Final Order — Money Services Business

Index: OFR 2026 - 470
ST ATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
CHECK PAYMENTS LLC, Case Number: 133691
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:
I. 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,--g-l:i. 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 to Check Payments LLC, by electronic mail to its Attorney of Record: Meagan Griffin, Esq. Partner, Global Fintech Group at Paul Hastings at meagangriffin@paulhastings.com and Sameer P. Sheikh, Esq., Of Counsel, Paul Hastings at sameersheikh@paulhastings.com on this ~ eptember, 2026. a Email: fr.gov Tel: (850) 410-9889

EXHIBIT A
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
CHECK PAYMENTS LLC, Case Number: 133691
Respondent.
STIPULATION AND CONSENT AGREEMENT
The State of Florida, Office of Financial Regulation ("Office"), and CHECK PAYMENTS LLC ("Respondent") m consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. Check Payments LLC is licensed as a money transmitter, having been
   issued license number FT230000390, pursuant to chapter 560, Florida Statutes. Andrew Brown is the Chief Executive Officer, President, and Manager of Check Payments LLC. The Office conducted an examination (No. 131687) to ascertain Respondent's compliance with chapter 560, Florida Statutes for the period of July 1, 2023 through June 30, 2025. Based on the examination, on April 2, 2026, the Office issued an Administrative Complaint. Respondent then submitted a response contesting the allegations in the Administrative Complaint. In lieu of initiating a formal administrative proceeding, the parties are herein fully resolving the matters at issue.
2. Jurisdiction. The Office is the state agency charged with the administration and
   enforcement of chapter 560, Florida Statutes, and the corresponding rules. 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
   neither admits nor denies, but consents to the Office making the following findings:

a Respondent failed to timely report changes to its banking information under which it conducted money services business activity, in violation of section 560.126(2), Florida Statutes; b. Respondent failed to report the addition of a control person(s), in violation of
section 560.126(3), Florida Statutes; and,
c. Respondent failed to timely renew its registration with the Financial Crimes
Enforcement Network ("FinCEN"), in violation of section 560.1235(1 ), Florida Statutes.
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, which Respondent neither admits nor denies, 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 comply with all the provisions of chapter 560, Florida Statutes, and corresponding rules. b. ADMINISTRATIVE FINE. Respondent agrees to pay the Office an administrative fine in the amount of Five Thousand Five Hundred Dollars ($5,500.00), to be paid at the time of the execution and delivery of 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 "Office 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 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;
c. Any right to an administrative hearing or issuance of a Recommended Order
pursuant to chapter 120, Florida Statutes; and d. 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 the Office's examination number 131687. Each party accepts this release and waiver by the other 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 Com ply. 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 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. [this section left intentionally blank with signatures appearing on the next page]

L
Docusign Envelope ID: 30346CAD-70C8-8751-80A4-CEAE74C74853 CHECK PA 'MRNTS Ll,C:
-~
(Signature)
Name: Andrew Bro\11 Title: Chief Executive Officer, President, and Manager of Check Payments LLC State of IJ-t.v. /or/.\ County of =.M_-t.Y--Yd.lk~- Andrew Bro>m, as Chief Executive Officer, President, and Manager of Check Payments LLC BEFORE ME by means of~ J physical presence or [ ] online notariwtion, has sworn (or affirmed) that he has read and understands the foregoing agreement and voluntarily signed the samrn':'"°' SWORN TO AND SUBSCRIBED before me this.Lt.f5day of August, 2026. ~ Check the appropriate box:
~ Personally known ~
OR Produced Identification 0
Type of identification produced D Driver's License 0 Passport D Other _ ______ _ (Do not include ID number) OFFICE OF FINANCIAL REGULATION 3~71'tt,.,u,t,, Interim Director Grsgory C. Oaks, Dir:e-i;tgr Division of Consumer Finance 9/25/2026 Date: ------ ~