Final Order — Money Services Business

Index: OF£ -Z.Olio --z1D 7 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: DENISE SORGEN Case Number: 127023 D/B/A CHECK CONSULT ANTS, Respondent. FINAL ORDER This cause came on for consideration and final agency action. Upon review of the record and being otherwise fully advised in the premises, the Office of Financial Regulation ("Office") hereby finds:

1. The Office has jurisdiction over the subject matter of this case and the parties hereto.
2. The entry of this Final Order concludes the above-referenced matter. ORDERED: A. The Stipulation and Consent Agreement (Exhibit A) is hereby approved and incorporated by reference as if fully stated herein and is adopted as the Office's Findings of Fact and Conclusions of Law. B. The parties shall comply with all terms of the Stipulation and Consent Agreement. DONE and ORDERED this 2.-l,...'fl..~ day of May, 2026, in Tallahassee, Leon County, Florida. Commissioner

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished to Denise Sorgen d/b/a Check Consultants, by electronic mail to her Attorney of Record: Colin Roopnarine, Esq. at c.roopnarine@grblawfirm.com on this 2.2J4ay of May, 2026. 2 A~ Office of Financial Regulation Post Office Box 8050 Tallahassee, FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

EXHIBIT A STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: DENISE SORGEN Case Number: 127023 D/B/ A CHECK CONSULT ANTS, Respondent. STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation ("Office"), and DENISE SORGEN d/b/a CHECK CONSULTANTS ("Respondent") in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. Ms. Denise Sorgen ("Sorgen") does business under the fictitious name of Check Consultants. Sorgen is and has been licensed as a Part III Money Services Business pursuant to chapter 560, Florida Statutes, operating as a check casher, holding license number FT30800483. The Office conducted an examination (examination number 123647) to ascertain Respondent's compliance with chapter 560, Florida Statutes, for the period of April 1, 2022 through March 31, 2024. Based on the examination, grounds existed to initiate an administrative proceeding against Respondent pursuant to chapter 560, Florida Statutes, and on May 6, 2025, the Office issued an Administrative Complaint. Respondent submitted a response. The parties are resolving the issues herein with this Stipulation and Consent Agreement in lieu of the Office conducting further proceedings in this matter.

2. Jurisdiction. The Office is the state agency charged with the administration and enforcement of chapter 560, Florida Statutes, and the rules promulgated thereunder. The Office has jurisdiction to bring this administrative action against Respondent pursuant to chapter 560, Florida Statutes.

3. Findings. For the purposes of this Stipulation and Consent Agreement, Respondent consents to the Office's finding that: a. Respondent entered inaccurate information into the Check Cashing Database ("CCDB") or failed to timely enter required information into the CCDB, in violation of section 560.310(2)( d), Florida Statutes; b. Respondent failed to timely submit a Currency Transaction Report to the Financial Crimes Enforcement Network, as required by rule, in violation of section 560.123(3 )( c ), Florida Statutes; c. Respondent failed to maintain complete customer files, in violation of section 560.310(2)(a), Florida Statutes; d. Respondent violated 31 C.F .R. section 1022.210, and thereby section 560.114(1 )(y ), Florida Statutes, by failing to maintain her corporate customer files in violation of its Anti-Money Laundering Program; and, e. Respondent violated section 560.114(1 )(u), Florida Statutes, by failing to pay the examination fee.

4. Terms and Conditions. The parties agree that the issues raised can be expeditiously resolved without further litigation by the 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 the foregoing findings and in consideration of the Office's forbearance from further litigation, Respondent agrees to the following terms and conditions: a. FUTURE COMPLIANCE. Respondent agrees that it shall cease and desist from violations of chapter 560, Florida Statutes, and the corresponding rules, and comply with all the 2

provisions of chapter 560, Florida Statutes, and corresponding rules. b. EXAMINATION FEE. Respondent has not paid the examination fee of Two Thousand Seven Hundred Ninety-Six Dollars and Thirty- Three Cents ($2,796.33). Respondent agrees to pay the outstanding examination fee at the time of the execution and delivery of this Stipulation and Consent Agreement. c. ADMINISTRATIVE FINE. Respondent agrees to pay the Office an administrative fine in the amount of Twenty-Two Thousand Two Hundred and Three Dollars and Sixty-Seven Cents ($22,203.67) to be paid in two installments. The first payment of Eleven Thousand One Hundred and One Dollars and Eighty-Four Cents ($11,101.84) shall be made at the time of the execution and delivery of this Stipulation and Consent Agreement. The second payment of Eleven Thousand One Hundred One Dollars and Eighty-Three Cents ($11,101.83) shall be made within 30 days of the entry of the Final Order adopting this Stipulation and Consent Agreement. This administrative fine shall be submitted in the form of a wire, cashier's check, or money order made payable to "Qffice of Financial Regulation" and shall be sent to the attention of Agency Clerk - c/o Attorney Maria A. Guitian, Post Office Box 8050, Tallahassee, Florida 32314-8050. Respondent acknowledges and agrees that in accordance with section 215 .31, Florida Statutes, regarding the deposit of monies, (i) the tendered fine or settlement check may be deposited in advance of full execution or acceptance of the Stipulation and Consent Agreement; and (ii) such deposit shall not be construed as a final acceptance of the Stipulation and Consent Agreement absent full execution thereof and entry of a Final Order adopting same. 5. Final Order. Respondent consents to the entry of a Final Order, which incorporates the terms of this Stipulation and Consent Agreement. Respondent understands and agrees that this Stipulation and Consent Agreement is subject to the final approval of the Office of 3

Financial Regulation and the entry of the Final Order adopting such Agreement. In the event that 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 action by the Office for which the Office may seek enforcement pursuant to the provisions of chapters 560 and 120, Florida Statutes. 6. Waiver. By Respondent's consent to the entry of a Final Order with respect to this proceeding, Respondent waives: a. Any right to separately stated Findings of Fact and Conclusions of Law; b. Any right to receipt of a Notice of Rights pursuant to chapter 120, Florida Statutes; d. Any right to an administrative hearing or issuance of a Recommended Order pursuant to chapter 120, Florida Statutes; and e. Any right to contest in any administrative forum or judicial proceeding (including, but not limited to, an appeal pursuant to section 120.68, Florida Statutes) the validity of any term, condition, obligation, or duty expressly created in this Stipulation and Consent Agreement and the Final Order. 7. Releases. Upon full execution of this Stipulation and Consent Agreement, Respondent waives, releases, and forever discharges the Office and its agents, representatives, and employees from any and all causes of action, in law or in equity, which Respondent may have arising out of this matter. The Office accepts this release and waiver by Respondent on behalf of itself, its agents, representatives, and employees without acknowledging, and expressly denying, that any such right or cause of action may exist. 8. Failure to Comply. Respondent acknowledges, concurs, and stipulates that Respondent's failure to comply with any of the terms, obligations and conditions of this Stipulation and Consent Agreement, and the Final Order adopting it, is a violation of the written agreement 4

and the Final Order entered pursuant to chapters 120 and 560, Florida Statutes. Such non￾compliance may result in the issuance of an emergency cease and desist order. However, nothing herein shall be construed to limit Respondent's right to contest any finding or determination of non-compliance. 9. Attorney's Fees. Each party herein shall be solely responsible for its separate costs and attorney fees incurred in the prosecution, defense, or negotiations in this matter up to and including the entry of the Final Order adopting this Stipulation and Consent Agreement. 10. Severabilitv. The parties agree that if any provision of this Stipulation and Consent Agreement or the application thereof to any person or circumstance is held invalid, the Stipulation and Consent Agreement will be given effect without the invalid provision, and to this end, the provisions of this Stipulation and Consent Agreement are declared severable. 11. Counterparts. This Stipulation and Consent Agreement may be executed in any number of counterparts, and by the parties in separate counterparts, each of which will be deemed to be an original but all of which together will constitute but one Stipulation and Consent Agreement. Copies of this Stipulation and Consent Agreement transmitted by facsimile or electronic mail shall have the same validity as if bearing an original signature. 12. Entire Agreement. This Stipulation and Consent Agreement represents the entire agreement by and between Respondent and the Office. 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 Respondent hereto, attached to the original of this Stipulation and Consent Agreement, and subject to the approval of the Office. WHEREFORE, in consideration of the foregoing, the Office and Respondent execute this Stipulation and Consent Agreement for entry of a Final Order on the last date executed below. 5

/a CHECK CONSULT ANTS: Date: __ .s-/ _ ~..,./~;;J~O_q,. ,:;, __ State of~ f_L ______ _ 0 ........ ., ,.<,•( Roxana Sierra :"'.\ ~ Notary Pullhc. StRte of Flonaa ~ ~J My Comm,ss,on fap,res 07/25/2027 •,, o, ,~rr CommissiOn No. HH 425801 CoW1ty of Brawa~J Denise Sorgen d/b/a Check Consultants, BEFORE ME by means of D(] physical presence or [ ] online notarization, has sworn (or affirmed) that she has read and understands the foregoing agreement and volW1tarily signed the same. SWORN TO AND SUBSCRIBED before me this .5 day of May, 2026. /2e4-~ Check the appropriate box: Personally known D OR Produced Identification ~ Type of identification produced 00 D □ Driver's License Passport Notary Public Other Fl-i)ravct;s l lc.r"SC. (Do not include ID number) - OFFICE OF FINANCIAL REGULATION Gregory C. Oaks, Director Division of Consumer Finance 6 Date: 5/21/2026

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