Index: OFR 2026 - 522

DOCKETED
10/29/2026
LEGAL

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION

In Re:
KIP A. HOOVER Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, Case Number: 137379-SR Petitioner.

FINAL ORDER DENYING HOOVER'S PETITION FOR WAIVER 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 June 11, 2026, on behalf of Kip A. Hoover ("Hoover"). Pursuant to section 120.542(8), Florida Statutes, the Office enters this Final Order Denying Hoover'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 of Law:

FINDINGS OF FACT

1. On September 8, 2026, the Office issued a Notice of Intent to Enter a Final Order Denying Hoover'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 Hoover's Petition for waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, as Hoover 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 Hoover 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 of Intent was sent to Hoover at his firm on September 8, 2026, via USPS mail.

4. The Notice of Intent was sent to Hoover at his firm via email on September 8, 2026. The email is attached hereto as Exhibit II.

5. Hoover's response to the Notice of Intent was to be filed with the Office on or before October 5, 2026. As of the date of this Final Order, Hoover 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 Hoover, 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 Hoover 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 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. Hoover'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 Hoover's right to an administrative hearing. See Rule 28-106.111(4), Fla. Admin. Code.

11. Hoover 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 Hoover's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, set forth in the Notice of Intent, being uncontested by Hoover, 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] Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED: Hoover's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, is hereby DENIED.

DONE and ORDERED this 29th 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:

By U.S. Mail, Fax or Email	OR	By Hand Delivery
Agency Clerk		Agency Clerk
Office of Financial Regulation		Office of Financial Regulation
P.O. Box 8050		Office of General Counsel
Tallahassee, Florida 32314-8050		The Fletcher Building
Phone: (850) 410-9889		101 East Gaines Street
Fax: (850) 410-9663		Tallahassee, Florida 32399
Email: Agency.Clerk@flofr.gov		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 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 by U.S. Mail to Kip A. Hoover, c/o Licensing and Registration, Kestra Financial, 5707 Southwest Parkway, Bldg. 2, Suite 400, Austin, TX 78735, and by electronic mail to registration@kestrafinancial.com on this[_ day of October, 2026.

Agency Clerk
Office of Financial Regulation
Post Office Box 8050
Tallahassee, FL 32314-8050
Email: Agency.Clerk@flofr.gov
Tel: (850) 410-9889

-8050
. erk@flofr.gov e:
-9889

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION

In Re:
KIP A. HOOVER Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, Petitioner.
Case Number: 137379-SR

NOTICE OF INTENT TO ENTER A FINAL ORDER DENYING HOOVER'S PETITION FOR WAIVER 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 waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code (hereinafter "Petition"), submitted June 11, 2026, on behalf of Kip A. Hoover ("Petitioner"), Central Registration Depository ("CRD") Number 4139720. 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 Hoover's Petition for waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code.

STATEMENT OF FACTS

1. On June 11, 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

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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)(b), 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 (SIE) Examination. The following applicants will be considered to have passed the SIE Examination:

    a. Applicants whose registration as an associated person was terminated 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:

1.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 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 in Rule 69W-600.0024(6), 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

FINAL ORDER EXHIBIT I

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 Rule 69W-600.0024(6)(b), Florida Administrative Code.

b. The Petition states that Petitioner "is an investment adviser representative and owner of Otium Financial Planners. Petitioner has been registered as an investment adviser representative since 2005 and is currently registered in the state of Ohio."

c. The Petition states that Petitioner "resides in Florida on a recurring seasonal basis for approximately five month each year."

d. The Petition states that "Petitioner does not maintain a physical office in Florida. . . This request is based on Petitioner's current business model, under which advisory services are provided primarily to clients located outside Florida without the operation of a Florida place of business."

e. The Office notes that Petitioner has never passed the Series 66 or 65 examination or been registered as an associated person of a federal covered adviser or investment adviser in Florida.

f. The Petition states that "[s]trict application of Rule 69W-600.0024(6)(b) would impose a substantial hardship on the Petitioner .... Restricting advisory activity during periods of temporary residence in Florida would disrupt client service, impair fulfillment of fiduciary obligations, and interfere with ongoing account monitoring and financial planning activities. The resulting impact would extend to both clients and firm operations."

g. The Petition states that "[g]ranting the requested waiver would be consistent with the purposes of Chapter 517, Florida Statutes, including investor protection and the regulation of advisory activity."

h. The Petition states that "Petitioner's activities remain subject to fiduciary obligations, firm compliance controls, and supervisory oversight."

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 115, published June 15, 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

FINAL ORDER EXHIBIT I

on a petition for a 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:

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);

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)(b), Florida Administrative Code. The Petition does not state the purpose of the underlying statute, section 517.12, Florida Statutes, but instead vaguely alludes to the facts that Petitioner has prior experience as an associated person of a federal covered adviser and is registered as such in the state of Ohio. Additionally, the Petition summarily states that "[g]ranting the requested waiver would be consistent with the purposes of Chapter 517, Florida Statutes, including investor protection and the regulation of advisory activity" without further explanation as to what 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

FINAL ORDER EX HIBIT I

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 alludes to the fact that Petitioner will be unable to conduct business in Florida if a waiver is not granted but does provide further details about such hardship or explain how application of Rule 69W-600.0024(6)(b), Florida Administrative Code, as to Petitioner otherwise creates an economic, technological, legal, or other type of hardship for the Petitioner.

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. Further, the Office notes that Petitioner is in no different position relative to taking the Series 65 or 66 exam than any other person who must retake or take these exams.

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 Hoover's Petition for Waiver of Rule 69W-600.0024(6)(b), Florida Administrative Code, subject only to the Notice of Rights contained herein.

Dated: 9/8/2026

Kerry Finegan

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:

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 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

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 HAVE 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 8th day of September, 2026, a true and correct copy of the foregoing has been furnished by U.S. mail and email to the following:

Kip A. Hoover c/o Licensing and Registration
Kestra Financial
5707 Southwest Parkway, Bldg. 2, Suite 400
Austin, TX 78735 registration@kestrafinancial.com

Ryann E. White
Assistant General Counsel
Office of Financial Regulation
200 E. Gaines Street
Tallahassee, FL 32399-0379
Tel: (850) 410-9803
Email: Ryann.White@flofr.gov

Ryann White

FINAL ORDER EX HIBIT I

5707 Southwest Parkway, Bldg. 2, Ste. 400, Austin, Texas 78735 844-5-KESTRA (844-553-7872)

KESTRA FINANCIAL

PETITION FOR WAIVER OF RULE 69W-600.0024(6)(b), F.A.C.

Petitioner Information
Name: Kip A. Hoover
Address: c/o Licensing and Registration
5707 Southwest Parkway, Bldg. 2, Suite 400
Austin, TX 78735
Email: registration@kestrafinancial.com
Telephone: 844-553-7872 (Option 6,1)
Fax: N/A

Attorney/ Qualified Representative

Petitioner is not represented by legal counsel. Administrative coordination is facilitated through Licensing and Registration at the address above.

Type of Action Requested

Pursuant to Section 120.542, Florida Statutes, Petitioner requests a waiver of Rule 69W-600.0024(6)(b), Florida Administrative Code.

Rule from Which Waiver is Sought

Rule 69W-600.0024(6)(b), Florida Administrative Code.

Statute Implemented by the Rule

Section 517.12, Florida Statutes.

Statement of Relevant Facts :

Petitioner is an investment adviser representative and owner of Otium Financial Planners. Petitioner has been registered as an investment adviser representative since 2005 and is currently registered in the State of Ohio.

Petitioner resides in Florida on a recurring seasonal basis for approximately five months each year. During these periods, Petitioner seeks to continue servicing clients through remote communications, including telephone and videoconference.

Petitioner does not maintain a physical office in Florida. Advisory activities are conducted in accordance with applicable fiduciary obligations, supervisory procedures, and firm compliance policies.

Petitioner's firm services approximately 350 households and manages over $115 million in client assets. The client base is predominantly located outside the State of Florida.

This request is based on Petitioner's current business model, under which advisory services are provided primarily to clients located outside Florida without the operation of a Florida place of business.

KESTRAFINANCIAL.COM

EXHIBIT A
V.18.t

FINAL ORDER EXHIBIT I

Substantial Hardship or Violation of Principles of Fairness

Strict application of Rule 69W-600.0024(6)(b) would impose a substantial hardship on the Petitioner.

Petitioner is responsible for longstanding client relationships. Restricting advisory activity during periods of temporary residence in Florida would disrupt client service, impair fulfillment of fiduciary obligations, and interfere with ongoing account monitoring and financial planning activities.

The resulting impact would extend to both clients and firm operations. The hardship is substantive and directly affects continuity of advisory services.

Statement Demonstrating Consistency with the Purpose of the Underlying Statute

Granting the requested waiver would be consistent with the purposes of Chapter 517, Florida Statutes, including investor protection and the regulation of advisory activity.

Petitioner's activities remain subject to fiduciary obligations, firm compliance controls, and supervisory oversight. The request does not alter the regulatory framework applicable to Petitioner's advisory activities.

Granting the waiver would not be contrary to the public interest and would support continuity of client service.

Duration of Waiver Requested

Petitioner requests a permanent waiver, based on an ongoing pattern of seasonal residence in Florida and continued operation of an advisory business serving primarily non-Florida clients without maintaining a Florida place of business.

This request is based on the facts presented herein. Any material change in Petitioner's business activities may require further review or additional regulatory relief.

Conclusion

Petitioner respectfully requests that the Florida Office of Financial Regulation grant a waiver of Rule 69W- 600.0024(6)(b), F.A.C., on the basis set forth above.

Signature
Kip A. Hoover
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KESTRAFINANCIAL.COM
Kestra Financial, Inc is the parent company of Kestra Investment Services, LLC member FINRA/SIPC and Kestra Advisory Services, LLC

EXHIBIT A

FINAL ORDER EXHIBIT II

From:
To:
White Ryann
"registration@kestrafinancial.com"
Subject:
SERVICE OF DOCUMENT: OFR LEGAL CASE NO. 137379-SR; In Re: Kip A. Hoover, Petition for Waiver from Rule 69W-600.0024(6)(b), F.A.C.
Date:
Tuesday, September 8, 2026 2:35:00 PM
Attachments:
ENV - NOID+EXHIBIT - 137379-SR - KIP A HOOVER.pdf image001.png image002.png image003.png image004.png image005.png

Good afternoon,

Please find attached Notice of Intent to Enter a Final Order Denying Hoover's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code & Notice of Rights issued today via U.S. mail in the above-referenced matter.

STATE OF FLORIDA
OFFIC'E OF FINANCIAL REGULATION
KIP A. HOOVER Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, Petitioner.
Case Number: 137379-SR
NOTICE OF INTENT TO ENTER A FINAL ORDER DENYING HOOVER'S PETITION FOR WAIVER FROM RULE 69W-600.0024(6)(b), FLORIDA ADMINISTRATIVE 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!
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OFFICE OF FINANCIAL REGULATION

Please note that pursuant to chapter 119, Florida Statutes, correspondence with the Office of

FINAL ORDER EXHIBIT II

Financial Regulation is considered public record. This correspondence is available to the public upon request unless exempt from disclosure.