Final Order — Douglas William Finley, Case Number 139835-SR

Index: OFR 2026 - 475
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
DOUGLAS WILLIAM FINLEY, Case Number: 139835-SR Respondent.
FINAL ORDER
The State of Florida, Office of Financial Regulation ("Office"), and Respondent Douglas William Finley ("Finley"), having entered into the attached Stipulation and Consent Agreement ("Agreement"), resolving and concluding this matter, it is therefore ORDERED:

1. The Agreement entered into by the Office and Finley is adopted and incorporated
   by reference herein as if set forth at length.
2. The parties shall comply with all provisions of the incorporated Agreement.
   DONE and ORDERED this z~ day of September, 2026, in Tallahassee, Leon County, Florida.

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished via electronic mail to Clinton Edgar, Esq., and Ronak Patel, Esq., attorneys for Douglas William Finley, at cedgar@bressler.com and rpatel@bressler.com on this -(_84'111.. day of September, 2026. egu ation 32314-8050 cy.Clerk@flofr.gov 410-9889

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
DOUGLAS WILLIAM FINLEY, Case Number: 139835-SR Respondent.
STIPULATION AND CONSENT AGREEMENT
The State of Florida, Office of Financial Regulation ("Office"), and Respondent Douglas William Finley ("Finley"), in consideration of the mutual promises herein, recite, stipulate, and agree, on the last date executed below, as follows:

1. Background: On February 19, 2026, the Office received an application, via Form
   U4, Uniform Application for Securities Industry Registration, through the Central Registration Depository ("CRD"), for Finley's registration with the Office as an associated person of AA Financial Advisors, LLC d/b/a Antolino Wealth Advisors ("AAFA"), a federal covered adviser. Finley's CRD number is 3039094. Following the receipt of Finley's application for registration, the Office sent a letter to Finely in which it requested documentation regarding, among other things, possible unregistered investment advisory business activity. On May 30, 2026, the Office received Finley's written statement that indicated Finley had rendered investment advice in Florida between January 2025 and December 2025 on behalf of Finley Wealth Management, LLC d/b/a Finley Wealth Advisors ("FWM"), a federal covered adviser, without being registered with the Office as an associated person of FWM. Prior to this period, Finley was registered with the Office as an associated person ofFWM from May 2007 through January 2025.

Finley maintains that the lapse in registration resulted from an administrative cancellation that occurred when his prior employer, FWM, transitioned from Florida registration to United States Securities and Exchange Commission ("SEC") registration, and that Finley did not intend to withdraw or terminate his investment advisor representative registration. Finley further maintains that he became seriously ill throughout 2025. Finley maintains that these unusual circumstances played a central role in the fact that Finley was not properly registered during 2025 with the Office as an associated person of FWM. The Office notes that while application filings with the Office through CRD are made by the associated person's employing firm, section 517.12(3), Florida Statutes (2024), imposes the registration obligation on the associated person, and an associated person cannot provide investment advice in or from Florida until appropriately registered with the Office.
2. Jurisdiction: The Office is the state agency charged with the administration and
enforcement of chapter 517, Florida Statutes, and the rules promulgated thereunder. The Office has jurisdiction to initiate an Administrative Complaint against Finley pursuant to chapter 517, Florida Statutes, as stipulated by Finley.
3. Findings: Finley neither admits nor denies the allegations but consents to the entry
of findings by the Office. The Office finds that Finley violated section 517.12(3), Florida Statutes (2024), by rendering investment advice, from a location within Florida, without being properly registered with the Office as an associated person of FWM.
4. Consideration: The parties agree that the issues raised in this proceeding can be
expeditiously resolved prior to the filing of an Administrative Complaint by their execution of this Stipulation and Consent Agreement. The parties acknowledge that they have read this Stipulation and Consent Agreement and fully understand the rights, obligations, terms, duties, and

responsibilities with respect to its contents. Therefore, in compromise and settlement of this matter and in consideration of the Office's forbearance from further litigation, the parties agree as follows:
a. Finley agrees to Cease and Desist from violations of section 517.12(3), Florida Statutes, and the Administrative Rules adopted thereto. b. Finley agrees to an imposition of an administrative fine against Finely in the amount of FIVE THOUSAND DOLLARS ($5,000.00). The administrative fine shall be submitted in the form of a certified check or money order made payable to the "Office o[ Financial Regulation" and sent to Agency Clerk, c/o Douglas M. Holcomb, Office of Financial Regulation, P.O. Box 8050, Tallahassee, FL 32314-8050, or paid by wire transfer. Finley agrees that this administrative fine shall be collected and deposited in accordance with section 215 .31, Florida Statutes. Finley agrees, regarding the deposit of monies, that (1) the tendered fine or settlement check proceeds may be deposited in advance of full execution or acceptance of the proposed settlement agreement and (2) such deposit shall not be construed as a final acceptance of the Stipulation and Consent Agreement absent full execution thereof and entry of the Final Order adopting same.
c. The Office agrees to approve Finley's pending application for registration
as an associated person of AAF A. Approval shall be granted upon receipt of the required administrative fine payment and entry of the Final Order adopting this Stipulation and Consent Agreement. In the event the Office discovers any additional adverse information concerning the pending application prior to entry of the Final Order, the Office reserves all legal rights and authority to take any action on the pending application as may be appropriate. Such action may include, but is not limited to, issuing an Administrative Complaint based on the violations cited above.

5. Final Order: Finley consents to the issuance by the Office of a Final Order, which
   incorporates the terms of this Stipulation and Consent Agreement. Finley understands and agrees that this Stipulation and Consent Agreement is subject to the final approval of the Commissioner of the Office of Financial Regulation and the entry of the Final Order adopting this Stipulation and Consent Agreement. In the event the Final Order is not entered, this Stipulation and Consent Agreement shall be null and void. The Final Order incorporating this Stipulation and Consent Agreement constitutes final agency action by the Office for which the Office may seek enforcement pursuant to the provisions of chapters 120 and 517, Florida Statutes.

6. Consent and Waiver: By Finley's consent to the entry of the Final Order with
   respect to this proceeding, Finley knowingly and voluntarily waives:
   a. Any right to receive further notice of this administrative action and notice of rights pursuant to chapter 120, Florida Statutes; b. Any right to an administrative hearing provided by chapter 120, Florida Statutes;
   c. Any requirement that the Office's Final Order contain separately stated
   findings of Fact and Conclusions of Law or a Notice of Rights; d. Any right to issuance of a recommended order by an Administrative Law Judge from the Division of Administrative Hearings or a Hearing Officer from the Office; and e. Any right to object to or challenge in any judicial proceeding including, but not limited to, an appeal pursuant to section 120.68, Florida Statutes, any term, condition, obligation, or duty expressly created by the Final Order.

7. Releases: Upon full execution of this Stipulation and Consent Agreement, Finley
   waives and releases the Office and its agents, representatives, and employees from any and all causes of action that Finley may have arising from or relating to the subject matter hereof. The Office agrees to accept this release on behalf of itself and its agents, representatives, and employees without acknowledging and expressly denying that any such cause or causes of action may exist.

8. Future Actions: This Stipulation and Consent Agreement is being executed solely
   for the purpose ofresolving and settling the instant proceeding. Nothing herein shall be construed to waive or restrict the Office's right in a future proceeding to undertake any administrative action under the provisions of chapter 517, Florida Statutes, or any civil or criminal prosecution, arising out of any facts or circumstances undisclosed or undiscovered at the time of the entry of the Final Order; or facts unrelated to this settlement should further information warrant such action.

9. Failure to Complv: Finley acknowledges, concurs, and stipulates that Finley's
   failure to comply with any of the terms, obligations and conditions of this Stipulation and Consent Agreement, and the Final Order adopting it, violates this written agreement and the Final Order entered pursuant to chapters 120 and 517, Florida Statutes. Such non-compliance may result in the issuance of an emergency Cease and Desist Order.

10. Attornevs' Fees: Each party herein shall be solely responsible for its attorneys'
    fees and costs incurred up to and including entry of the Final Order in this matter.

11. Severability: Finley agrees that if any provision of this Stipulation and Consent
    Agreement or the application thereof to any person or circumstance is held to be invalid, the invalidity shall not affect the remaining provisions of the Stipulation and Consent Agreement or the Final Order adopting it, which shall be given effect without the invalid provision(s), and to this end, the provisions of this Stipulation and Consent Agreement are severable.

12. Entire Agreement: This Stipulation and Consent Agreement represents the entire
    agreement by and between the Office and Finley. Any alterations, variations, changes, modifications, or waivers of the provisions hereof shall be valid only when they have been reduced to writing, duly signed by the Office and Finley, and attached to the original of this Stipulation and Consent Agreement. WHEREFORE, the undersigned parties hereby acknowledge and agree to the terms and conditions of the foregoing Stipulation and Consent Agreement, subject to final approval by the Commissioner of the Office of Financial Regulation, by written consent on the last date executed below:
    DOUGLAS WILLIAM FINLEY
    Douglas William Finley
    STATE OF~~ A) Virginia
    COUNTY 0 ~ Ashburn
    09/22/2026
    Date
    BEFORE ME, the undersigned authority, appeared Douglas William Finley, by means of

• physical presence or ~ online notarization, who, upon being duly sworn, states that he has read
  and understands the foregoing agreement and voluntarily signed the same.
  SWORN TO AND SUBSCRIBED before me this 22nd day of September , 2026.
  12#1?-J
  NOTARY PUBLIC Winstead Barnes Jr.
  My Commission expires: 07/31/2028
  Personally known ___ or produced identification ✓ __ Type of identification produced: Driver's License OFFICE OF FINANCIAL REGULATION 9/28/26 Date Director Division of Securities 003Je2N COMMMIONUPIR[S Juty~1, 20Z:I Notarized remotely online using communication technology via Proof.