Final Order — Loan Originator

Index: OFR 2026 - 246
KETEO '
/2026
GAL
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
JASON HALSTEAD, Case Number: 132539
Petitioner.
FINAL ORDER
This cause came on for consideration and final agency action. Upon review of the complete record in this case, including the attached Amended Recommended Order, and being otherwise fully advised in the premises, the Office of Financial Regulation ("Office") hereby finds:
I . The Office has jurisdiction over the subject matter of this case and the parties hereto.
2. The entry of this Final Order shall conclude the above-matter.
IT IS ACCORDINGLY ORDERED:
A. The attached Amended Recommended Order is hereby adopted by the Office and incorporated by reference as if fully stated herein. B. Petitioner's application for a loan originator license is hereby DENIED. DONE and ORDERED this JY t~ day of May. 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:
Bv Mail or Email
Agency Clerk
Office of Financial Regulation
P.O. Box 8050
Tallahassee, Florida 32314-8050
Phone: (850) 410-9889
Agency .Clerk@flofr.gov
OR By Hand Delivery
Agency Clerk
Office of Financial Regulation
General Counsel's Office
The Fletcher Building
101 East Gaines Street, Suite 504
Tallahassee, Florida 32399
Phone: (850) 410-9889
A COPY OF THE NOTICE OF APPEAL, ACCOMPANIED BY THE FILING FEES AS REQUIRED BY LAW, MUST ALSO BE FILED WITH THE DISTRICT COURT OF APPEAL, FIRST DISTRICT, 2000 DRAYTON DRIVE, TALLAHASSEE, FLORIDA 32399-0950, OR WITH THE DISTRICT COURT OF APPEAL IN THE APPELLATE DISTRICT WHERE THE PARTY RESIDES. THE NOTICE OF APPEAL MUST BE FILED WITH BOTH THE 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. 2

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order was furnished via electronic mail to Petitioner, Jason Halstead at nmls@halsteadlandkom.com, on this I ~f;l. day of May, 2026. 3 al Regulation X 8050 e, FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
Case Num her: 132539
JASON HALSTEAD,
Petitioner.
AMENDED RECOMMENDED ORDER
Pursuant to notice, a hearing in this case was conducted on March 12, 2026 via video teleconference pursuant to sections 120.569 and 120.57(2), Florida Statutes, before Miriam S. Wilkinson, a duly designated Hearing Officer with the Florida Office of Financial Regulation ("Office"). For the Office:
For Petitioner:
APPEARANCES
Joaquin Alvarez, Esquire
Office of Financial Regulation
200 E. Gaines Street
Tallahassee, FL 32399-0376
Jason Halstead
STATEMENT OF THE ISSUE
Whether grounds exist to deny Petitioner's application for a mo1tgage loan originator license based on the allegations contained in the Notice oflntent to Deny issued by the Office on July 2, 2025. PRELIMINARY STATEMENT On August 7, 2025, Petitioner, Jason Halstead, filed an application with the Office of Financial Regulation ("the Office") for a mortgage loan originator license. On October 27, 2025, 1

the Office issued a Notice oflntent to Deny and Notice of Rights ("Notice") to Petitioner. Petitioner timely submitted a request for an administrative hearing pursuant to section 120.57(2), Florida Statutes, admitting the material factual allegations in the Notice but disputing the proposed penalty. By Order dated January 7, 2026, the Office granted Petitioner a proceeding in this matter pursuant to section 120.57(2), Florida Statutes, and appointed the undersigned as the Hearing Officer. On January 15, 2026, the undersigned Hearing Officer issued a "Notice of Video Telecon~erence Hearing," and a final hearing was held on March 12, 2026. The Office cal1ed one witness, Bill Morin, Chief, Bureau of Registrations, Division of Consumer Finance. The following exhibits offered by the Office were admitted into evidence at the hearing:
Office's Exhibit 1: Mortgage Loan Originator License Application of Jason Halstead filed August 4, 2025 Office's Exhibit 2: Records Received from Jason Halstead Office's Exhibit 3: Certified Court Records in State of Florida vs. Jason Shaun Halstead, Case 53-2014-CF-005596-A000-XX (Polk County) Office's Exhibit 4: Certified Court Records in State of Florida vs. Jason Shaun Halstead, Case 1997-CF-009187-A-O (Orange County) Petitioner called no witnesses, but offered six exhibits which were admitted into evidence, and testified on his own behalf:
Petitioner's Exhibit 1: Certified Court Records Petitioner's Exhibit 2: Halstead Statement Letter Petitioner's Exhibit 3: Professional License Jnfonnation; Earned Designations and Certifications Petitioner's Exhibit 4: Character References from Past Clients Petitioner's Exhibit 5: Character References from Past Employers Petitioner's Exhibit 6: Character References from Friends, Family, & Community The undersigned took official recognition of chapter 494, Florida Statutes, and Florida Administrative Code Rule chapter 69V-40. At the conclusion of the hearing, the parties were advised they could submit proposed recommended orders, which would be due no later than 10 days from the date the Notice of Filing 2

Transcript is received by the Office. The one-volume hearing transcript was filed with the Office's Agency Clerk on March 27, 2026. The Office filed its proposed recommended order on April 6,
2026. Petitioner did not file a proposed recommended order.
FINDINGS OF FACT
l. On August 7, 2025, Jason Halstead submitted an application for licensure as a
mortgage loan originator.
2. During the application process, the Office received documents from Petitioner
evidencing that, on February 4, 1998, in case number CR-O-97-9187/A, in the Circuit Court of the Ninth Judicial Circuit, in and for Orange County, Florida, Mr. Halstead pied Guilty to and was Adjudicated Guilty of Aggravated Assault with a Deadly Weapon, a felony crime, and Improper Exhibition of a Dangerous Weapon or Fireann, a misdemeanor crime ..
3. Mr. Halstead additionally provided documentation to the Office evidencing that on
September 2, 2014, in case number 2014CF-005596-A000-XX, in the Circuit/County Court in and for Polk County, Florida, he pied Guilty to Petit Theft, a misdemeanor crime.
4. Mr. Halstead has not received a pardon or had his civil rights restored.
5. Bill Morin has been the Chief of the Bureau of Registrations since 2018, and is
responsible for overseeing the application review and approval process for the Office's Division of Consumer Finance.
6. For those license applicants with criminal histories, Mr. Morin and his staff review
the criminal history background materials provided by an applicant to determine his or her eligibility for licensure under Florida law.
7. Rule 69V-40.00l 12(3), Florida Administrative Code, classifies felony crimes into
three categories: "A," "B," and "C," and classifies misdemeanor crimes as Class "D." For a Class 3

"A" crime, the applicant is permanently ineligible for Iicensure with the Office. For a Class "B" crime, the applicant will not be granted a license until the expiration of a 15-year disqualifying period. For a Class "C" crime, the applicant will not be granted a license until the expiration of a 7-year disqualifying period. For a Class "D" crime, the applicant will not be granted a license until the expiration of a 5-year disqualifying period.
8. Pursuant to Rule 69V-40.00112(4)(a), Florida Administrative Code, an applicant
whose law enforcement record includes multiple class crimes requires a longer disqualification period. The total disqualification period for an applicant is calculated from the "trigger date," which is the disposition date of the most recent crime.
9. According to Mr. Morin, the Office evaluated both crimes and determined that the
1998 felony was a Class B crime that carried a 15-year disqualifying period, and the 2014 misdemeanor was an "additional crime" under the multiple crimes rule, which carried a 5-year disqualifying period. The Office concluded that Mr. Halstead is subject to a 20-year disqualifying period and is therefore not eligible for licensure as a mortgage loan originator until 2034.
10. Rule 69V-40.00 l 12(5), Florida Administrative Code, provides a list of mitigating
factors that can be applied to reduce the disqualifying period, as follows:
(a) The disqualifying period for a Class "B" crime shall be shortened upon proof of one or more of the following factors. When more than one factor is present the applicant is entitled to add together all of the applicable mitigation amounts and deduct that total from the usual disqualifying period, provided that an applicant shall not be permitted an aggregate mitigation of more than three (3) years for the following factors:

1. One year is deducted if the probation officer or prosecuting attorney in
   the most recent crime states in a signed writing that the probation officer or prosecuting attorney believes the relevant person would pose no significant threat to public welfare if the applicant is licensed as a loan originator, mortgage broker, or mortgage lender.
2. One year is deducted if restitution or settlement has been made for all
   crimes in which restitution or settlement was ordered by the court, and proof 4

of such restitution or settlement is shown in official court documents or as verified in a signed writing by the prosecuting attorney or probation officer.
3. One year will be deducted if the relevant person was under age 21 when
the crime was committed and there is only one crime in the relevant person's law enforcement record.
4. One year is deducted if the applicant furnishes proof that the relevant
person was at the time of the crime addicted to drugs or suffering active alcoholism. The proof must be accompanied by a written letter from a properly licensed doctor, psychologist, or therapist licensed by a duly constituted state licensing body stating that the licensed person has examined or treated the applicant and that in his or her professional opinion the addiction or alcoholism is currently in remission and has been in remission for the previous 12 months. The professional opinion shall be dated within 45 days of the time of application.
5. Other Mitigating Factors. An applicant is permitted to submit any other
evidence of facts that the applicant believes should decrease the disqualifying period before licensure is allowed and one additional year shall be deducted if the Office agrees the facts have a mitigating effect on the licensure decision. (b) The burden is upon the applicant to establish these mitigating factors.
11. In mitigation, Mr. Halstead testified that he accepts responsibility for the two
crimes, one of which was committed when he was 19 years old.
12. Mr. Halstead is currently his own real estate broker, but also works as a meat cutter
for a local meat market. For the previous 8 years he worked as a meat cutter for a different meat market located in Winter Haven, Florida, which was recently sold. He was the only employee in the market's 40-year history to have been provided with a key giving him unlimited access to the store, thereby signifying the trust that the owner placed in him.
13. Mr. Halstead has been licensed since 2008 as a real estate agent, and in 20 I 6 he
became a licensed real estate broker. He takes very seriously his clients' trust that he will responsibly protect his cJient's personal confidential financial information.
14. Mr. Halstead has never received any complaints from his clients. In his exhibits,
Mr. Halstead presented many credible laudatory character references from past and present clients, former employers, and members of his local community, who praised Mr. Halstead as a trustworthy 5

and honest person based on their own experience with him.
15. As a real estate agent, Mr. Halstead has received approximately 10 certifications
from the National Association of Realtors.
16. Mr. Halstead was a volunteer from 2020 to 2023 with On the Water with Veterans,
an organization that coordinated fishing trips for active and inactive military veterans.
17. Based on his excellent character references, the Office conceded at hearing that Mr.
Halstead is entitled to one year of mitigation pursuant to the referenced rule. No proof that Mr. Halstead met the requirements of any of the other mitigating factors was received by the Office, and therefore they were excluded from consideration. CONCLUSIONS OF LAW
18. Pursuant to section 494.0011, Florida Statutes, the Office has jurisdiction over loan
originators and is responsible for the administration and enforcement of chapter 494, Florida Statutes, and the administrative rules promulgated thereunder.
19. In hearings pursuant to section 120.57(2), Florida Statutes, where, by definition,
there are no disputed issues of material fact, only conclusions oflaw arc to be drawn as to whether the facts support the agency's intended decision. Dep't of Banking & Fin. v. Osborne Stern & Co., 670 So. 2d 932, 934 (Fla. 1996).
20. The general rule is that a party asserting the affirmative of an issue has the burden
of presenting evidence as to that issue. McGrm1' v. Department o,fState Div. o,fLicensing, 491 So. 2d 1193, 1 195 (Fla. 1st DCA 1986).
21. As the applicant seeking licensure, Mr. Halstead bears the burden of proving
entitlement to the license by a preponderance of the evidence. Dep 't of Banking & Fin. v. Osborne Slern & Co., 670 So. 2d 932, 934 (Fla. 1996)(in a denial of licensure action, the applicant carries 6

the burden of persuasion with respect to his or her fitness for licensure and entitlement to the license).
22. Pursuant to section 494.011(2)(c), Florida Statutes, and Rule 69V-40.00112(1),
Florida Administrative Code, as part of the application process, the Office is required to consider an applicant's law enforcement record when deciding whether to approve an application for licensure.
23. Pursuant to section 494.00255(1)0) and (2)(d), Florida Statutes, the Office may
deny a 1icense to an applicant who was convicted of, or entered a plea of guilty or nolo contendere, regardless of adjudication, to any felony, or, any crime involving fraud, dishonesty, or act of moral turpitude.
24. Rule 69V-40.00112, Florida Administrative Code, tit1ed, "Effect of Law
Enforcement Records on Applications for Loan Originator, Mortgage Broker, and Mortgage Lender Licensure" ("Law Enforcement Rule") was adopted and implemented by the Florida Financial Services Commission in 2010, pursuant to section 494.0011(2)(c), Florida Statutes, which states the Office's responsibilities include:
Establishing time periods during which a loan originator, mortgage broker, or mortgage lender license applicant under part ll or part III is barred from licensure due to prior criminal convictions of, or guilty or nolo contendere pleas by, any of the applicant's control persons, regardless of adjudication.
1. The rules must provide:
a. Permanent bars for felonies involving fraud, dishonesty, breach of trust, or money laundering; b. A 15-year disqualifying period for felonies involving moral turpitude;
c. A 7-year disqualifying period for all other felonies; and
d. A 5-year disqualifying period for misdemeanors involving fraud, dishonesty, or any other act of moral turpitude.

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4. An applicant is not eligible for liccnsure until the expiration of the
disqualifying period set by rule.
7

25. Pursuant to Rule 40.00 l 12(2)(b ), Florida Administrative Code, these classifications
reflect the Office's evaluation of various crimes in terms of moral turpitude and the seriousness of the crime as such factors relate to the prospective threat to public welfare typically posed by a person who would commit such a crime. According to the testimony, buying a home is likely the largest purchase a consumer will make in his or her lifetime. A person operating as a real estate agent and a loan originator is uniquely positioned to access a consumer's personal identifiable infonnation, including financial information such as bank accounts, retirement accounts, social security numbers, and credit bureau infonnation. Consumers place their trust in loan originators, expecting them to operate fairly and honestly, and they trust that the Office has thoroughly appraised an applicant for suitability before granting him or her a license.
26. Under the Law Enforcement Rule, the felony crime of aggravated assault with a
deadly weapon is classified as a Class "B" crime pursuant to Rule 69V-40.00112(14)(d), Florida Administrative Code. Pursuant to Rule 40.00112(3)(b), Florida Administrative Code, an applicant who has committed a Class "B" crime is ineligible for licensure until 15 years have passed from the trigger dale. The misdemeanor crime of Petit Theft is classified as a Class "D" crime pursuant to Rule 69V-40.00112(16), Florida Administrative Code. Pursuant to Rule 40.00112(3)(d), Florida Administrative Code, an applicant who has committed a Class "D" crime is ineligible for licensure until 5 years have passed from the trigger date. Of the two crimes, aggravated assault with a deadly weapon is considered to be the more serious crime committed by the applicant.
27. Rule 69V-40.00112(4) Applicants With Multiple Crimes states:
(a) The Office requires that applications with a relevant person whose law enforcement record includes multiple class "B," "C," or "D," crimes, or any combination thereof, wait longer than those whose law enforcement record includes only a single crime before becoming eligible for licensure in order to assure that such applicant's greater inability or unwillingness to abide by the law has been 8

overcome. Therefore, the Office finds it necessary that a longer disqualifying period be utilized in such instances, before 1icensure can safely be granted. Accordingly, where the relevant person has been found guilty or pled guilty or pled nolo contendere to more than one crime, the Office shall add 5 years to the disqualifying period for each additional crime. (b) The additional periods are added to the disqualifying period for the most serious class "B," "C," or "D," crime, and the combined total disqualifying period then runs from the trigger date of the most recent class ''B," "C," or "D," crime.
28. ln this case, the Office evaluated Mr. Halstead's criminal record and determined
that the 1998 felony is a Class "B" crime mandating a 15-year disqualifying period. Applying the rule in (4)(b), above, the combined total disqualifying period is 15 years for this felony (the more serious crime), plus 5 years for the commission of multiple crimes, i.e., committing one additional crime (the 2014 petit theft). ln calculating the combined total disqualification period in this case, the petit theft crime is considered only for its status (1) as an additional crime; and (2) in providing a trigger date for the total combined disqualification period.
29. Pursuant to rule, the total combined disqualification period of 20 years must run
from the disposition date of the most recent crime, which was in 2014. The Office concluded that Mr. Halstead is therefore not eligible for licensure as a mortgage loan originator until 2034. However, based on his excellent character references, the Office conceded at hearing that Mr. Halstead is entitled to one year of mitigation pursuant to the referenced rule, which reduces the disqualification period to 19 years.
30. Mr. Halstead offered credible testimony and numerous laudatory character
references from clients, employers, and members of his community which, in the opinion of the undersigned Hearing Officer, amply demonstrate his good moral character and fitness to hold a mortgage loan originator license. However, because of the mandatory and highly restrictive nature of the laws and rules governing licensure of mortgage loan originators, the undersigned has no discretion under current Florida law to recommend approval of Mr. Halstead's mortgage loan 9

originator license application.
31. No proof that Mr. Halstead met the requirements of any of the other mitigating
factors was received by the Office, and therefore they were excluded from consideration. Pursuant to Florida law, applying one mitigating factor, Mr. Halstead is currently subject to a 19-year disqualifying period, beginning on September 2, 2014 and ending on September 2, 2033. RECOMMENDATION Based on the foregoing Findings of Fact and Conclusions of Law, it is recommended that the Office of Financial Regulation enter a Final Order DENYING Jason Halstead's application for a mortgage loan originator license. Respectfully submitted this 5th day of May 2026, in Tallahassee, Leon County, Florida. Mir/,Am,,S. W ~ MIRIAM S. WILKINSON Hearing Officer Office of Financial Regulation 200 E. Gaines Street Tallahassee, FL 32399-0370 [Remainder of this page intentionally left blank]

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Amended Recommended Order has been furnished via electronic mail to Jason Halstead at 5+~ NMLS@halsteadlandkom.com on this __ day of May, 2026. Cc: Joaquin Alvarez, Asst General Counsel Office of Financial Regulation 11 ~ I Regulation 50 Tallahassee, FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889