2026-05-14
Added · Updated
The Florida Office of Financial Regulation issued a Final Order against LC Motors 1 Inc. and Henry Raud for violating Chapter 520, Florida Statutes by requiring GAP product purchases and failing to provide proper validation and contract instructions. The Respondents agreed to a Stipulation and Consent Agreement requiring them to provide restitution to affected customers via account credits, mailed checks, or deficiency offsets within 21 days. Additionally, the Respondents must pay a $5,000 administrative fine within 7 days and cease all future violations of motor vehicle retail installment laws.
Index: OFR 2026 - 247 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION ,, .. f DO 5/14/2026 LEGAL BH In Re: LC MOTORS 1 INC., and HENRYRAUD, Case Number: 131197 Respondents. 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:
CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished by electronic mail to counsel for Respondents, Joshua Talcovitz, Esquire, at jtalcovitz@kfb-law.com on this ( s+ ~ of May, 2026. 2 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889
STA TE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: LC MOTORS 1 INC., and HENRYRAUD, Respondents. Exhibit A Case Number: 131197 STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation ("Office"), and LC MOTORS 1 INC., and HENRY RAUD ("Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows: I. Background. At all times material hereto, LC Motors 1 Inc., is and has been a motor vehicle retail installment seller in the State of Florida, having been issued license number MV9907935. At all times material, Herny Raud is and has been the President, Sole Owner, and Registered Agent of LC Motors 1 Inc. The Office conducted an examination (Examination No. 127131) to ascertain compliance with Chapter 520, Florida Statutes. Based on the examination, grounds existed to initiate an administrative proceeding against Respondents, and on October 23, 2025, the Office issued an Administrative Complaint. Respondents timely filed a response to the Administrative Complaint. In lieu of inith,!-ting 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 520, Florida Statutes, and the rules promulgated thereunder. The Office has jurisdiction to bring this administrative action against Respondents pursuant to chapter 520, Florida Statutes.
paid in full and are no longer active, by mailing a refund check to the customer's last known address maintained in Respondents' business records; and (iii) for customers whose vehicles have been repossessed and who have a deficiency balance, by applying the applicable refund amount as a credit or offset against such deficiency balance. Respondents' obligation with respect to any customer for whom a refund check is required shall be satisfi,ed upon issuance and mailing of the check to the customer's last known address, and shall not be conditioned upon actual receipt, negotiation, or presentment of the check by the customer. Any refund checks which remain outstanding 90 days after being issued and mailed must be voided and the funds remitted as unclaimed property to the Florida Department of Financial Services. Respondents shall include a letter with each refund check explaining that such action will be taken if the check is not cashed within 90 days. This provision applies to all refund checks not cashed within 90 days, not just those which are returned as undeliverable. As documentary proof of compliance, Respondents shall provide an affidavit executed by an authorized representative within 30 days of Respondents' execution and delivery of this Stipulation and Consent Agreement attesting that all required credits and offsets have been made and all refund checks have been issued and mailed. Respondents shall report the correct unpaid balance to a credit bureau if the account was charged off and an outstanding balance is due, unless Respondents provide a written statement to the Office that they did not report the charged off amounts to a credit bureau. Within 120 days, Respondents shall provide an affidavit executed by an authorized representative attesting that all required remittances of unclaimed funds have been made to the Florida Department of Financial Services, Division of Unclaimed Property, in accordance with this section and Attachment A. Respondents agree to retain a record of all credits made to 3
customers, all refund checks issued and mailed, as well as all canceled and voided checks, and documentation of offsets, in each customer file and make the same available to the Office for verification upon request. b. FUTURE COMPLIANCE. Respondents agree that they shall cease and desist from future violations of chapter 520, Florida Statutes, and the rules promulgated thereunder, and comply with all the provisions of chapter 520, and the rules promulgated pursuant thereto. c. ADMINISTRATIVE FINE. Respondents agree to pay the Office an administrative fine in the amount of Five Thousand Dollars ($5,000.00), to be paid within 7 days of the execution and delivery of this Stipulation and Consent Agreement. This administrative fine shall be submitted in the form ofa wire, cashier's check or money order made payable to ''Office of Financial Regulation. " Such payment shall reference Case Number 131197 and shall be sent to the attention of Agency Clerk - c/o Damaris Reynolds, P.O. Box 8050, Tallahassee, Florida 32314-8050. Respondents acknowledge and agree 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 sarne. 5. Final Order. Respondents consent to the entry of a Final Order, which incorporates the terms and conditions of this Stipulation and Consent Agreement. Respondents understand and agree 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 4
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 520 and 120, Florida Statutes. 6. Waiver. By Respondents' consent to the entry of a Final Order with respect to this proceeding, Respondents 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 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, Respondents waive, release, and forever discharge the Office and its agents, representatives, and employees from any and all causes of action, in law or in equity, which Respondents may have arising out of this matter. The Office accepts this release and waiver by Respondents 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. Respondents acknowledge, concur, and stipulate that Respondents' 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 5
agreement and the Final Order entered pursuant to chapters 120 and 520, 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 Respondents' 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 Respondents 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 Respondents 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 Respondents execute this Stipulation and Consent Agreement for entry of a Final Order on the last date executed below. 6
LC MOTORS 1 INC.: Date: (} ,S-.- Bl - 20(l0 (Signature) Name: HENRY RAUD Title: President and Sole Owner ~. State of fµJ-µ p ~ County of ~ HE~RAUD, as President and Sole Owner of LC MOTORS 1 INC., BEFORE ME by means of ci' physical presence or D online 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..30#v'day of-"ft_,_P'---'Jl+'---"- . ____ , 2026. Check the appropriate Ix: Personally known ~ OR Produced Identification D Mt /4,-~~ ~ N6tary Public , Nolary.Publiq State of Florida I ~ M.all Mlkker Rock I 4 My Commission HH 323531 I 4 IIII Expires 10/19/2026 ' Type of identification produced D Driver's License D Passport D Other ______ _ (Do not include ID number) 7
HENRYRAUD: Date: ------------ Name: HENRY RAOD
ATTACHMENT "A" Date Sold Vdi.lclrlnfo VDI# GAP AMOUNT Status (Active, Paid Off, or CHARGED Reposmed) 7n/2023 $300.00 PAID OFF 8/21/2023 $300.00 ACTIVE 10/2/2023 $300.00 REPOSESSED I 1/3/2023 $300.00 REPOSESSED 12/18/2023 $500.00 ACTIVE 2/5/2024 $300.00 REPOSF.SSED 2/24/2024 2021 NISS $300.00 REPOSESSED 3/6/2024 2018 FORD $300.00 PAID OFF 3/11/2024 2019 INfl $500.00 REPOSESSED 4/10/2024 2022 TOYT $300.00 ACTIVE 5/14/2024 $500.00 ACTIVE 6111/2024 $500.00 PA1D0Ff" 7/10/2024 $500.00 ACl'IVI:! 8112/2024 $500.00 PAID OFF 8/23/2024 2019 NISS $500.00 PAID OFF II I 024 5 10/1/2024 $500.00 ACTIVE 10/21/2024 $500.00 ACTIVE 11/15/2024 2019 CHEV $500.00 REPOSESSED 11/23/2024 $500.00 ACTIVE )21312024 $500.00 ACTIVE