dispute the Office's conclusions of law to those factual allegations, and request disposition of this matter by informal hearing pursuant to section 120.57(2), Florida Statutes. I request to (CHECK ONLY ONE OF THE FOLLOWING 2 OPTIONS):

a. D Attend a hearing by video teleconference before a Hearing Officer appointed by the Office; OR

b. D Submit a written statement with supporting documentation to a Hearing Officer appointed by the Office.

OPTION #3: D I do dispute one or more of the Office's factual allegations. I request a formal hearing before the Division of Administrative Hearings (DOAH) pursuant to section 120.57(1), Florida Statutes. In accordance with Rule 28-106.2015(5)(c), FAC, I am attaching a copy of the material facts that I dispute.

TO PRESERVE YOUR RIGHT TO A HEARING, A RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION AGENCY CLERK NO LATER THAN 5:00 P.M. ON OR BEFORE THE TWENTY-FIRST DAY AFTER RECEIPT OF THE ADMINISTRATIVE COMPLAINT, BY ANY OF THE FOLLOWING METHODS:

1. By email: Agency.Clerk@flofr.gov; or

2. By U.S. Mail: P.O. Box 8050, Tallahassee, Florida 32314-8050; or

3. By hand delivery: Office of General Counsel, Suite 504, Fletcher Bldg., 101 E. Gaines Street, Tallahassee, FL 32399.

Signature of Respondent or
Mailing Address
Authorized Representative of Respondent
Printed Name & Title
City
State
Zip
Date
E-mail Address
Telephone Number

Form: OFR-GC-13 (rev. 1/28/2026)

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION

Case No: Case No: 132707
Viamericas Corporation
2100 Ponce De Leon Boulevard PH-2
Coral Gables, Florida 33134

**YOU ARE TO COMPLETE THE FOLLOWING ONLY IF YOU HAVE CHECKED OPTION #3 ON THE PRECEDING PAGE. If you need more space, you may provide additional pages.

As Respondent or the authorized representative of Respondent, I am disputing the following material facts:

Signature of Respondent or Authorized Representative Date

Form: OFR-GC-13 (rev. 1/28/2026)

Florida Office of Financial Regulation
200 East Gaines Street I Tallahassee, Florida 32399-0370 RETURN SERVICE REQUESTED

Viamericas Corporation
2100 Ponce De Leon Boulevard PH-2
Coral Gables, Florida 33134

1111111
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9489 □□ □ □□ 27 662 □ 8395 38

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UNITED STATES POSTAL SERVICE ®

EXHIBIT B

October 20, 2026

Dear BIANCA LHERISSON:

The following is in response to your request for proof of delivery on your item with the tracking number: 9489 0090 0027 6620 8395 38.

Item Details
Status:
Status Date / Time:
Location:
Postal Product:
Extra Services:
Delivered, Front Desk/Reception/Mail Room
September 21, 2026, 12:54 pm
MIAMI, FL 33134
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