Final Order Denying Leah Hadley's Petition for Waiver from Rule 69W-600.0024(6)(b)

Index: OFR 2026 - 329
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
LEAH HADLEY, Petition for Waiver from
Rule 69W-600.0024(6)(b), Florida
Administrative Code,
Case Number: 135132-SR
Petitioner.
FINAL ORDER DENYING HADLEY'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 January 31, 2026, by Leah Hadley ("Petitioner"). Pursuant to section 120.542(8), Florida Statutes, the Office enters this Final Order Denying Hadley'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 April 29, 2026, the Office issued a Notice of Intent to Enter a Final Order
   Denying Hadley'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 oflntent gave notice of the Office's intent to enter a Final Order Denying Hadley's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, as Hadley 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
   Hadley that she 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 Hadley on April 29, 2026, via USPS mail.

4. The Notice of Intent was sent to Hadley via email to her firm on April 29, 2026.
   The email is attached hereto as Exhibit II.

5. Hadley's response to the Notice of Intent was to be filed with the Office on or
   before May 20, 2026. As of the date of this Final Order, Hadley 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 Hadley, 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 Hadley 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. Hadley'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 Hadley's right to an administrative hearing. See Rule 28-106.111(4), Fla. Admin. Code.
11. Hadley has not alleged any basis for equitable tolling. See Patz v. Dep 't of Health,
Fla. Bd. Of Med., 864 So. 2d 79 (Fla. 3dDCA 2003).
12. The legal conclusions that form the basis for the denial of Hadley's Petition for
Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, set forth in the Notice of Intent, being uncontested by Hadley, 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:
Hadley's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, is hereby DENIED. DONE and ORDERED this I c,1,- 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 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 t ~~ ay of July, 2026, a true and correct copy of the foregoing has been furnished by U.S. mail and email to the following:
Leah Hadley
Intentional Wealth Partners
7017 Pearl Rd., Ste 12
Cleveland, OH 44130 leah@intentionalwealthpartners.co 5
• Regulation
50
314-8050 erk@flofr.gov
Tel: (850) 410-9889

FINAL ORDER EXHIBIT I
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
LEAH HADLEY, Petition for Waiver from
Rule 69W-600.0024(6)(b), Florida
Administrative Code,
Petitioner.
Case Number: 135132-SR
NOTICE OF INTENT TO ENTER A FINAL ORDER DENYING HADLEY'S PETITION FOR WAIVER FROM RULE 69W-600.0024C6Hbl, 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 January 31, 2026, by Leah Hadley ("Petitioner"), Central Registration Depository ("CRD") Number 5119724. Section 120.542(8), Florida Statutes, provides that an order granting or denying a petition for variance or waiver "sha11 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 Hadley's Petition for waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code. STATEMENT OF FACTS

1. On January 31, 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 (SIE) Examination. The following applicants will be considered to have passed the SIB 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 I, 2018, and who continue to maintain those registrations on or after October I, 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

FINAL ORDER EXHIBIT I
2.a. App1icants 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:
1. Certified Financial Planner (TM) or (CFP®) awarded by the Certified
Financial Planner Board of Standards, Inc.;
2. Chartered Financial Consultant (ChFC) awarded by the American
College of Financial Services;
3. Personal Financial Specialist (PFS) awarded by the American Institute of
Certified Public Accountants;
4. Chartered Financial Analyst (CFA) awarded by the CFA Institute; or
5. Certified Investment Management Analyst (CIMA) awarded by the
Investment & Wealth Institute.
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. 51 7 .120 I 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. 3

FINAL ORDER 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. 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, which requires certain associated person of investment advisers to pass the Series 65 examination." b. The Petition states that Petitioner "is an experienced investment adviser and fiduciary with extensive professional credentials and industry experience."
c. The Petition states that "Petitioner holds multiple advanced professional
designations, including Accredited Financial Counselor (AFC®); Certified Divorce 4

FINAL ORDER EXHIBIT I
Financial Analyst (CDFA®); and [a]dditional mediation and financial counseling credentials focused on complex financial decision-making and fiduciary responsibility." d. The Petition states that Petitioner "has been continuously engaged in financial planning, investment advisory work, and fiduciary client service of a significant period of time and has demonstrated ongoing competence in: [i]nvestment principles, [p ]ortfolio construction, [r ]isk management, [ c ]lient suitability analysis, [ and] [ e ]thical and fiduciary standards." e. The Petition states that Petitioner "has provided investment advisory and fiduciary planning services for more than a decade." f. The Petition states that "[t]he knowledge and competencies assessed by the Series 65 examination are already demonstrated through Petitioner's education, credentials, professional experience, and ongoing fiduciary practice." g. The Petition states that "Petitioner has no history of disciplinary action, investor complaints, or regulatory sanctions." h. The Office notes that Petitioner passed the Series 66 exam on May I 0, 2008. Petitioner was registered as an associated person of a federal covered adviser from May 12, 2008, through July 3, 2008, and then was not registered again as an associated person of a federal covered adviser until July 10, 2012, after receiving an exam waiver from the State of Ohio. This 4 year gap in registration exceeds the two-year window for affiliation with an investment adviser or federal covered adviser permitted under Rule 69W￾600.0024( 6)( c ), Florida Administrative Code, and is the reason for the expiration of Petitioner's Series 66 exam results. 5

FINAL ORDER EX HIBIT I
1. The Petition states that Rule 69W-600.0024(6)(b), Florida Administrative
Code, creates a "legal and professional hardship ... as it imposes a duplicative licensing requirement despite demonstrated competence and ongoing regulatory oversight." j. The Petition states that the application of Rule 69W-600.0024(6)(b ), Florida Administrative Code, violates principles of fairness "because Petitioner is similarly situated to other investment advisers who have been granted waivers based on experience, credentials, and demonstrated competency" and the "literal application of the rule affects Petitioner in a manner significantly different from similarly situated professionals whose qualifications have been deemed sufficient to satisfy the underlying statutory purpose without examination." k. The Petition states that "[g]ranting this waiver serves that purpose because:
[p]etitioner is already subject to comprehensive regulatory oversight, [p]etitioner operates under a fiduciary standard, [p]etitioner's education, credentials, and experience ensure competence equivalent to or exceeding that tested by the Series 65 examination, [i]nvestor protection is fully achieved through existing regulatory and professional safeguards," and "[g]ranting the requested waiver would not diminish investor protection and would remain consistent with the legislative intent of Chapter 517, Florida Statutes."
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 22, published February 3, 2026.
9. The Office did not receive any comments on the Petition.
6

FINAL ORDER EXHIBIT I
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 on a petition for a 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. 7

FINAL ORDER EX HIBIT I
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); (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 fo1lowing 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 summarily states that the "purpose of section 517 .12, Florida Statutes, is the protection of investors through the regulation of investment advisers and associated persons" but does not explain how the purpose of the underlying statute will be achieved by a waiver of the knowledge and time-frame requirements imposed by Rule 69W￾600.0024(6)(b ), Florida Administrative Code. Additionally, the Petition summari1y states 8

FINAL ORDER EXHIBIT I that "Petitioner's education, credentials, and experience ensure competence equivalent to or exceeding that tested by the Series 65 examination" without further explanation or comparison as to how these facts relate to the topics covered by the Series 65 examination. The Petition further states Petitioner is already subject to comprehensive oversight and that Petitioner operates under a fiduciary standard. The fact that Petitioner received an exam waiver and has been registered in another jurisdiction, is 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. 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 Rule 69W-600.0024(6)(b), Florida Administrative Code, would create a "legal and professional hardship" and that it "imposes a duplicative licensing requirement despite demonstrated competence and ongoing regulatory oversight." However, the Petition neither provides specific details about the "legal and professional 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 Petition states that requiring Petitioner to satisfy the examination 9

FINAL ORDER EX HIBIT I requirements will violate principles of fairness because Petitioner, with Petitioner's "experience, credentials, and demonstrated competency," is akin to other applicants who hold certain professional designations and do not have to satisfy the exam requirements of Rule 69W-600.0024(6)(b), Florida Administrative Code. However, the Petition neither explains how Petitioner is affected differently from similarly situated applicants who lack a professional designation specified in the Rule nor does it explain the requirements of any professional designation specified in the Rule or compare Petitioner's "experience, credentials, and demonstrated competency" to such requirements. The Office finds that Petitioner is in no different position relative to retaking the Series 66 exam or taking the Series 65 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 Hadley's Petition for Waiver from Rule 69W-600.0024(6)(b), Florida Administrative Code, subject only to the Notice of Rights contained herein. Dated: 4-/21/21)26 10 ,<1JUt,, l/tZAM4-tf~ A'~ .F""~ 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:
Bv 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: Auency .Clerkriiiflofr.!!ov
OR Bv Hand Deliverv
Agency Clerk
Office of Financial Regulation
Office of General Counsel
The Fletcher Building
IO I 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 Tms 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 nm OFFICE'S PROPOSED AGENCY ACTION WlLL 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 HA VE SUBPOENAS AND SUBPOENAS DUCES TECUM ISSUED ON YOUR BEHALF. PURSUANT TO SECTION 120.573, FLORIDA STATUTES, MEDIATION IS NOT AVAILABLE. 11

FINAL ORDER EXHIBIT I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 29th day of April, 2026, a true and correct copy of the foregoing has been furnished by U.S. mail and email to the following:
Leah Hadley
Intentional Wealth Partners
7017 Pearl Rd., Ste 12
Cleveland, OH 44130 leah@intentionalwealthpartners.co 12 R_ ann 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

FINAL ORDER EXHIBIT I
PETITION FOR WAIVER OF RULE 69W-600.0024(6)(b), FLORIDA ADMINISTRATIVE CODE Petitioner:
Leah Hadley
7017 Pearl Rd, Ste 12
Cleveland, OH 44130
Email: lea h@intentionalwealthpartners.co
Phone: 440.545.1001
Petitioner is not represented by legal counsel.
I. RULE FROM WHICH WAIVER IS REQUESTED
Petitioner respectfully requests a permanent waiver of Rule 69W-600.0024{6)(b), Florida Administrative Code, which requires certain associated persons of investment advisers to pass the Series 65 examination.
II. STATUTE IMPLEMENTED BY THE RULE
Rule 69W-600.0024(6)(b), Florida Administrative Code, implements Section 517.12, Florida Statutes, governing the registration and regulation of investment advisers and associated persons.
Ill. TYPE OF ACTION REQUESTED
Petitioner requests a permanent waiver of the Series 65 examination requirement under Rule 69W-600.0024(6)(b), Florida Administrative Code.
IV. STATEMENT OF FACTS

1. Petitioner, Leah Hadley, is an experienced investment adviser and fiduciary with
   extensive professional credentials and industry experience.
2. Petitioner is the founder and principal of Intentional Wealth Partners, an investment
   advisory firm providing comprehensive financial planning and investment advisory services to clients.
3. Petitioner holds multiple advanced professional designations, including:
   o Accredited Financial Counselor (AFC®) o Certified Divorce Financial Analyst (CDFA®) o Additional mediation and financial counseling credentials focused on complex financial decision-making and fiduciary responsibility E}!HIBIT A

FINAL ORDER EXHIBIT I
4. Petitioner has been continuously engaged in financial planning, investment advisory
work, and fiduciary client service for a significant period of time and has demonstrated ongoing competence in:
o Investment principles o Portfolio construction o Risk management o Client suitability analysis o Ethical and fiduciary standards
5. Petitioner has provided investment advisory and fiduciary financial planning
services for more than a decade.
6. Petitioner has no history of disciplinary action, investor complaints, or regulatory
sanctions and has consistently conducted advisory activities in compliance with applicable state and federal securities laws.
7. The knowledge and competencies assessed by the Series 65 examination are
already demonstrated through Petitioner's education, credentials, professional experience, and ongoing fiduciary practice.
V. SUBSTANTIAL HARDSHIP AND PRINCIPLES OF FAIRNESS
A. Substantial Hardship
Strict application of Rule 69W-600.0024(6)(b) in Petitioner's circumstances would create a legal and professional hardship within the meaning of Section 120.542(2), Florida Statutes, as it imposes a duplicative licensing requirement despite demonstrated competence and ongoing regulatory oversight. B. Principles of Fairness Application of the rule in this instance would violate principles of fairness as defined in
Section 120.542(2), Florida Statutes, because Petitioner is similarly situated to other
Investment advisers who have been granted waivers based on experience, credentials, and demonstrated competency. The literal application of the rule affects Petitioner in a manner significantly different from similarly situated professionals whose qualifications have been deemed sufficient to satisfy the underlying statutory purpose without examination.
VI. PURPOSE OF THE UNDERLYING STATUTE
E} HIBIT A

FINAL ORDER EX HIBIT I
The purpose of Section 517.12, Florida Statutes, is the protection of investors through the regulation of investment advisers and associated persons. Granting this waiver fully serves that purpose because:
• Petitioner is already subject to comprehensive regulatory oversight
• Petitioner operates under a fiduciary standard
• Petitioner's education, credentials, and experience ensure competence equivalent
to or exceeding that tested by the Series 65 examination
• Investor protection is fully achieved through existing regulatory and professional
safeguards
Granting the requested waiver would not diminish investor protection and would remain consistent with the legislative intent of Chapter 517, Florida Statutes.
VII. DURATION OF WAIVER
Petitioner requests that the waiver be permanent.
VIII. NOTICE AND SERVICE
A copy of this Petition for Waiver has been provided to:
• The Florida Office of Financial Regulation
• The Joint Administrative Procedures Committee, as required by Rule 28-104.002,
Florida Administrative Code
IX. CONCLUSION
For the reasons stated above, Petitioner respectfully requests that the Office of Financial Regulation grant a permanent waiver of Rule 69W-600.0024(6)(b), Florida Administrative Code, pursuant to Section 120.542, Florida Statutes. Respectfully submitted, u ~ Leah Hadley January 31, 2026 El~HIBIT A

White, Ryann
From:
Sent:
To:
Subject:
Attachments:
Good afternoon,
FINAL ORDER EXHIBIT II
White, Ryann
Wednesday, April 29, 2026 4:40 PM
Lea h@i ntenti onalwealth partners.co
SERVICE OF DOCUMENT: OFR LEGAL CASE NO. 135132-SR; In Re: Leah Hadley, Petition for Waiver from Rule 69W-600.0024{6)(b), F.A.C. ENV - Hadley NOi to Enter FO 4.29.26 Signed.pdf Please find attached Notice oflntent to Enter a Final Order Denying Hadley'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 .
....
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---

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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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.