Final Order — Mortgage Broker

Index: OFR 2026 - 288 , DOCKETED • • 6/3/2026 LEGAL STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: TSI FINANCIAL SERVICES, INC., and LOUIS-MARIE VILDOR, Case Number: 123677 Respondents. FINAL ORDER This cause came on for consideration and final agency action. Upon review of the complete record in this case, including the attached 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-referenced matter. IT IS ACCORDINGLY ORDERED: A. The attached Recommended Order is hereby adopted by the Office and incorporated by reference as if fully stated herein. B. Within thirty (30) days of the docketing of this Final Order, Respondents shall pay an ADMINISTRATIVE FINE of One Thousand Dollars ($1,000.00). This administrative fine shall be submitted either via wire transfer, or via money order or cashier's check made payable to the Office of Financial Regulation and shall be sent to the attention of Agency Clerk, c/o Joaquin Alvarez, Esq., Post Office Box 8050, Tallahassee, Florida 32314-8050.

C. Respondent shall CEASE and DESIST from any further violations of chapter 494, Florida Statutes, and the rules promulgated thereto. DONE and ORDERED this 3 rd day of June, 2026, in Tallahassee, Leon County, Florida. 2

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: By 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 Bv 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. 3

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order was furnished via electronic mail to Respondents at lvildor@gmail.com and at tsifinancialservice@gmail.com, on this 3rJ day of June, 2026. 4 egulation OS 8 0 Tallahassee L 314-8050 Email: Age y.Clerk@flofr.gov Tel: (850) 410-9889

STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: TSI FINANCIAL SERVICES, INC., and LOUIS-MARIE VILDOR, Respondents. RECOMMENDED ORDER Case N um her: 123677 A hearing in this case was conducted via written submissions 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 Respondents: APPEARANCES Joaquin Alvarez, Esquire Office of Financial Regulation 200 E. Gaines Street Tallahassee, FL 32399-0376 No appearance STATEMENT OF THE ISSUE Whether the Office should impose an administrative fine for the violations cited in the Administrative Complaint. PRELIMINARY STATEMENT On February 25, 2026, the Office of Financial Regulation ("Office") issued an Administrative Complaint and Notice of Rights ("Complaint") to TSI Financial Services, Inc. and Louis-Marie Vildor ("TSI" or "Respondents"). Pursuant to section 120.57(2), Florida Statutes, 1

Respondents timely filed a request for an administrative hearing by written submission, admitting the material factual aJlegations in the Complaint. By Order dated April 1, 2026, the Office granted a proceeding pursuant to section 120.57(2), Florida Statutes, and appointed the undersigned as the Hearing Officer in this matter. On April 3, 2026, an Initial Order was entered that provided the parties with the schedule for a hearing by written submissions. On May 14, 2026, an amended Complaint was filed, seeking a reduction in the original fine amount requested. All written submissions and exhibits were timely filed by the Office. Respondents filed no submissions or exhibits. The following exhibits offered by the Office were admitted into evidence without objection: Office's Exhibit 1: Notice of Non-Compliance issued to Respondents on January 11, 2024 in Examination No. 115385 Office's Exhibit 2: Screenshot of Nationwide Multistate Licensing System & Registry website with Respondents' Mortgage Call Report filing history Office's Exhibit 3: Email reminders sent January 23, 2024 and May 2, 2024 regarding due date for the Mortgage Call Report for the 2024 1st Quarter Office's Exhibit 4: Email reminders sent April 2, 2024, April 22, 2024 and February 5, 2024 regarding due date for the Mortgage Call Report for the 2023 4th Quarter Office's Exhibit 5: Screenshot of examiner Ken McKenzie's notes in the Office of Financial Regulation's REAL system database showing summary of late-filed Mortgage CaJI Reports in Examination No. 122634 Office's Exhibit 6: Late-filed Mortgage CaJI Reports for Q4 2023, Ql-Q4 2024 Office's Exhibit 7: Sanction Computation Worksheet, Examination 122634 Office's Exhibit 8: Revised Sanction Computation Worksheet, Examination 122634 The undersigned took official recognition of chapter 494, Florida Statutes, sections 120.569, 120.57(2), and 120.60, Florida Statutes, and Florida Administrative Code Rule chapter 69V-40. 2

The parties were advised they could file written submissions and exhibits within thirty (30) days of the filing of the Initial Order, and could file proposed recommended orders within fourteen (14) days after submission of all written statements and proposed exhibits. The Office filed its Proposed Recommended Order on May 18, 2026. Respondents did not file a Proposed Recommended Order. FINDINGS OF FACT

1. At all times material, TSI Financial Services, Inc. and Louis-Marie Vildor have operated as a licensed mortgage broker in Florida (License No. MBR5709), pursuant to chapter 494, Florida Statutes.
2. The Findings of Fact as alleged in the Administrative Complaint issued to Respondents on February 25, 2026, are hereby adopted as the Findings of Fact in this Recommended Order. CONCLUSIONS OF LAW
3. Pursuant to section 494.0011, Florida Statutes, the Office is responsible for administering and enforcing the provisions of chapter 494, Florida Statutes, and the administrative rules promulgated thereunder.
4. In hearings pursuant to section 120.57(2), Florida Statutes, where, by definition, there are no disputed issues of material fact, only conclusions oflaw are to be drawn as to whether the facts support the agency's intended decision. See Autoworld of America Corp. v. Department of Highway Safety and Motor Vehicles, 754 So. 2d 76, 77 (Fla. 3d DCA 2000).
5. Pursuant to section 494.0011, Florida Statutes, the Office is charged with the responsibility of administering and enforcing the provisions of chapter 494, Florida Statutes.
6. Pursuant to section 494.001 (23), Florida Statutes (2023), a "mortgage broker" 3

means "a person conducting loan originator activities through one or more licensed loan originators employed by the mortgage broker or as independent contractors to the mortgage broker." Pursuant to section 494.001(30), Florida Statutes, a "principal loan originator" means "the licensed loan originator in charge of, and responsible for, the operation of a mortgage lender or mortgage broker, including all of the activities of the mortgage lender's or mortgage broker's loan originators, in-house loan processors, and branch managers, whether employees or independent contractors." 7. Pursuant to section 494.001(7), Florida Statutes, a "control person" means "an individual, partnership, corporation, trust, or other organization that possesses the power, directly or indirectly, to direct the management or policies of a company, whether through ownership of securities, by contract, or otherwise." 8. Rule 69V-40.l 1 l(l), Florida Administrative Code, provides that the penalties that are applicable to each ground for disciplinary action that may be imposed by the Office against a person for a violation of chapter 494, Florida Statutes, are set forth in the Office of Financial Regulation, Division of Consumer Finance, Disciplinary Guidelines for Mortgage Loan Originators and Mortgage Entities, Form OFR-494-14. 9. Pursuant to Rule 69V- 40.111 (5)(6), Florida Administrative Code, the range for an "A" level administrative fine is from $1,000.00 to $3,500.00, and the range for an "A" level suspension is from 3 to IO days. 10. Pursuant to section 494.004(2), Florida Statutes, a mortgage broker must submit to the Office on a quarterly basis a report of condition, also known as a Mortgage Call Report ("MCR") to the Nationwide Mortgage Licensing System and Registry ("NMLS"). 11. Pursuant to Rule 69V-40.176(3)(a), Florida Administrative Code, mortgage brokers who are not approved Fannie Mae, Freddie Mac Sellers/Servicers, or Ginnie Mae Issuers 4

are required to submit the Residential Mortgage Loan Activity component of the MCR to the Office via NMLS within 45 days of the end of each calendar quarter. 12. Respondents failed to timely submit MCRs as follows: A. MCR for quarter ending December 31, 2023, which was due on February 14, 2024, was filed on December 30, 2024; B. MCR for quarter ending March 31, 2024, which was due on May 15, 2024, was filed on December 30, 2024; C. MCR for quarter ending June 30, 2024, which was due on August 14, 2024, was filed on December 30, 2024; D. MCR for quarter ending September 30, 2024, which was due on November 14, 2024, was filed on December 30, 2024; and E. MCR for quarter ending December 31, 2024, which was due on February 14, 2025, was filed on July 18, 2025. 13. In failing to timely submit MCRs, Respondents violated section 494.004(2), Florida Statutes, by violating Rule 69V-40.l 76(3), Florida Administrative Code. 14. Pursuant to the Disciplinary Guidelines for Mortgage Loan Originators and Mortgage Entities Form OFR-494-14, incorporated by reference in Rule 69V-40.1 ll, Florida Administrative Code, a licensee cited for violating section 494.004(2), Florida Statutes, is subject to an "A" level administrative fine and an "A" level suspension. 15. The penalty originally recommended for these serial violations was $3,500.00, which the Office subsequently reduced to $1,000.00 in its amended Complaint. 16. Respondents did not appear at the hearing or file a written submission or proposed recommended order, nor did Respondents present any mitigating circumstances warranting a further reduction in the recommended fine. 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 imposing on Respondents an administrative fine in the amount of One Thousand Dollars ($1,000.00), to be paid within thirty (30) days of the 5

entry of the Final Order adopting this Recommended Order. Respectfully submitted this 20th day of May 2025, in TaJlahassee, Leon County, Florida. MirUtA11/ S. W~ MIRIAM S. WILKINSON Hearing Officer Office of Financial Regulation 200 E. Gaines Street Tallahassee, FL 32399-0370 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Recommended Order has been furnished via email to TSI Financial Services, Inc. and Louis-Marie Vildor at lvildor@gmail.com on this _2_0t_h ___ day of May, 2026. Cc: Joaquin Alvarez, Asst General Counsel Office of Financial Regulation 6 Office of Financial Regulation Post Office Box 8050 Tallahassee, FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889