Final Order — Money Services Business

Index: OFR 2026 - 257
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
TIPALTI, INC.,
D/B/ A TIP AL TI,
Case N um her: 132028
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 /~-,4 day of May, 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 Tipalti, Inc., d/b/a Tipalti by electronic mail at regulatory@tipalti.com on this J5-I-,-\ day of May, 2026. ial Regulation X 8050 s , FL 32314-8050 Ema1 . Agency.Clerk@flofr.gov Tel: (850) 410-9889 2

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
TIP AL TI, INC., d/b/a TIP AL TI,
Respondent.
Exhibit A
Case Number: 132028
STIPULATION AND CONSENT AGREEMENT
The State of Florida, Office of Financial Regulation ("Office"), and TIP AL TI, INC., d/bla TIP AL TI ("Respondent"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. At all times material hereto, Tipalti, Inc., d/b/a Tipalti, is and has
   been a Part II Money Services Business in the State of Florida, having been issued license number FT230000139. Tipalti, Inc., d/b/a Tipalti is a wholly owned subsidiary of Tipalti Solutions LTD. Perla Stoeckert is the Chief Compliance Officer and she has been authorized by Tipalti Solutions LTD, to be the signatory to this Stipulation and Consent Agreement The Office conducted an examination (No. 128475) of Respondent's business records and operations to ascertain compliance with chapter 560, Florida Statutes, for the period of January 1, 2023, through December 31, 2024. 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 Respondent pursuant to chapter 560, Florida Statutes.

3. Findings. For purposes of this Stipulation and Consent Agreement, Respondent
   consents to the Office making the following findings:
   a) Respondent failed to report changes in financial information within thirty days of the change, in violation of Rule 69V-560.201(2), Florida Administrative Code, thereby section 560.126(2), 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, Respondent agrees to the following tenns and conditions:
   a. FUTURE COMPLIANCE. Respondent agrees that they shall cease and desist from future violations of chapter 560, Florida Statutes, and the rules promulgated thereunder, and comply with all the provisions of chapter 560, Florida Statutes, and the rules promulgated pursuant thereto. b. ADMINISTRATIVE FINE. Respondent agrees to pay the Office an administrative fine in the amount of Four Thousand Three Hundred Seventy-Five Dollars ($4,375.00), 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 fonn of a wire, cashier's check or money order made payable to "Office of Financial Regulation ". Such payment shall reference Case Number 132028 and shall be sent to the attention of Agency Clerk - c/o Carrie S. Franz, 2

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 shal1 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 waive:
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 3

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 e~pressly 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 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'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. 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. 4

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 executes this Stipulation and Consent Agreement for entry of a Final Order on the last date executed below. [this space intentionally left blank with signatures appearing on the following page] 5

C., d/b/a TIPALTI:
(Signature)
Name: Perla Stoeckert
State of ()9 g t,Clc \l\l,. ~
County of $a..,,,,.. ~O-/\ u,.s ~
Date:
Title: Chief Compliance Officer of Tipalti,
Inc.. d/b/a Tipalti, as authorized by Tipalti
Solutions L m.
Perla Stoeckert, as Chief Compliance Officer of Tipalti, Inc., d/b/a Tipalti as authorized by Tipalti Solutions LTD, BEFORE ME by means of W physical presence or D online notarization, has sworn ( or affirmed) that 't':has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me this lb ~ ay of A-?r ~ l /\ nc~J:·y ·--,=· ;;ub:ic Jr other --- o~f:ar com;:;:J.:· .. ,..: :his J c2rt:ficate voriiies only the i'.!entit:• cf :::a individual •::h:l 1:tr.~;l the: tiocument iO which f; :is certificate Is attached, ind not the truthfulness accuracy, or v::lidity or Iha! document. Check the appropriate box:
Personally known 0
OR Produced Identification El]
Type of identification produced Driver's License Passport Other -------- (Do not include JD number) OFFICE OF FINANCIAL REGULATION Date: 5/11/2026 , 2026. ------------ Gregory C. Oaks, Director Division of Consumer Finance 6