Final Order — Consumer Collection Agency

Index: OFR 2026 - 491 ' ·
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
HILL CITY HOLDINGS LLC, and
JOSEPH SHAW,
Respondents.
FINAL ORDER
.-' OOCKITEO
( 1 0/8/2026 1
LEGAL
Case Number: 130296
The State of Florida, Office of Financial Regulation ("Office"), being authorized and directed to administer and enforce chapter 559, Florida Statutes, hereby enters this Final Order with Notice of Rights ("Final Order") as authorized by the provisions of chapters 120 and 559, Florida Statutes, against HILL CITY HOLDINGS LLC and JOSEPH SHAW (together "Respondents"). FINDINGS OFF ACT

1. The Office has jurisdiction over the subject matter of this case and the parties
   hereto.
2. Hill City Holdings LLC ("Hill City Holdings") was licensed as a consumer
   collection agency registered under Chapter 559, Florida Statutes, having been issued registration number CCA9904961, from September 11, 2024 through December 31, 2024.
3. Joseph Shaw a/k/a Joseph MacGregor Shaw is and has been the sole owner of Hill
   City Holdings and its Chief Operating Officer.
4. The Office conducted an examination, to ascertain Respondents' compliance with
   chapter 559, Florida Statutes, and the corresponding rules for the period of January 1, 2024 through

December 31, 2024. The Office found that grounds existed to initiate legal action against Respondents. As such, on August 24, 2026, the Office issued an Administrative Complaint ("Complaint") (Exhibit A) seeking an administrative fine of $32,500.00.
5. Respondents were served the Complaint by U.S. Certified Mail, at the address of
Respondents' Registered Agent, on August 31, 2026. The Complaint was also served at the address ofrecord of Joseph Shaw on September 4, 2026. (Composite Exhibit B) As, such, a response was due no later than September 25, 2026. To date, the Office has neither received a written response to the Complaint nor have Respondents made a claim of equitable tolling.
6. The Complaint contained a Notice of Rights, which fully advised Respondents 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 120.59 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.
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 559,
Florida Statutes, and has jurisdiction over the subject matter and of Respondents pursuant to
chapter 559, Florida Statutes.

9. The Findings of Fact that have been adopted herein serve as the basis of the entry
   of this Final Order against Respondents. l 0. Section 120.569(2)(a), Florida Statutes, and Rule 28-106.1 I I (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.
10. 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).
11. Pursuant to Rule 28-106.111(4), Florida Administrative Code, the failure of
    Respondents to timely respond to the Complaint constitutes a waiver of Respondents' right to an administrative proceeding.
12. 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. Department of Admin., 523 So. 2d 1132 (Florida 1988).
13. 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).
14. Based on the Findings of Fact adopted herein, the Office concludes that Respondents
    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.
15. The Findings of Fact and Conclusions of Law that form the basis for the Complaint,
    together with the waiver of a hearing by Respondents, constitute grounds for the Office to impose an administrative fine against HILL CITY HOLDINGS LLC and JOSEPH SHAW. 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, Respondents shall pay an ADMINISTRATIVE FINE of Thirty-Two Thousand Five Hundred Dollars ($32,500.00). B. Respondents 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 130296 and sha11 be sent to the attention of Agency Clerk, c/o Maria A. Guitian, Assistant General Counsel, P.O. Box 8050, Tallahassee, FL 32314-8050. DONE and ORDERED this ~ day of October, 2026, in Tallahassee, Leon County, Florida. 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:
Bv 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 Bv 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 HILL CITY HOLDINGS LLC and JOSEPH SHAW by U.S. Mail to Joseph Shaw at 4219 Regent Street, Duluth, MN 55804, and Registered Agent: David Roberts, 7901 4th Street North, Suite 300, St. Petersburg, FL 33702 on this e+"'~ ay of October, 2026. ial Regulation 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
HILL CITY HOLDINGS LLC, and
JOSEPH SHAW,
Respondents.
ADMINISTRATIVE COMPLAINT
EXHIBIT A
Case No: 130296
The State of Florida, Office of Financial Regulation, ("Office") files this Administrative Complaint against HILL CITY HOLDINGS LLC and JOSEPH SHAW (together "Respondents"), alleging:
GENERAL ALLEGATIONS

1. Pursuant to section 559.554, Florida Statutes, the Office is charged with
   administering and enforcing the provisions of Part VJ, Chapter 559, Florida Statutes.
2. Pursuant to section 559.55(3), Florida Statutes, a consumer collection agency is
   defined as any debt collector or business entity engaged in the business of soliciting conswner debts for collection or collecting consumer debts, if not expressly exempted.
3. Pursuant to section 559.55(4), Florida Statutes, a "control person" means among
   other things, an individual that possesses the power to direct the management or policies of a company, whether through ownership of securities, by contract, or otherwise. The term includes among other things, the president, chief executive officer, director or other individuals having similar status or functions.
4. Pursuant to section 559.553(1), Florida Statutes, a person may not engage in
   business in this state as a consumer collection agency or continue to do business in this state as a

consumer collection agency without first registering in accordance with this part and thereafter maintaining a valid registration.
5. Pursuant to section 559.5541(1), Florida Statutes, the Office may, without advance
notice, conduct examinations and investigations, within or outside this state, to detennine whether a person has violated this part or related rules. For purposes of this section, the office may examine the books, accounts, records, and other documents or matters of any person subject to this part. The office may compel the production of all relevant books, records, and other documents and materials relative to an examination or investigation.
6. Pursuant to section 559.725, Florida Statutes, the Office shall investigate
complaints from consumers.
7. Hill City Holdings LLC ("Hill City Holdings") was licensed as a consumer
collection agency registered under Chapter 559, Florida Statutes, having been issued registration number CCA9904961, from September 11, 2024 through December 31, 2024.
8. Joseph Shaw a/k/a Joseph MacGregor Shaw is and has been the sole owner of Hill
City Holdings and its Chief Operating Officer and has active management authority over the business decisions, actions, and activities ofHi11 City Holdings; therefore, he is a "control person" as the term is defined in section 559.55(4), Florida Statutes.
9. The Office conducted an examination, which was open because of an anonymous
complaint, to ascertain Respondents' compliance with Florida's statutes and the corresponding mies for the period of January I, 2024 through December 31, 2024 ("examination period").
10. The Office selected a random sample of25 debtor files to review; of the 25 files, 2
were determined to be duplicated, therefore a total of 23 debtor files were reviewed during the examination.
11. Pursuant to section 559.730(1)(k), Florida Statutes, failure to comply with any

provision of Part VI, Chapter 559, Florida Statutes, or related rule constitutes grounds for disciplinary action.
12. Pursuant to section 559. 730(7), Florida Statutes, the Office shall adopt rules
establishing guidelines for imposing administrative penalties.
13. Pursuant to Rule 69V-180.100(5), Florida Administrative Code, the range for an
"A" level administrative fine is between$] ,000.00 and $3,500.00.
COUNTI
14. The above general allegations are hereby re-alleged and incorporated by reference
as if fuJly stated herein.
15. Pursuant to section 559.730(l)(i), Florida Statutes, a material misstatement or
omission of fact on an initial or amended registration application is grounds for disciplinary action.
16. The Office reviewed aJl submissions from Respondents. The initial application
submitted by Respondents on September 9, 2024, reflected that they had not operated as a consumer collection agency in Florida.
17. The Office reviewed the debtor files provided by Respondents. The Office
determined that Respondents had conducted unlicensed activities commencing April 29, 2024, which is prior to the date the registration application was submitted to the Office.
18. Registrant made a material misstatement or omission of fact, when Respondent
indicated that there had been no unlicensed activity prior to registration, in violation of section 559.730(l)(i), Florida Statutes.
19. Pursuant to the Disciplinary Guidelines for Consumer Collection Agencies Form
OFR-559-103, incorporated by reference in Rule 69V-180.100, Florida Administrative Code (2015), violation number 35, a licensee cited for violating section 559.730(l)(i), Florida Statutes, is subject to an "A" level administrative fine.

20. Therefore, the Office is seeking to impose an administrative fine of $1,000.00.
    COUNT II
21. The above genera] a1legations are hereby re-aJleged and incorporated by reference
    as if fully stated herein.
22. Pursuant to section 559.553(2), Florida Statutes, each consumer collection agency
    doing business in this state shall register with the office and renew such registration annual1y.
23. Pursuant to section 559.730(l)(h), Florida Statutes, acting as a consumer collection
    agency without a current registration issued under chapter 559, Florida Statutes, is grounds for disciplinary action . . 24. Respondents submitted a registration application on June 25, 2024, however, was abandoned.
24. The Office reviewed a sample of 23 debtor files and found that Respondents
    attempted to collect a debt either before they were registered (between April 29, 2024 to September J 0, 2024) and after their registration as a consumer collection agency expired (between January l, 2025 to April 11, 2025).
25. Respondents acted as a conswner collection agency without a current registration
    issued under chapter 559, Florida Statutes, in violation of section 559. 730( 1 )(h), Florida Statutes.
26. Pursuant to the Disciplinary Guidelines for Consumer Collection Agencies Fonn
    OFR-559-103, incorporated by reference in Rule 69V-180.100, Florida Administrative Code (2015), violation number 34, a licensee cited for violating section 559. 730() )(h ), Florida Statutes, is subject to a fine of $1,000.00 per day.
27. Therefore, the Office is seeking to impose a $25,000.00 administrative fine.
    COUNTIII
28. The above general allegations are hereby re-alleged and incorporated by reference

as if fully stated herein.
30. Pursuant to section 559.730(1)(k), Florida Statutes, failure to comply with, or a
violation of, any provision of chapter 559, Florida Statutes, or a corresponding ru]e is grounds for disciplinary action.
31. Pursuant to Rule 69V-180.080(10), Florida Administrative Code, a Registrant is
required to at a minimum, maintain all records specified in this rule; and the records shall be kept current to within one week of the current date. Computerized records that contain the equivalent of the information required to be maintained by this rule are acceptable. Among the records to be maintained are copies of all letters, emails, and correspondence, written or electronically sent to a debtor.
32. The Office reviewed a sample of 23 debtor fiJes and found that all fiJes were
missing copies of correspondence sent to the debtor(s). For example, the Office found that in 4 instances, the account notes reflect that there was an "Initial Notice Sent", yet the file does not contain a copy of the notice. Additionally, the Office requested to see the "Model Validation Notice" or a "Notice of Assignment" to the debtor, for each file; Respondents stated they failed to maintain the copies.
33. Respondents failed to maintain copies of all letters sent to debtors, in violation of
Rule 69V-l 80.080(10), Florida Administrative Code, and thereby in violation of section 559.730(1)(k), Florida Statutes.
34. Pursuant to the Disciplinary Guidelines for Consumer Collection Agencies Form
OFR-559-103, incorporated by reference in Rule 69V-180.100, Florida Administrative Code (2015), violation number 37, a licensee cited for violating section 559.730(l)(k), Florida Statutes, is subject to an "A" level administrative fine.
35. Therefore, the Office is seeking to impose a $3,500.00 administrative fine.

COUNTIV
36. The above general allegations are hereby re-alleged and incorporated by reference
as if fully stated herein.
37. Pursuant to section 559.72(17), Florida Statutes, in collecting consumer debts, a
person may not communicate with the debtor between the hours of 9 p.m. and 8 a.m. in the debtor's time zone without the prior consent of the debtor. This subsection does not apply to an e-mail communication that is sent to an e-mail address and that otherwise complies with this section.
38. As part of its examination, the Office reviewed a sample of 23 debtor files and
found that in 3 of the files sampled, Respondents communicated with debtors between the hours of9 pm and 8 am in the debtor's time zone and without prior consent from the debtor. Specifically, Respondents contacted the following debtors in violation of section 559.72(17), Florida Statutes:
S.D.; D.H.; and J.B.
39. Respondents communicated with debtors between the hours of 9 pm and 8 am
without prior consent of the debtor, in violation of section 559.72(17), Florida Statutes.
40. Pursuant to the Disciplinary Guidelines for Consumer Collection Agencies Form
OFR-559-103, incorporated by reference in Rule 69V-180.100, Florida Administrative Code (2015), violation number 23, a licensee cited for violating section 559.72(17), Florida Statutes, is subject to an "A" level administrative fine.
41. Therefore, the Office is seeking to impose a $3,000.00 administrative fine.
WHEREFORE, Respondents, HILL CITY HOLDINGS LLC and JOSEPH SHAW are hereby notified that the Office intends to enter an Order imposing an administrative fine of $32,500.00.

NOTICE OF RIGHTS
The registrant is entitled to be represented by counsel or another qualified representative. The licensee also has the rightto request a hearing pursuantto 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
Office of Financial Regulation
P.O. Box 8050
TaJiahassee, FL 32314-8050
Phone: (850) 410-9889
Email: Agency.Clerk@flofr.gov
OR Bv Hand Delivery
Office of Financial Regulation
General Counsel's Office
The Fletcher Building
IO 1 East Gaines Street, Suite 504
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 S: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 W AIYER 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 RESPONDENTS
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, l 01 East Gaines Street, Tallahassee, Suite 504, Florida 32399, Phone: (850) 410-9889, orby Email: Agency.Clerk@flofr.gov. tnwW Q.. lJi.ib,,," Maria A. Guitian Assistant General Counsel Office of Financial Regulation Office of General Counsel Fla. Bar No. 813966 200 E Gaines Street Tallahassee, FL 32399 Tel: (305) 536-0341 Email:Maria.Guitian@flofr.gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service by U.S. Certified Mail to Hill City Holdings LLC and Joseph Shaw at 314 W Superior Street, Suite 802, Duluth, MN 55802, and Registered Agen: David Roberts, 7901 4th N, Suite300, St. Petersburg, 33702, and Joseph MacGregor Shaw at 4219 Regent Street, Dululth, MN 55804, on this 24th day of August, 2026. 9489 0090 0027 6620 &120 12 -t,,w;,, a.. 11,i;~ Maria A. Guitian

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