Final Order — Money Services Business

Index: OFR 2026 - 368 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: CT PA YER LLC, Case Number: 138995 Respondents. FINAL ORDER This cause came on for consideration and final agency action. Upon review of the record and being otheIWise 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 / 6 ~ day of July, 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 by U.S. Mail to CT Payer LLC at 100 S. Ashley Drive, Suite 600, Tampa, Florida 33602 and by electronic mail at mike@ctpayer.com on this 1 )t:,} of July, 2026. Tel: (850) 410-9889 2 n 14-8050 @flofr.gov

Exhibit A ST A TE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: CT PAYER LLC, Case Number: 138995 Petitioner. _STIPULATION AND CONSENT A1i8EEl.\1ENI. The State of Florida, Office of Financial Regulation ("Office"), and CT PA YER LLC ("Petitioner") in consideration of the mutual promises herein, recites, stipulates, and agrees as follows:

1. Backiround. On January 14, 2026, Petitioner submitted a new application for licensure as a Part II Money Services Business in the State of Florida, pursuant to chapter 560, Florida Statutes. On April 20, 2026, the application was deemed complete. Based on disclosures made by Petitioner during the application process, the Office determined Petitioner engaged in unlicensed money transmitter activity during the period of December 31, 2018, through January 14,

Michael T. Nevin is the Chief Executive Officer (CEO) and Managing Member of CT Payer LLC. As such, he is the signatory to this Stipulation and Consent Agreement. In lieu of initiating a formal proceeding, the parties are herein 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 rules promulgated thereunder. The Office has jurisdiction to bring this administrative action against Petitioner pursuant to chapter 560, Florida Statutes. 3. Finding. For purposes of this Stipulation and Consent Agreement, Petitioner neither ndmits nor denies, but consents to the Office making a finding that during the period of

December 31, 2018, through January 14, 2026, Petitioner engaged in unlicensed money transmitter activity, in violation of sections 560.125(1) and 560.204(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 and in consideration of the Office's forbearance from further litigation, Petitioner agrees to the following terms and conditions: a. FUTURE COMPLIANCE. Petitioner agrees that it shall cease and desist from violations of chapter 560, Florida Statutes, and the rules promulgated thereunder, and comply with all provisions of chapter 560, Florida Statutes, and the rules promulgated thereunder. b. ADMINISTRATIVE FINE. Petitioner agrees to pay the Office an administrative fine in the amount of Twenty-Nine Thousand Dollars ($29,000.00), to be paid in three installments. The first payment of Ten Thousand Dollars ($10,000.00) shall be paid at the time of the execution and delivery of this Stipulation and Consent Agreement. The second payment of Ten Thousand Dollars ($10,000.00) shall be paid within 30 days of the date of the Final Order. The final payment of Nine Thousand Dollars ($9,000.00) shall be paid within 60 days of the date of the Final Order. This administrative fine payments shall be submitted in the form of a wire, cashier's check, or money order made payable to "Office of Financial Regulation". Such payment shall reference Case Number 138995 and shall be sent to the attention of Agency Clerk- c/o Attorney Carrie Franz, Post Office Box 8050, Tallahassee, Florida 32314-8050. Petitioner

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. c. LICENSURE. The Office shall approve Petitioner's Part II Money Transmitter application and issue the license within one business day of the date of the Final Order adopting this Stipulation and Consent Agreement. 5. Final Order. Petitioner consents to the entry of a Final Order, which incorporates the terms of this Stipulation and Consent Agreement. Petitioner 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 Petitioner's consent to the entry of a Final Order with respect to this proceeding, Petitioner 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, Petitioner 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 Petitioner may have arising out of this matter. The Office accepts this release and waiver by Petitioner 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 Complv. Petitioner acknowledges, concurs, and stipulates that Petitioner'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 Petitioner'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's 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. Severability. 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 Petitioner 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 Petitioner 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 Petitioner execute this Stipulation and Consent Agreement for entry of a Final Order on the last date executed below. [This space is intentionally left blank. Signatures to begin on following page.)

CT PA YER LLC: (Signature) Name: Michael T. Nevin State of Flu1-:dc... County of. u i t ls-'7or "" ~ h Date: Title: Chief Executive Officer, and Managing Member of CT Payer LLC Michael T. Nevin, as Chief Executive Officer (CEO), Managing Member of CT Payer LLC, BEFORE ME by means of (g' physical presence or O on line notarization, has sworn ( or affirmed) that he has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me this /cl' day of _.,.Ji""-""-t-+~f ___ ___,1 2026. Notary ~ Public Check the appropriate box: Personally known D OR Produced Identification (EJ Type of identification produced (g) Driver's License D Passport D Other ______ _ (Do not include ID number) OFFICE OF FINANCIAL REGULATION 8dt~~ for Gregory C. Oaks Gregory C. Oaks, Director Division of Consumer Finance 7/16/2026 Date:

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