Final Order — Consumer Collection Agency

Index: OFR 2026 - 286 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: GLOBAL RECOVERY SOLUTIONS LLC, and ROBERT CASTRO, Respondents. FINAL ORDER Case Number: 120237 6 This cause came on for consideration and final agency action. Upon review of the record and being otherwise fully advised in the premises, the Office of Financial Regulation ("Office") hereby finds:

1. The Office has jurisdiction over the subject matter of this case and the parties hereto.
2. The entry of this Final Order concludes the above-referenced matter. ORDERED: A. The 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. B. The parties shaJI comply with all terms of the Stipulation and Consent Agreement. DONE and ORDERED this ?/ ·d. day of June, 2026, in Tallahassee, Leon County, Florida.

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished to Dean Hoover, Esquire, Counsel for Global Recovery Solutions LLC and Robert Castro, by electronic mail at dsh@causallc.com on this JI!!_ day of June, 2026. a Regulation 0 050 L 32314-8050 . y.Clerk@flofr.gov Tel: (850) 410-9889 2

EXHIBIT A STATE OF FLOIUUA OFFICE OF FINANCIAL REGULATION In Re: GLOBAL RECOVERY SOLUTIONS LLC anal ROBERT CASTRO, Case Number: 120237 Rcsponllcnts. STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation ("Office"), and GLOBAL RECOVERY SOLUTIONS LLC anal ROBERT CASTRO ("Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows: I. Backgrounll. At all times material hereto, Global Recovery Solutions LLC is and has been a consumer collection agency in the State of Florida, having been issued license number CCA9904480. At all times material, Robert Castro is and has been the President and Sole Owner of Global Recovery Solutions LLC. The Office conducted an examination (No. l 06616) to ascertain Respondents• compliance with chapter 559, Florida Statutes, for the period of February 8, 2021, through August 7, 2021. In lieu of initiating a formal proceeding, the parties herein resolve the matters at issue. 2. Jurisllictjon. The Office is the state agency charged with the administration and enforcement of chapter 559, Florida Statutes, and the rules promulgated thereunder. The Office has jurisdiction to bring this administrative action against Respondents. pursuant to chapter 559, Florida Statutes. 3. Finllings. For purposes of this Stipulation and Consent Agreement, Respondents consent to the Office making the following findings:

r a) Respondents failed lo maintain policies and procedures regarding the destruction of records including which records were destroyed, when the records were destroyed, where the records were destroyed, and who destroyed the records, in violation of Rule 69V-t 80.090(2)(b ), Florida Administrative Code, and thereby section 559. 730( 1 )(k), Florida Statutes; b) Respondents failed to maintain policies and procedures that include a secure method of destroying consumer information, in violation of Rule 69V-180.090 (2)(a), Florida Administrative Code, and thereby section 559.730(l)(k), Florida Statutes; c) Respondents failed to maintain all written agreements executed between the registrant and the debtor after the account bad been received from the creditor, in violation of Rule 69V-180.080(8), Florida Administrative Code, and thereby section 559.730(1)(k), Florida Statutes; d) Respondents failed to maintain documentation of the debt provided by the creditor for debtor's accounts, in violation of Rule 69V-180.080(9), Florida Administrative Code, and thereby section 559.730(1)(k), Florida Statutes; e) Respondents failed to maintain copies of letters, emails, and correspondence, written or electronically sent to debtor, in violation of Rule 69V-180.080(10), Florida Administrative Code, and thereby section 559.730(1)(k), Florida Statutes; 2

t) Respondents communicated with debtors between the hours of 9 p.m. and 8 a.m. in the debtor's time zone without the prior consent of the debtor, in violation of section 559.72(17), Florida Statutes. 4. Terms and Conditions. The parties agree that the issues raised can be expeditiously resolved without further litigation by the execution of this Stipulation and Consent Agreement. The parties acknowledge that 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 Office's forbearance from further litigation, Respondents agree to the following tenns and conditions: a. FUTURE COMPLIANCE. Respondents agree that they shall cease and desist from future violations of chapter 559, Florida Statutes, and the rules promulgated thereunder, and comply with all the provisions of chapter 559, Florida Statutes, and the rules promulgated pursuant thereto. b. ADMINISTRATIVE FINE. Respondents agree to pay the Office an administrative fine in the amount of Fifteen Thousand Dollars ($15,000.00), to be paid at the time of the execution and delivery of this Stipulation and Consent Agreement. This administrative fine shall be submitted in the form of a wire, cashier's check, or money order made payable to "O/flce of Financial Reg11/ation "and shall be sent to the attention of Agency Clerk - c/o Debra H. Pierce, Post Office Box 8050, Tallahassee, Florida 32314- 8050. Respondents acknowledge and agree that in accordance with section 215.31, Florida Statutes, regarding the deposit of monies, (i) the tendered fine or settlement check may be deposited in advance of full execution or acceptance of the Stipulation and Consent Agreement; 3

L 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. S. Final Order. Respondents consentto the entry of a Final Order, which incorporates the terms of this Stipulation and Consent Agreement. Respondents understand and agree that this Stipulation and Consent Agreement is subject to the final approval of the Office of Financial Regulation and the entry of the Final Order adopting such Agreement. If the Final Order is not entered, this Stipulation and Consent Agreement shall be nuU and void. The Final Order incorporating this Stipulation and Consent Agreement constitutes final action by the Office for which the Office may seek enforcement pursuant to the provisions of chapters 559 and 120, Florida Statutes. 6. Waiver. By Respondents' consent to the entry of a Final Order with respect to this proceeding, Respondents waive: a) Any right to 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, Respondents waive, release, and forever discharge the Office and its agents, representatives, and 4

employees from any and all causes of action, in law or in equity, which Respondents may have arising out of this matter. The Office accepts this release and waiver by Respondents on behalf of itself, its agents, representatives, and employees without acknowledging, and expressly denying, that any such right or cause of action may exist. 8. Failure to Comply. Respondents acknowledge, concur, and stipulate that Respondents' failure to comply with any of the terms, obligations and conditions of this Stipulation and Consent Agreement, and the Final Order adopting it, is a violation of the written agreement and the Final Order entered pursuant to chapters 120 and 559, Florida Statutes. Such non￾compliance may result in the issuance of an emergency cease and desist order. However, nothing herein shall be construed to limit Respondents' right to contest any finding or determination of non-compliance. 9. Attorney's Fees. Each party herein shall be solelyresponsible for its separate costs and attorney's fees incurred in the prosecution, defense, or negotiations in this matter up to and including the entry of the Final Order adopting this Stipulation and Consent Agreement. I 0. 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 will be given effect without the invalid provision, and 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 nwnber 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. 5

12. Entire Ag~ement. This Stipulation and Consent Agreement represents the entire agreement by and between Respondents 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 Respondents hereto, attached to the original of this Stipulation and Consent Agreement, and subject to the approval of the Office. WHEREFORE, in consideration of the foregoing, the Office and Respondents execute this Stipulation and Consent Agreement for entry of a Final Order on the last date executed below. {this space intentionally left blank ~th signatures appearing on the following page] 6

GLOBAL RECOVERY SOL\JTIONS LLC: Date: ___.. 5 /2/9 /z, __ Name: Robert Castro Title: President and Sole Owner State of HD[Li J4 County of flt{ M "&Al H Robert Castro, as President and Sole Owner of Global Recovery Solutions LLC, BEFORE ME by means of 6ohvskal presence or D 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...t9, day of 11+1 ,2026. fa ~ otary Public Ji,{ -/fJ_JltJN tL l Check the appropriate box: Personally known 0 OR Produced rdentification IZ( Type of identification produced 0Driver's License H 011 id 't D Passport D Other ___ _ __ _ (Do not include ID number) 7

ROBERT CASTRO: Date: _ 5 ...,....,.,h~~tc __ Name: Robert Castro State of Hortl o{,g County o(y.q l M ""8 l-4 ( H Robert Castro, BEFORE ME by means of ~lcal presence or D 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 A day of f1 tr''/ , 2026. J IJ,d)i,/ N'otaryi>ublic /.{. /4Jj~J:-<-- I Check the appropriate box: . ,.,.., - • ~ HofAry~--=~ • Personally known O , ~ Ccm1111mo,i, HH tt t 15 , -~ e Mt Comtii, llplres How 11. zo.11

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OR Produced Identification []I.. Clftdfd~llllloni!Nou,yAssn. Type ofidentification produced 12(' Driver's License P"tott.." {)ht D Passport D Other _____ _ (Do not include JD number) omcE OF FINANCIAL REGULATION ,j.~ C.((}k Gregory C. Oaks, Director Division of Consumer Finance 8 Date: 6/1/2026 ----------