Final Order Denying Brian P. Callanan's Petition for Waiver from Rule 69W-600.0024(6)(b)

Index: OFR 2026 - 327
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
BRIAN P. CALLANAN, Petition for
Waiver from Rule 69W-600.0024(6)(b),
Florida Administrative Code,
Petitioner.
Case Number: 136058-SR
FINAL ORDER DENYING CALLANAN'S PETITION FOR W AIYER FROM RULE 69W-600.0024(6)(b}, FLORIDA ADMINISTRATIVE CODE, AND NOTICE OF RIGHTS This matter is before the State of Florida, Office of Financial Regulation ("Office"), on the request for a waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code (hereinafter "Petition"), submitted February 12, 2026, by Brian P. Callanan ("Callanan"). Pursuant to section 120.542(8), Florida Statutes, the Office enters this Final Order Denying Callanan's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, and in support thereof, makes the following Findings of Fact and Conclusions oflaw:
FINDINGS OF FACT

1. On May 11, 2026, the Office issued a Notice of Intent to Enter a Final Order
   Denying Callanan's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, and Notice of Rights ("Notice of Intent") via United States Postal Service ("USPS") mail and email. The Notice of Intent gave notice of the Office's intent to enter a Final Order Denying Callanan's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, as Callanan has not met the criteria for waiver provided by section 120.542(2), Florida Statutes. The Notice of Intent is attached hereto as Exhibit I.

2. The Notice of Intent had attached thereto a Notice of Rights, which fully advised
   Callanan that he had twenty-one (21) days after issuance of the Notice within which to petition the Office for an administrative hearing to contest the allegations set forth in the Notice of Intent and that failure to do so would constitute a waiver of such right.

3. The Notice oflntent was sent to Callanan on May 11, 2026, via USPS mail.

4. The Notice of Intent was sent to Callanan via email to his firm on May 11, 2026.
   The email is attached hereto as Exhibit II.

5. Callanan's response to the Notice of Intent was to be filed with the Office on or
   before June 8, 2026. As of the date of this Final Order, Callanan has failed to file a petition for hearing or to file any other document with the Office in response to the Notice of Intent.

6. The facts alleged in the Notice of Intent, being uncontested by Callanan, are
   accepted as true and correct, incorporated herein by reference, and adopted by the Office as Findings of Fact for purposes of this Final Order. CONCLUSIONS OF LAW

7. The Office is responsible for the administration and enforcement of chapter 517,
   Florida Statutes, and has jurisdiction over the subject matter and Callanan pursuant to chapters 120 and 517, Florida Statutes.

8. Subsection 120.60(3), Florida Statutes. sets forth the following service
   requirements:
   Each applicant shall be given written notice, personally or by mail, that the agency intends to grant or deny, or has granted or denied, the application for license. The notice must state with particularity the grounds or basis for the issuance or denial of the license, except when issuance is a ministerial act. Unless waived, a copy of the notice shall be delivered or mailed to each party's attorney ofrecord and to each person who has made a written request for notice of agency action. Each notice must inform the recipient of the basis for the agency decision, inform the recipient of any administrative 2

hearing pursuant to ss. 120.569 and 120.57 or judicial review pursuant to s. 120.68 which may be available, indicate the procedure that must be followed, and state the applicable time limits. The issuing agency shall certify the date the notice was mailed or delivered, and the notice and the certification must be filed with the agency clerk.
9. The Office's issuance of the Notice of Intent as set forth in paragraphs one (1)
through four (4) above complies with the service requirements provided in subsection 120.60(3), Florida Statutes.
10. Callanan's failure to file a petition for hearing or to file any other document in
compliance with Rules 28-106.201, 28-106.2015, or 28-106.301, Florida Administrative Code, constitutes a waiver of Callanan' s right to an administrative hearing. See Rule 28-106.111 ( 4 ), Fla. Admin. Code.
11. Callanan has not alleged any basis for equitable tolling. See Patz v. Dep 't of Health,
Fla. Bd. Of Med., 864 So. 2d 79 (Fla. 3d DCA 2003).
12. The legal conclusions that form the basis for the denial of Callanan' s Petition for
Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, set forth in the Notice of Intent, being uncontested by Callanan, are accepted as true and correct, incorporated herein by reference, and adopted by the Office as Conclusions of Law for purposes of this Final Order. [Remainder of page intentionally blank] 3

Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED:
Callanan's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, is hereby DENIED. DONE and ORDERED this t f'-day of July, 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:
By U.S. Mail, Fax or Email
Agency Clerk
Office of Financial Regulation
P.O. Box 8050
Tallahassee, Florida 32314-8050
Phone: (850) 410-9889
Fax: (850) 410-9663
Email: Agency.Clerk@flofr.gov
OR By Hand Deliverv
Agency Clerk
Office of Financial Regulation
Office of General Counsel
The Fletcher Building
101 East Gaines Street
Tallahassee, Florida 32399
Phone: (850) 410-9889
A COPY OF THE NOTICE OF APPEAL, ACCOMPANIED BY THE FILING FEES AS REQUIRED BYLAW, 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 4

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 on this J__ day of July, 2026, a true and correct copy of the foregoing has been furnished by U.S. mail and email to the following:
Brian P. Callanan
4975 East Sabal Palm Blvd.
Tamarac, FL 33319 brian@callananfinancial.com
5
• 1 Regulation
• 8050
e , L 32314-8050
. gency.Clerk@flofr.gov
Tel: (850) 410-9889

FINAL ORDER EXHIBIT I
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
BRIAN P. CALLANAN, Petition for
Waiver from Rule 69W-600.0024(6)(b),
Florida Administrative Code,
Petitioner.
Case Number: 136058-SR
NOTICE OF INTENT TO ENTER A FINAL ORDER DENYING CALLANAN'S PETITION FOR WAIVER FROM RULE 69W-600.0024(6l(b), FLORIDA ADMINISTRATIVE CODE. AND NOTICE OF RIGHTS This matter is before the State of Florida, Office of Financial Regulation ("Office"), on the request for a waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code (hereinafter "Petition"), submitted February 12, 2026, by Brian P. Callanan ("Petitioner"), Central Registration Depository ("CRD") Number 5752195. Section 120.542(8), Florida Statutes, provides that an order granting or denying a petition for variance or waiver "shall contain a statement of the relevant facts and reasons supporting the agency's action." Having considered all relevant facts and pertinent law, the Office enters this NOTICE of its intent to enter a Final Order DENYING Callanan's Petition for waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code. STATEMENT OF FACTS

1. On February 12, 2026, the Office received the Petition requesting a waiver from
   Rule 69W-600.0024(6)(b), Florida Administrative Code (the "Petition"). (See Exhibit A)
2. Rule 69W-600.0024, Florida Administrative Code, concerns the application for
   registration as an associated person of an investment adviser or federal covered adviser. This rule contains various obligations, including the submission of an application, the identification of the advisory firm with which the applicant seeks registration as an associated person, the payment of an assessment fee, the submission of fingerprints, the identification of civil, criminal or

FINAL ORDER EXHIBIT I administrative legal proceedings, and the submission of examination qualifications. The rule also addresses multiple registration, grandfathering provisions for applicants registered in other jurisdictions, and exemptions from examination qualifications for applicants holding current specified professional designations.
3. As to examination qualifications, Rule 69W-600.0024(6), Florida Administrative
Code, in pertinent part provides:
( 6) Examinations/Qualifications.
(a) Every applicant for registration shall execute and submit a statement attesting to said applicant's knowledge and review of the Florida Securities and Investor Protection Act, as contained in the Form U4. (b) Every applicant for registration shall provide the Office with one of the following:

1. Proof of passing, within two years of the date of application for
   registration, the Uniform Investment Adviser Law Examination (Series 65); or
2. Proof of passing, within two years of the date of application for
   registration, the General Securities Representative Examination (Series 7), the Uniform Combined State Law Examination (Series 66), and proof of passing within four years of the date of application for registration, the Securities Industry Essentials (SIB) Examination. The following applicants will be considered to have passed the SIE Examination:
   a. AppJicants whose registration as an associated person was terminated between October I, 2014, and September 30, 2018, provided they re-register as an associated person within four years from the date of their last registration; b. Applicants who registered as an associated person prior to October 1, 2018, and who continue to maintain those registrations on or after October 1, 2018. (c) Applicants who meet one of the following conditions satisfy the examination requirements of paragraph ( 6)(b) of this rule, except the Office may require additional examinations for any applicants found to have violated any state or federal securities law:
   l .a. Applicants who passed either the Series 65 examination or both the Series 7 and Series 66 examinations; and b. Have not had a lapse in registration as an associated person of an investment adviser or federal covered adviser in any jurisdiction in the United States for a period exceeding two years.
   c. Periods of time during which an applicant provides advisory services
   for compensation on behalf of a dealer, a federal covered adviser, or an investment adviser, in any jurisdiction in the United States that does not require such persons to register as an associated person of the dealer, federal covered adviser, or investment adviser on whose behalf such advisory services were performed, will not be considered a lapse in registration for purposes of this paragraph. 2

FINAL ORDER EXHIBIT I
2.a. Applicants who were previously registered with the Office as an associated person of an investment adviser or federal covered adviser; and b. Have not had a lapse in registration as an associated person of an investment adviser or federal covered adviser in any jurisdiction in the United States for a period exceeding two years.
4. Section 517.12, Florida Statutes, is implemented by Rule 69W-600.0024, Florida
Administrative Code, and provides in pertinent part as follows:
517 .12 Registration of dealers, associated persons, intermediaries, and investment advisers. - (3) No investment adviser or associated person of an investment adviser or federal covered adviser shall engage in business from offices in this state, or render investment advice to persons of this state, by mail or otherwise, unless the federal covered adviser has made a notice-filing with the office pursuant to s. 517.1201 or the investment adviser is registered pursuant to the provisions of this chapter and associated persons of the federal covered adviser or investment adviser have been registered with the office pursuant to this section. (8) The commission or office may require the applicant or one or more principals or general partners, or natural persons exercising similar functions, or any associated person applicant to successfully pass oral or written examinations. . . . the commission may waive the examination process when it determines that such examinations are not in the public interest. The office shall waive the examination requirements for any person who has passed any tests as prescribed in s. 15(b )(7) of the Securities Exchange Act of 1934 that relates to the position to be filled by the applicant.
5. As set forth m Rule 69W-600.0024(6)(b), Florida Administrative Code,
qualifications for registration may be demonstrated. as to this category, by: 1) providing proof of passing, within two years of the date of application for registration, the Uniform Investment Adviser Law Examination (Series 65); or 2) providing proof of passing three examinations: a) the General Securities Representative Examination ("Series 7"), within two years of the date of application; b) the Uniform Combined State Law Examination ("Series 66"), within two years of 3

FINAL ORDER EXHIBIT I the date of application; and c) the Securities Industry Essentials ("SIE") Examination, within four years of the date of application.
6. The Series 65 and 66 examinations cover topics that have been determined to be
necessary to provide investment advice to clients including the following: economic factors and business information; investment vehicle characteristics; client investment recommendations and strategies; and laws, regulations, and guidelines, including prohibition of unethical business practices. The Series 65 examination consists of 130 multiple-choice questions and 10 pretest questions. The Series 66 examination consists of 100 multiple-choice questions and 10 pretest questions. The examinations are administered by the Financial Industry Regulatory Authority ("FINRA").
7. The Petition asserts the following as the basis for the waiver and the Office notes
other relevant facts:
a. The Petition requests a "permanent waiver of the 'within two years of the date of application' examination requirement, as applied to Petitioner." b. The Petition states that Petitioner has "no regulatory, criminal, civil, customer dispute, or termination disclosures."
c. The Petition states that Petitioner "passed the Series 66 examination on
October 10. 2011. and has passed numerous additional securities qualification examinations." d. The Office notes that Petitioner passed the Series 66 exam on October 1 0, 2011 . Petitioner was last registered as an associated person of a federal covered adviser or investment adviser on December 8, 2022. Accordingly, unless Petitioner applied for registration as an associated person of an investment adviser or federal covered adviser on 4

FINAL ORDER EXHIBIT I or before December 8, 2024, and such registration was subsequently granted, Petitioner's Series 66 exam results would have expired. e. The Petition states that the "purpose of §517.12, as implemented by Rule 69W-600.0024, is to ensure that persons providing investment advice in Florida possess current knowledge of securities law, regulatory obligations, and investment practices, and are subject to ongoing regulatory supervision." f. The Petition states that "Petitioner satisfies this purpose by other means, including ongoing regulated activity, recent examinations, and documented continuing education compliance." g. The Petition states that "[ s ]trict application of the examination recency requirement would impose a substantial economic hardship. Petitioner stands to earn approximately $320,000 annually, or approximately $6,153.85 per week, based on a 50- hour workweek. Reasonable preparation for retesting would require approximately 200 hours over four weeks, diverting time from revenue-producing activity."
8. Pursuant to and in compliance with Rule 28-104.005(1), Florida Administrative
Code, the Office published notice of the Petition, as required. The notice appeared in the Florida Administrative Register at Volume 52, Number 30, published May 13, 2026.
9. The Office did not receive any comments on the Petition.
CONCLUSIONS OF LAW
10. The Office is responsible for the administration and enforcement of chapter 517,
Florida Statutes, and the rules promulgated thereunder. The Office has jurisdiction over the subject matter and the Petition pursuant to section 20.121 (3)(a)2., Florida Statutes, and chapters 120 and 517, Florida Statutes. The Office is the proper state agency to receive, process, and render a ruling 5

FINAL ORDER EXHIBIT I on a petition for waiver involving chapter 517, Florida Statutes, and the rules promulgated thereunder.
11. Section 120.542(1 ), Florida Statutes, provides in part:
Strict application of unifonnly appJicable rule requirements can lead to unreasonable, unfair, and unintended results in particular instances. The Legislature finds that it is appropriate in such cases to adopt a procedure for agencies to provide relief to persons subject to regulation.
12. Section 120.542(2), Florida Statutes, provides:
Variances and waivers shall be granted when the person subject to the rule demonstrates that the purpose of the underlying statute will be or has been achieved by other means by the person and when application of a rule would create a substantial hardship or would violate principles of fairness. For purposes of this section, "substantial hardship" means a demonstrated economic, technological, legal, or other type of hardship to the person requesting the variance or waiver. For purposes of this section, "principles of fairness" are violated when the literal application of a rule affects a particular person in a manner significantly different from the way it affects other similarly situated persons who are subject to the rule.
13. Section 120.542(5), Florida Statutes, provides in part:
A person who is subject to regulation by an agency rule may file a petition with that agency, ... requesting a variance or waiver from the agency's rule. In addition to any requirements mandated by the uniform rules, each petition shall specify:
(a) The rule from which a variance or waiver is requested.
(b) The type of action requested.
( c) The specific facts that would justify a waiver or variance for the petitioner. (d) The reason why the variance or the waiver requested would serve the purposes of the underlying statute.
14. Rule 28-104.002(2), Florida Administrative Code, further provides that a petition
for variance or waiver must include the following infonnation:
(2) The petition must include the following information:
(a) The caption shall read:
Petition for (Variance from) or (Waiver of) Rule (Citation); 6

FINAL ORDER EXHIBIT I
(b) The name, address, any e-mail address, telephone number, and any facsimile number of the petitioner, if the party is not represented by an attorney or a qualified representative; ( c) The name, address, e-mail address, telephone number, and any facsimile number of the attorney or qualified representative of the petitioner, if any; ( d) The applicable rule or portion of the rule; ( e) The citation to the statute the rule is implementing; (f) The type of action requested; (g) The specific facts that demonstrate a substantial hardship or a violation of principles of fairness that would justify a waiver or variance for the petitioner; (h) The reason why the variance or the waiver requested would serve the purposes of the underlying statute; and (i) A statement whether the variance or waiver is permanent or temporary. If the variance or waiver is temporary, the petition shall include the dates indicating the duration of the requested variance or waiver.
15. The Office makes the following findings regarding the criteria for waiver provided
by section 120.542(2), Florida Statutes, as it pertains to Rule 69W-600.0024(6)(b), Florida Administrative Code:
a. The Office finds that the Petition makes generalized and conclusory statements about how the purpose of the underlying statute will be achieved by a waiver of the exam requirements imposed by Rule 69W-600.0024(6), Florida Administrative Code. The Petition states that the purpose of section 517.12, Florida Statutes, "is to ensure that persons providing investment advice in Florida possess current knowledge of securities law, regulatory obligations, and investment practices, and are subject to ongoing regulatory supervision." The Petition summarily states that "Petitioner satisfies this purpose by other means, including ongoing regulated activity, recent examinations, and documented continuing education compliance" without further explanation or comparison as to why these facts satisfy the purpose of the underlying statute or relate to the topics covered by the Series 65 examination. Further, as posed in the Petition, it would take Petitioner hundreds of hours to study for and take the exam indicating that Petitioner does not 7

FINAL ORDER EXHIBIT I currently possess the requisite knowledge on the covered topics to pass the exam. Accordingly, the Office finds that the Petition has not demonstrated that the purpose of the underlying statute, section 517 .12, Florida Statutes, implemented by the rule requirement to have timely passed the examination requirements, has been satisfied as to Petitioner's qualifications and knowledge. b. The Office finds that the Petition did not demonstrate that application of Rule 69W-600.0024(6)(b), Florida Administrative Code, as to Petitioner, would create a substantial hardship. The Petition states that "retesting would require approximately 200 hours over four weeks, diverting time from revenue-producing activity." However, the Petition neither provides details about how the loss of revenue produces economic hardship nor does it explain how Rule 69W-600.0024(6)(b), Florida Administrative Code, created such circumstances.
c. Additionally, the Office finds that the Petition fails to clearly identify or
delineate the specific way(s) Rule 69W-600.0024(6)(b), Florida Administrative Code, violates principles of fairness by affecting Petitioner in a manner significantly different from the way it affects other similarly situated persons who must take or retake an examination. The Office notes that Petitioner is in no different position relative to retaking the Series 66 exam or taking the Series 65 exam than any other person whose Series 66 exam results have expired or who must take the Series 65 exam. Based on the foregoing Statement of Facts and Conclusions of Law, the Office concludes that Petitioner has not met the criteria for waiver provided by section 120.542(2), Florida Statutes. 8

FINAL ORDER EXHIBIT I
PROPOSED AGENCY ACTION
Upon consideration of the factual statement set forth above and applicable law, NOTICE is hereby given that the Office intends to enter a Final Order DENYING Callanan's Petition for Waiver of Rule 69W-600.0024(6)(b), Florida Administrative Code, subject only to the Notice of Rights contained herein. Dated: 5/11/2026 9 Kerry • inegan Director Division of Securities

FINAL ORDER EXHIBIT I
NOTICE OF RIGHTS
PLEASE BE ADVISED THAT PURSUANT TO SECTIONS 120.569 AND 120.57, FLORIDA STATUTES, YOU MAY REQUEST A HEARING TO CONTEST THIS ACTION BY THE OFFICE. REQUESTS FOR SUCH A HEARING MUST COMPLY WITH THE PROVISIONS OF RULES 28-106.104(2), FLORIDA ADMINISTRATIVE CODE, RULE 28- 106.201, FLORIDA ADMINISTRATIVE CODE, OR RULE 28-106.301, FLORIDA ADMINISTRATIVE CODE, AND MUST BE FILED WITH:
B,· U.S. Mail. Fax or Email
Agency Clerk
Office of Financial Regulation
Office of General Counsel
P.O. Box 8050
Tallahassee, Florida 32314-8050
Phone: (850) 410-9889
Fax: (850) 410-9663
Email: Agency .Clerk@flofr.uov
OR B , Hand Deliven·
Agency Clerk
Office of Financial Regulation
Office of General Counsel
The Fletcher Building
1 01 East Gaines Street
Tallahassee, Florida 32399
Phone: (850) 410-9889
YOUR REQUEST MUST BE FILED WITH THE AGENCY WITHIN TWENTY￾ONE (21) DAYS OF THE ISSUANCE OF THIS NOTICE. YOUR FAILURE TO RESPOND TO THIS NOTICE WITHIN TWENTY-ONE (21) DAYS OF ISSUANCE WILL CONSTITUTE A WAIVER OF YOUR RIGHT TO REQUEST A HEARING AND THE OFFICE'S PROPOSED AGENCY ACTION WILL BECOME FINAL. IF YOU REQUEST A HEARING, YOU WILL HA VE THE RIGHT TO BE REPRESENTED BY COUNSEL OR OTHER QUALIFIED REPRESENTATIVE; TO OFFER TESTIMONY, EITHER ORAL OR WRITTEN; TO CALL AND CROSS-EXAMINE WITNESSES, AND TO HAVE SUBPOENAS AND SUBPOENAS DUCES TECUM ISSUED ON YOUR BEHALF. PURSUANT TO SECTION 120.573, FLORIDA STATUTES, MEDIATION IS NOT AVAILABLE.

FINAL ORDER EX HIBIT I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11th day of May, 2026, a true and correct copy of the foregoing has been furnished by U.S. mail and email to the following:
Brian P. Callanan
4975 East Sabal Palm Blvd.
Tamarac, FL 33319 brian@callananfinancial.com
11
Assistant General Counsel
Office of Financial Regulation
200 E. Gaines Street
Tallahassee, FL 32399-03 79
Tel: (850) 410-9803
Email: Ryann.White@flofr.gov

FINAL ORDER EX HIBIT I
PETITION FOR WAIVER OF RULE 69W-600.0024(6)(b), F.A.C.
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
TO:
Agency Clerk
Florida Office of Financial Regulation
COPYTO:
Joint Administrative Procedures Committee
Email: japc@Jeg.state.ft.us
FROM:
Brian P. CalJanan (CRD No. 5752195)
Email: brian@callananfinancial.com
Telephone: (954) 557-3400
I. INTRODUCTION AND JURISDICTION
Petitioner, Brian P. Callanan ("Petitioner"), files this Petition for Waiver pursuant to §120.542, Florida Statutes, and Rule 28-104.002, Florida Administrative Code, seeking a waiver from the strict application of the examination recency requirement contained in Rule 69W-600.0024(6)(b), Florida Administrative Code, as applied to Petitioner's application for registration as an associated person of an invesbnent adviser and/or federal covered adviser under§Sl 7.12, Florida Statutes.
11. APPLICABLE RULE AND STATUTE
Rule from which relief is sought: Rule 69W-600.0024(6)(b ), Florida Administrative Code. Underlying statute implemented by the rule: §517.12, Florida Statutes. Type of relief requested: A permanent waiver of the "within two years of the date of application" examination recency requirement, as applied to Petitioner.
Ill. MATERIAL FACTS
Petitioner passed the Series 66 examination on October l 0, 2011, and has passed numerous additional securities qualification examinations, including Series 7, Serles 24, the SIE, and additional examinations in 2023 (Series 79TO and Series 82TO), as reflected in Exhibit A. Petitioner ls currently registered in regulated securities capacities and licensed as a Florida agent. EXHIBIT A

l
FINAL ORDER EXHIBIT I
The BrokerCheck report reflects no regulatory, criminal, civil, customer dispute, or termination disclosures, and reflects one resolved financial disclosure event Petitioner has executed a Letter or Intent to acquire an investment advisory practice that requires an active Series 66 registration to engage in the business (Exhibit H).
IV. ARGUMENT
The purpose of §517 .12, as implemented by Rule 69W-600.0024, is to ensure that persons providing investment advice in Florida possess current knowledge of securities law, regulatory obligations, and investment practices, and are subject to ongoing regulatory supervision. Petitioner satisfies this purpose by other means, including ongoing regulated activity, recent examinations, and documented continuing education compliance. Strict application of the examination recency requirement would impose a substantial economic hardship. Petitioner stands to earn approximately $320,000 annually, or approximately $6,153.85 per week, based on a SO-hour workweek. Reasonable preparation for retesting would require approximately 200 hours over four weeks, diverting time from revenue-producing activity. Under the attached Letter of Intent, Petitioner's expected monthly revenue from the acquired practice would range from approximately $13,333.33 (50% payout) to $26,666.67 (full payout) predicated on final definitive agreement, placing material revenue at risk due to retesting delays.
V. REQUEST FOR RELIEF
WHEREFORE, Petitioner respectfully requests that the Office grant this Petition for Waiver and waive the strict application of the examination recency requirement in Rule 69W￾600.0024(6)(b), Florida Administrative Code, as applied to Petitioner. Respectfully submitted, Brian P. Callanan CRD No. s.~ 9~/ --z:- ~~ ~ Date: -~~..=-,f __ EXHIBIT A

FINAL ORDER EX HIBIT II
White, Ryann
From: White, Ryann
Sent:
To:
Cc:
Monday, May 11, 2026 2:38 PM brian@callananfinancial.com dan@stirlingshire.com Subject:
Attachments:
Good afternoon,
SERVICE OF DOCUMENT: OFR LEGAL CASE NO. 136058-SR; In Re: Brian P. Callanan, Petition for Waiver from Rule 69W-600.0024(6)(b), F.A.C. Mail - Callanan NOi to Enter FO Issued 5.11.26.pdf Please find attached Notice oflntent to Enter a Final Order Denying Callanan's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, and Notice of Rights issued today via U.S. mail in the above-referenced matter. STATE OF FWRIDA OFFICE OF FINANCIAl, REGULATION In Re:
BRIAN P. CALLANAN, Petition for
Wah•er from Ruic 69W..(j()0.0024(6)(b),
Florida Administi-allve Code,
Case Number: 136058-SR
Petitioaer,
NOTICE Qt' INTENT TO ENTER A FINAL ORDER DENYING CALLANAS'S P:tTITION FOR WAJVER FROM RULE 69W~.0024!61(h), FLORJDA ADMINJSTRATIVE COD£. AND NOTICE OF RIGHTS Regards, Ryann E. White Assistant General Counsel Office of Financial Regulation Office of General Counsel 200 East Gaines Street Tallahassee, FL 32399-0375 Office: (850) 410-9500 Direct: (850) 410-9803 Promoting a safe marketplace for financial success Connect with OFR! @(f)Qry 1

FINAL ORDER EX HIBIT II
Please note that pursuant to chapter 119, Florida Statutes, correspondence with the Office of Financial Regulation is considered public record. This correspondence is available to the public upon request unless exempt from disclosure. 2