Final Order Denying Cowles' Petition for Variance or Waiver from Rule 69W-600.0024(6)

Index: OFR 2026 - 337 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: KRISTOPHER J. COWLES, Petition for Variance or Waiver from Rule 69W￾600.0024(6), Florida Administrative Code, Petitioner. Case Number: 136856-SR FINAL ORDER DENYING COWLES' PETITION FOR VARIANCE OR WAIVER FROM RULE 69W-600.0024(6), 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 Variance or Waiver from Rule 69W-600.0024(6), Florida Administrative Code (hereinafter "Petition"), submitted February 27, 2026, by Kristopher J. Cowles ("Cowles"). Pursuant to section 120.542(8), Florida Statutes, the Office enters this Final Order Denying Cowles' Petition for Variance or Waiver from Rule 69W-600.0024(6), Florida Administrative Code, and in support thereof, makes the following Findings of Fact and Conclusions oflaw: FINDINGS OFF ACT

1. On May 26, 2026, the Office issued a Notice of Intent to Enter a Final Order Denying Cowles' Petition for Variance or Waiver from Rule 69W-600.0024(6), 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 Cowles' Petition for Variance or Waiver from Rule 69W-600.0024(6), Florida Administrative Code, as Cowles has not met the criteria for Variance or Waiver provided by section 120.542(2), Florida Statutes. The Notice oflntent is attached hereto as Exhibit I.

2. The Notice of Intent had attached thereto a Notice of Rights, which fully advised Cowles 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 Cowles on May 26, 2026, via USPS mail.

4. The Notice oflntent was sent to Cowles via email on May 27, 2026. The email is attached hereto as Exhibit II.

5. Cowles' response to the Notice oflntent was to be filed with the Office on or before June 22, 2026. As of the date of this Final Order, Cowles 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 oflntent, being uncontested by Cowles, 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 Cowles 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 of record 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. I 20.68 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. Cowles' 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 Cowles' right to an administrative hearing. See Rule 28-106.111(4), Fla. Admin. Code. 11. Cowles 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 Cowles' Petition for Variance or Waiver from Rule 69W-600.0024(6), Florida Administrative Code, set forth in the Notice of Intent, being uncontested by Cowles, 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: Cowles' Petition for Variance or Waiver from Rule 69W-600.0024(6), Florida Administrative Code, is hereby DENIED. DONE and ORDERED this ~ 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 Bv Hand Delivery 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 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 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 /4f~ y of July, 2026, a true and correct copy of the foregoing has been furnished by U.S. mail and email to the following: Kristopher J. Cowles 515 Cypress Cir. Tequesta, FL 33469 kriscow les@comcast.net 5 IIUU',_,..., Regulation X 8050 Tallaha , FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

FINAL ORDER EXHIBIT I STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: KRISTOPHER J. COWLES, Petition for Variance or Waiver from Rule 69W￾600.0024(6), Florida Administrative Code, Petitioner. Case Number: 136856-SR NOTICE OF INTENT TO ENTER A FINAL ORDER DENYING COWLES' PETITION FOR VARIAN CE OR WAIVER FROM RULE 69W-600.0024{6 ), FLORIDA ADMINSITRATIVE CODE, AND NOTICE OF RIGHTS This matter is before the State of Florida, Office of Financial Regulation ("Office"), on the request for a variance or waiver from the examination requirements of Rule 69W-600.0024(6), Florida Administrative Code (hereinafter "Petition"), submitted February 27, 2026, by Kristopher J. Cowles ("Petitioner''), Central Registration Depository ("CRD") Number 4012612. 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 Crowles' Petition for variance or waiver of the examination requirements of Rule 69W-600.0024(6), Florida Administrative Code. STATEMENT OF FACTS

1. On February 27, 2026, the Office received the Petition for a "variance or waiver from the rule requiring re-examination due to lapse of Investment Adviser Representative registration for a period exceeding two years" and requesting "[a]pproval to reinstate [Petitioner's]

FINAL ORDER EX HIBIT I Investment Adviser Representative registration in the State of Florida without the necessity of retaking the Series 65 examination" (the "Petition"). 1 (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 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 SIB Examination: 1 The Office reads this Petition as a request for variance or waiver from Rule 69W-600.0024(6), Florida Administrative Code, which requires an applicant for registration as an associated person of an investment adviser or federal covered adviser to satisfy certain examination requirements. 2

FINAL ORDER EXHIBIT I a. Applicants whose registration as an associated person was tenninated between October 1, 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: I .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.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 fo11ows: 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. 5 J 7.1201 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 3

FINAL ORDER EXHIBIT I 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. I S(b )(7) of the Securities Exchange Act of 1934 that relates to the position to be filled by the applicant. 5. As set forth in 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 the date of application; and c) the Securities Industry Essentials ("SIE") Examination, within four years of the date of application. 6. The Series 65 examination covers 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 IO pretest questions. The Series 65 examination is administered by the Financial Industry Regulatory Authority ("FINRA"). 7. The Petition asserts the following as the basis for the variance or waiver and the Office notes other relevant facts: a. The Petition requests a "variance or waiver from the rule requiring re￾examination due to the lapse of my Investment Adviser Representative registration for a period exceeding two years." 4

FINAL ORDER EXHIBIT I b. The Petition states that Petitioner has "successfully passed the Uniform Investment Adviser Law Examination (Series 65) and previously maintained proper registration. [Petitioner's] registration lapsed due to business restructuring and professional focus shifts within [Petitioner's] insurance and health benefits enterprises, not due to disciplinary action, regulatory deficiency, or customer-related matters." c. The Petition states that Petitioner's "lapse was administrative and structural in nature rather than the result of disengagement from industry knowledge or professional competency." d. The Office notes that Petitioner passed the Series 65 exam on June 28, 2019. Petitioner was last registered as an associated person of a federal covered adviser or investment adviser on December 12, 2023. Accordingly, unless Petitioner applied for registration as an associated person of an investment adviser or federal covered adviser on or before December 12, 2025, and such registration was subsequently granted, Petitioner's Series 65 exam results would have expired. e. The Office notes that Petitioner does not currently have an application for registration as an associated person of an investment adviser or federal covered adviser pending before the Office. e. The Petition states that "requiring re-examination . . would create . . . [ e ]conomic hardship associated with delayed advisory operations [ and] [ o ]perational hardship affecting business planning and service expansion. " f. The Petition states that "[t]he purpose of the underlying statute is to ensure that individuals acting as Investment Adviser Representatives possess the knowledge, competency, and ethical standards necessary to protect the investing public." The Petition 5

FINAL ORDER EXHIBIT I states that the "purpose has been achieved and continues to be achieved in [Petitioner's] case through: [p ]rior successful completion of the Series 65 examination[,] [ o ]ngoing professional engagement within regulated financial services sectors[,] [ m ]aintenance of active Jicensure in related regulated industries[, and] [a]bsence of disciplinary history." g. The Petition states that "[s]trict application of the rule in this instance produces an unintended and inequitable result when compared to similarly situated professionals who maintain industry engagement but experience administrative lapses due to business restructuring rather than competency issues." 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 53, published March 18, 2026. 9. The Office did not receive any comments on the Petition. CONCLUSIONS OF LAW I 0. 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 on a petition for variance or waiver involving chapter 517, Florida Statutes, and the rules promulgated thereunder. 11. Section 120.542(1 ), Florida Statutes, provides in part: Strict application of uniformly applicable 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: 6

FINAL ORDER EX HIBIT I 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 information: (2) The petition must include the following information: (a) The caption shall read: Petition for (Variance from) or (Waiver of) Rule (Citation); (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 7

FINAL ORDER EXHIBIT I (i) A statement whether the variance or waiver is permanent or temporary. If the variance or waiver is temporary, the petition shaJI include the dates indicating the duration of the requested variance or waiver. 15. The Office finds that the Petitioner does not currently have an application for registration as an associated person of an investment adviser or federal covered adviser pending before the Office. Thus, Petitioner is not an applicant for registration as an associated person of an investment adviser or federal covered adviser. Therefore, Petitioner is not subject to agency action pursuant to Rule 69W-600.0024(6), Florida Administrative Code, which requires "an individual applying to be registered as an associated person of an investment adviser or federal covered adviser" to provide the Office proof of meeting specified exam requirements. 16. Accordingly, a variance or waiver of the application of Rule 69W-600.0024( 6), Florida Administrative Code, as to the Petitioner, cannot be granted because the Office makes the preliminary determination that Petitioner is not currently subject to Rule 69W-600.0024(6), Florida Administrative Code. A hypothetical application, to be filed on behalf of Petitioner, is not ripe for evaluation by the Office and does not satisfy the condition precedent for consideration of a request for a variance or waiver pursuant to section 120.542, Florida Statutes. 17. Although the Office has concluded that it does not have jurisdiction over the subject matter and the Petition and that Petitioner cannot request a variance or waiver of Rule 69W￾600.0024( 6), Florida Administrative Code, because the Petitioner is not currently subject to Rule 69W-600.0024(6), Florida Administrative Code, the Office makes the following findings regarding the criteria for variance or waiver provided by section 120.542(2), Florida Statutes, as it pertains to Rule 69W-600.0024(6), Florida Administrative Code: a. The Office finds that the Petition fails to specify whether the variance or waiver requested is permanent or temporary. 8

FINAL ORDER EXHIBIT I b. The Office finds that the Petition makes generalized and conclusory statements about how the purpose of the underlying statute wi11 be achieved by a variance or waiver of the exam requirements imposed by Rule 69W-600.0024(6), Florida Administrative Code. The Petition does not cite to the underlying statute but states that its purpose "is to ensure that individuals acting as Investment Adviser Representatives possess the knowledge, competency, and ethical standards necessary to protect the investing public." The Petition summarily states that "[g]ranting this waiver would not compromise investor protection" and that Petitioner has demonstrated competency by previously passing the Series 65 examination, not having any disciplinary history, engaging in financial services business, and maintaining active Iicensure in related regulated industries. The facts that Petitioner passed the Series 65 nearly 7 years ago and that Petitioner has been engaged in related financial services business without further explanation or comparison as to why these facts relate to the topics covered by the Series 65 examination or to Petitioner's qualifications and knowledge of the securities industry and laws are unpersuasive. 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. c. The Office finds that the Petition did not demonstrate that application of Rule 69W-600.0024(6), Florida Administrative Code, as to Petitioner, would create a substantial hardship. The Petition states that requiring Petitioner to satisfy the exam requirements would create "economic hardship" and "operational hardship" related to Petitioner's inability to conduct investment advisory business in a registered capacity in 9

FINAL ORDER EX HIBIT I Florida. However, the Petition neither provides details about the economic hardship or operational hardship nor does it explain how Rule 69W-600.0024(6), Florida Administrative Code, created such circumstances. d. Additionally, the Office finds that the Petition fails to clearly identify or delineate the specific way(s) Rule 69W-600.0024(6), 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 Petition makes a conclusory statement that application of the rule "produces an unintended and inequitable result ... [for] professionals who maintain industry engagement but experience administrative lapses due to business restructuring" without further explanation or detail regarding how Petitioner is affected differently from such professionals or persons operating within the securities industry in a capacity other than that of an associated person of an investment adviser. The Office notes that Petitioner is in no different position relative to retaking the Series 65 exam or Series 66 exam than any other person whose Series 65 or Series 66 exam results have expired. Based on the foregoing Statement of Facts and Conclusions of Law, the Office concludes that Petitioner has not met the criteria for variance or waiver provided by section 120.542(2), Florida Statutes. [Remainder ofpage intentionally blank]

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 Crowles' Petition for Variance or Waiver of the examination requirements of Rule 69W-600.0024(6), Florida Administrative Code, subject only to the Notice of Rights contained herein. Dated: 5/26/2026 Keny'b½ Director Division of Securities NOTICE OF RIGHTS PLEASE BE ADVISED THAT PURSUANT TO SECTIONS 120.569 AND 120.57, FLORIDA STA TlJTES, YOU MAY REQUEST A HEARING TO CONTEST TIIIS 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: By 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: Agencv.Clerk@flofr.gov OR B Hand Deliven · Agency Clerk 11 Office of Financial Regulation Office of General Counsel The Fletcher Building 101 East Gaines Street Tallahassee, Florida 32399 Phone: (850) 410-9889

FINAL ORDER EXHIBIT I 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. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 26th day of May, 2026, a true and correct copy of the foregoing has been furnished by U.S. mail and email to the following: Kristopher J. Cowles 515 Cypress Cir. Tequesta, FL 33469 kriscowles@comcast.net 12 Assistant General Counsel Office of Financial Regulation 200 E. Gaines Street Tallahassee, FL 32399-0379 Tel: (850) 410-9803 Email: Ryann.White@flofr.gov

FINAL ORDER EXHIBIT I RECEIVED - FLORIOII FEB 2 7 2026 Subject: Petition for Variance or Waiver - Reinstatement of Uniform Investment Adviser Law Examination (Series 65) Registration - CRD #4012612 Ofllcn of RnRnaai Regulation Dear Sir or Madam, I respectfully submit this correspondence as a formal petition for a variance or waiver pursuant to Florida Statute § 120.542, seeking reinstatement of my registration as an Investment Adviser Representative based upon my prior successful completion of the Uniform Investment Adviser Law Examination (Series 65), without the requirement to retake the examination. Petitioner: Kristopher J. Cowles CRD #4012612 (a) Rule from Which Variance or Waiver Is Requested This petition requests a variance or waiver from the rule requiring re-examination due to the lapse of my Investment Adviser Representative registration for a period exceeding two years. (b) Type of Action Requested Approval to reinstate my Investment Adviser Representative registration in the State of Florida without the necessity of retaking the Series 65 examination. (c) Specific Facts Justifying the Waiver I successfully passed the Unifonn Investment Adviser Law Examination (Series 65) and previously maintained proper registration. My registration lapsed due to business restructuring and professional focus shifts within my insurance and health benefits enterprises, not due to disciplinary action, regulatory deficiency, or customer-related matters. During the period in which my registration was inactive: EXHIBIT A

FINAL ORDER EXHIBIT I • I remained continuously engaged in the financial services and insurance industry. • I maintained active state insurance licensure. • I continued operating regulated entities, including health and property & casualty agencies. • I remained committed to regulatory compliance and ethical standards. • I did not engage in advisory activities requiring Series 65 registration while inactive. My lapse was administrative and structural in nature rather than the result of disengagement from industry knowledge or professional competency. Requiring re-examination under these circumstances would create a substantial hardship, including: • Economic hardship associated with delayed advisory operations. • Operational hardship affecting business planning and service expansion. • Unnecessary duplication of qualification already demonstrated through successful prior examination and continued industry involvement. (d) How the Requested Waiver Serves the Purpose of the Underlying Statute The purpose of the underlying statute is to ensure that individuals acting as Investment Adviser Representatives possess the knowledge, competency, and ethical standards necessary to protect the investing public. That purpose has been achieved and continues to be achieved in my case through: • Prior successful completion of the Series 65 examination. • Ongoing professional engagement within regulated financial services sectors. • Maintenance of active Iicensure in related regulated industries. • Absence of discip1inary history. • Commitment to full compliance with all Florida regulatory requirements. Granting this waiver would not compromise investor protection. Rather, it would allow a qualified and previously examined professional to resume regulated advisory services without unnecessary duplication of testing where competency has already been demonstrated. EXHIBIT A

FINAL. 'ORDERcXHIBIT I Further, strict application of the rule in this instance produces an unintended and inequitable result when compared to similarly situated professionals who maintain industry engagement but experience administrative lapses due to business restructuring rather than competency issues. Statement of Fairness and Hardship Literal application of the re-examination requirement in this case creates substantial hardship and does not materially advance the statutory purpose of investor protection. My knowledge base, regulatory familiarity, and industry involvement have remained continuous and current. I respectfully submit that the purpose of the statute has been achieved by other means and that granting this variance or waiver is consistent with both the spirit and intent of §120.542. I appreciate your time and consideration of this petition. Please advise if any additional documentation, attestations, or supporting materials would assist in your review. Respectful1y, Kristopher J. Cowles CRD #4012612 (561) 315-4500 kriscowles@comcast.net EXHIBIT A

White, Ryann From: Sent: To: Cc: Subject: Attachments: Good morning, FINAL ORDER EXHIBIT II White, Ryann Wednesday, May 27, 2026 1:04 PM OFR Notice Of Intent Filings Melchior, Greg; Finegan, Kerry; Harris, Ann A LEGAL CASE NO. 136856-SR; In Re: Kristopher J. Cowles - NOID Issued SERVICE OF DOCUMENT: OFR LEGAL CASE NO. 136856-SR; In Re: Kristopher J. Cowles, Petition for Variance or Waiver from Rule 69W-600.0024(6), F.A.C.; NOI-ENV - 136856- SR - Kristopher J. Cowles.pdf Please see attached NOID issued via U.S. mail and email. 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! @Cf)@) 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.