2026-07-01
Added · Updated
The Florida Office of Financial Regulation issued a Final Order denying Geoffrey Parkinson, Jr.'s petition for a waiver of Rule 69W-600.0024(6), which mandates timely passing of specific investment adviser examination qualifications. The Office determined that Parkinson failed to meet the statutory criteria for a waiver under section 120.542(2), Florida Statutes, because his petition was procedurally deficient and failed to demonstrate substantial hardship or a violation of fairness principles. Consequently, the petition was denied due to Parkinson's failure to specify the waiver's duration, improper captioning, and insufficient evidence that his prior exam passage and experience satisfied the underlying statute's purpose.
Index: OFR 2026 - 328 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: GEOFFREY PARKINSON, JR., Petition for Waiver from Rule 69W-600.0024(6), Florida Administrative Code, Petitioner. Case Number: 134199-SR FINAL ORDER DENYING PARKINSON'S PETITION FOR 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 waiver from Rule 69W-600.0024(6), Florida Administrative Code (hereinafter "Petition"), submitted November 19, 2025, by Geoffrey Parkinson, Jr. ("Parkinson"). Pursuant to section 120.542(8), Florida Statutes, the Office enters this Final Order Denying Parkinson's Petition for Waiver from Rule 69W-600.0024(6), Florida Administrative Code, and in support thereof, makes the following Findings of Fact and Conclusions oflaw: FINDINGS OF FACT
On February I I, 2026, the Office issued a Notice of Intent to Enter a Final Order Denying Parkinson's Petition for 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 oflntent gave notice of the Office's intent to enter a Final Order Denying Parkinson's Petition for Waiver from Rule 69W-600.0024(6), Florida Administrative Code, as Parkinson 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.
The Notice of Intent had attached thereto a Notice of Rights, which fully advised Parkinson 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.
The Notice oflntent was sent to Parkinson on February 11, 2026, via USPS mail.
The Notice oflntent was sent to Parkinson via email to his firm on February 11,
The email is attached hereto as Exhibit II.
Parkinson's response to the Notice oflntent was to be filed with the Office on or before March 9, 2026. As of the date of this Final Order, Parkinson has failed to file a petition for hearing or to file any other document with the Office in response to the Notice oflntent.
The facts alleged in the Notice of Intent, being uncontested by Parkinson, 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
The Office is responsible for the administration and enforcement of chapter 517, Florida Statutes, and has jurisdiction over the subject matter and Parkinson pursuant to chapters 120 and 517, Florida Statutes.
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. 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. Parkinson'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 Parkinson's right to an administrative hearing. See Rule 28-106.111(4), Fla. Admin. Code. 11. Parkinson 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 Parkinson's Petition for Waiver from Rule 69W-600.0024(6), Florida Administrative Code, set forth in the Notice of Intent, being uncontested by Parkinson, 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: Parkinson's Petition for 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 nJDICIAL 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 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 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 j5f- day of July, 2026, a true and correct copy of the foregoing has been furnished by U.S. mail and email to the following: Geoffrey Parkinson, Jr. President & CEO Charitable Foundation Services LLC 6270 Riva Lakes Blvd. Sarasota, FL 34241-2725 geoff@fsllc.net 5 egulation 50 Tallahassee 32314-8050 Email: Ag cy.Clerk@flofr.gov Tel: (850) 410-9889
EXHIBIT I STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: GEOFFREY PARKINSON, JR., Petition for Waiver from Rule 69W-600.0024(6), Florida Administrative Code, Petitioner. Case Number: 134199-SR NOTICE OF INTENT TO ENTER A FINAL ORDER DENYING PARKINSON'S PETITION FOR 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 waiver from Rule 69W-600.0024(6), Florida Administrative Code (hereinafter "Petition"), submitted November 19, 2025, by Geoffrey Parkinson, Jr. ("Petitioner"), Central Registration Depository ("CRD") Number 2180284. 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 the Petition for waiver from Rule 69W-600.0024(6), Florida Administrative Code. STATEMENT OF FACTS
EXHIBIT I 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:
EXHIBIT I 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.
(f) The examination requirement for associated persons of an investment adviser or federal covered adviser shall not apply to an applicant who currently holds one of the following professional designations:
EXHIBIT I 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 10 pretest questions and is administered by the Financial Industry Regulatory Authority ("FINRA"). 7. Petitioner asserts the following as the basis for the waiver and the Office notes other relevant facts: a. Petitioner "seeks recognition of a previously passed Series 65 exam." b. Petitioner states that "Petitioner successfully completed the ... Series 65 (4/2/1997-88) .... [and that] the Series 65 ... 'expired' solely due to an administrative registration gap slightly over two years, not due to failure or lack of qualification." c. Petitioner states that "Connecticut and Pennsylvania previously issued waivers acknowledging Petitioner's qualification despite the lapse." 4
EX HIBIT I d. The Office notes that Petitioner passed the Series 65 exam on April 2, 1997. Petitioner was not registered as an associated person of an investment adviser or federal covered adviser until May 14, 2012, 15 years after passing the Series 65 exam pursuant to an exam waiver granted by the state of Connecticut. e. Petitioner states that "Petitioner has 34 years of continuous financial industry experience." f. Petitioner states that "[t]he rule aims to ensure advisory competence. Petitioner already met his goal by passing all required exams and maintaining long-term professional experience." g. The Office notes that Petitioner does not state whether the waiver requested is permanent or temporary. h. The Office notes that the Petition is not properly captioned, failing to utilize "Petition for (Variance from) or (Waiver of) Rule (Citation)." 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 51, Number 230, published November 26, 2025. 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
EX HIBIT I on a petition for a waiver or variance 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: 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); 6
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), Florida Administrative Code: a. The Office finds that the Petition fails to specify whether the waiver requested is permanent or temporary. b. The Office finds that the Petition is not properly captioned. c. The Office finds that the Petition does not cite to the statute the rule is implementing, section 517.12, Florida Statutes, but states that the rule "aims to ensure advisory competence." The Petition vaguely alludes to the facts that Petitioner has previously passed the Series 65 exam and has "34 years of continuous financial industry experience" without further explanation as to why these facts ensure Petitioner's competence or otherwise satisfy the purpose of the underlying statute. 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 7
EXHIBIT I timely passed the examination requirements, has been satisfied as to Petitioner's qualifications and knowledge. d. 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. Petitioner states that "application of the two-year rule creates unreasonable hardship and does not further investor protection" but does not provide specific details about such hardship. e. 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. Further, the Office notes that Petitioner is in no different position relative to retaking the Series 65 exam or taking the Series 66 exam than any other person who must retake or take these exams. 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. 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 Parkinson's Petition for Waiver of Rule 69W-600.0024(6), Florida Administrative Code, subject only to the Notice of Rights contained herein. Dated: 2/9/26 8 Director Division of Securities
EXHIBIT I NOTICE OF RIGHTS PLEASE BE ADVISED THAT PURSUANT TO SECTIONS 120.569 AND 120.57, FLORIDA ST A TUTES, 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: 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: 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 YOUR REQUEST MUST BE FILED WITH THE AGENCY WITHIN TWENTYONE (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 W AIYER 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 I 20.573, FLORIDA STATUTES, MEDIATION IS NOT AVAILABLE. 9
EXHIBIT I CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11th day of February, 2026, a true and correct copy of the foregoing has been furnished by U.S. mail and email to the following: Geoffrey Parkinson, Jr. President & CEO Charitab]e Foundation Services LLC 6270 Rivo Lakes Blvd. Sarasota, FL 34241-2725 geoff@fsllc.net ~White Assistant Genera] Counsel Office of Financia] Regulation 200 E. Gaines Street Tallahassee, FL 32399-0379 Tel: (850) 410-9803 Email: Ryann. White@flofr.gov
¥f.~ Charitable Foundation Services LLC J • §[ 6270 Rivo Lakes Blvd., Sarasota, FL 34241-2725 EXHIBIT I Petition for Waiver or Variance
From: To: White Ryann "geoff@fsUc.net" EXHIBIT II Subject: SERVICE OF DOCUMENT: OFR LEGAL CASE NO. 134199-SR; In Re: Geoffrey Parkinson, Jr., Petition for Waiver from Rule 69W-600.0024(6), F.A.C. Date: Wednesday, February 11, 2026 12:59:00 PM Attachments: Parkinson NOi to Enter EQ Final 2.11.26.pdf Parkinson eetition tor Rule wajver - EXHIBIT A Qdt iroaaeoo1.ona iroaaeooz.ona iroaaeoo3.ona iroaae004.ona iroaaeoos.ona Good afternoon, Please find attached Notice oflntent to Enter a Final Order Denying Parkinson's Petition for Waiver from Rule 69W-600.0024(6), Florida Administrative Code, and Notice of Rights issued today via U.S. mail in the above-referenced matter. STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: GEOFFREY PARKINSON, JR., Petition for Wniver from Role 69W-600.0024(6), Floridn Administ1·ative Code, Petitioner. Case Number: 134199-SR NOTICE OF INTEl'lff TO ENTER A FINAL ORDER DENYING PARKINSON'S PETITION FOR WAIVER FROM RULE 69\V-600.0024(6), FLORIDA ADMINISTRUIVE CODE, 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)@
EXHIBIT 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.