Final Order of Approval for Cogent Bank to Exercise Trust Powers

Index: OFR 2026 - 301 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: APPLICATION FOR AUTHORITY FOR A BANK OR ASSOCIATION TO EXERCISE TRUST POWERS - COGENT BANK, ORLANDO, ORANGE COUNTY, FLORIDA FINAL ORDER OF APPROVAL Case No.: 139121 On June 10, 2026, the Office issued a Notice of Intent to Approve ("NOi") the application for approval for authority for Cogent Bank to exercise trust powers. On June 11, 2026, the Office received the Applicant's written waiver of the right to an administrative hearing concerning the Office's intended action. Accordingly, it is ORDERED:

1. The application is APPROVED, subject to satisfaction of the conditions contained in the attached NOL
2. The Applicant must satisfy the conditions of approval specified in the attached NO I. Until these conditions have been met, or if any interim development is deemed to warrant further action by the Office, the Office reserves the right to alter, suspend, or withdraw approval. DONE and ORDERED this 15* day of June, 2026, at Tallahassee, Leon County, Florida.

NOTICE OF RIGHT TO APPELLATE REVIEW 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: B 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 By Hand Deliverv Agency Clerk Office of Financial Regulation General Counsel's Office The Fletcher Building 101 East Gaines Street Tallahassee, Florida 32399-0379 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 THIS ORDER. 2 of3

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing Final Order of Approval has been furnished by electronic mail to Ms. Kimberly Rossa at krossa@cogentbank.com this J_5:/-3ay of June, 2026. da 32314-8050 Email: Agency.Clerk@flofr.gov Phone: (850) 410-9889 3 of3

Commissioner Russell C. Weigel, III June 10, 2026 Ms. Kimberly Rossa Chief Compliance Officer Cogent Bank 420 S Orange Ave, Suite 150 Orlando, Florida 32801 Re: Application for Authority for a Bank or Association to Exercise Trust Powers - Cogent Bank. Orlando. Orange County. Florida OFR Case No.: 139121 Dear Ms. Rossa: NOTICE IS HEREBY GIVEN pursuant to chapters 655,658,660 and sections 120.60 and 120.80, Florida Statutes, that the Office of Financial Regulation ("Office") has considered the information presented in the application by Cogent Bank, Orlando, Orange County, Florida ("Applicant" or "Bank") for authority to exercise trust powers and intends to approve the application based upon the following: FINDINGS OF FACT (1) The application for authority to exercise trust powers by the Applicant was filed with the Office on April 1, 2026. (2) On or about May 12, 2026, the Applicant applied to the Federal Deposit Insurance Corporation ("FDIC") with its intent to exercise trust powers. The FDIC subsequently approved the application on June 1, 2026. (3) Notice of the application was published in the Florida Administrative Register on April 3, 2016. No hearing was requested and none was held. (4) The decision due date for the application is August 6, 2026. (5) The Applicant is a state-chartered bank located at 420 South Orange Avenue, Suite 150, Orlando, Orange County, Florida. (6) The Board of Directors of the Bank passed a resolution on March 19, 2026, approving the establishment of a Trust Department. (7) The Applicant submitted Madelayne Cordero ("Ms. Cordero") as the proposed Senior Trust Officer. (8) The Office conducted a background investigation of Ms. Cordero. The Office discovered no information to preclude Ms. Cordero from serving as Senior Trust Officer. WWW.FLOFR.COM IO I East Gaines Street, Tallahassee, Florida 32399-0370 (850)410-9601 • FAX(850)410-9663 Mailing Address: 200 East Gaines Street, Tallahassee, Florida 32399-03 70

Ms. Kimberly Rossa Chief Compliance Officer June 10, 2026 Page 2 CONCLUSIONS OF LAW (9) The general condition of the Bank is sufficient to support the proposed trust department. (10) The earnings and earnings prospects of the Bank, including the earning prospects of the proposed trust department, are sufficient to support the anticipated expenses and any anticipated operating losses of the trust department during its formative or initial years. ( 11) The capital structure of the Bank is adequate to support the trust department. (12) Ms. Cordero has, or will be supplied with, sufficient trust and related investment, financial, and managerial experience, ability, and standing to operate the trust department. (13) Provision has been made for the trust department to occupy suitable quarters at the location specified in the application. Having considered the application, the Office concludes that the application satisfies the criteria of section 660.26, Florida Statues (2025). Consequently, the Office intends to approve the application subject to the following conditions: (]) That the FDIC does not rescind, suspend, or withdraw its approval of the application for trust powers by the Applicant. (2) That the Bank's Senior Trust Officer shall be Madelayne Cordero. (3) That securities are deposited or pledged to the Chief Financial Officer as required by section 660.27, Florida Statues, prior to commencement of trust business. (4) That stockholder approval is obtained for amendment to the Bank's Articles oflncorporation providing for the operation of a general banking and trust business. Applicant shall submit to the Office the original Amended Articles of Incorporation, duly executed, together with the filing fee due to the Department of State under section 607 .0122, Florida Statutes. (5) That blanket bond coverage includes operation of trust department and that trust errors and omissions insurance have been obtained. The Office will issue a conditional Final Order of Approval after the expiration of the 21-day period contained in the Notice of Rights unless the Applicant elects to waive rights to a hearing by providing written notification of such waiver to the Office. Before all the conditions specified above and other reasonable requirements of the Office have been fulfilled, or if any interim development is deemed by the Office to warrant such action, the Office retains the right to alter, suspend, or withdraw approval of the indirect change in control of the Bank and the Trust Company. This approval shall expire six months from the date of the Final Order, unless the Office has granted a request for an extension of time for good cause shown. In taking this action, the Office has relied on the representations and commitments made by the Applicant in the application and all supplemental information submitted. Every effort should be made to meet these representations and commitments. Please keep the Office advised of the steps being taken to comply with the conditions imposed in this Notice. If you have any questions, please contact the Office at (850) 410-9513.

Ms. Kimberly Rossa Chief Compliance Officer June 10, 2026 Page 3 Sincerely, Ben F. Brinkley III Director Division of Financial Institutions cc: Federal Deposit Insurance Corporation, Atlanta, Georgia Federal Reserve Bank of Atlanta Bureau Chief, Bank Regulation, Office of Financial Regulation Agency Clerk, Office of Financial Regulation

Ms. Kimberly Rossa Chief Compliance Officer June 10, 2026 Page4 NOTICE OF RIGHTS You may request a hearing to be conducted in accordance with the provisions of sections 120.569 and 120.57, Florida Statutes. A request for such a hearing must comply with the provisions of Rule 28- 106.104(2), Florida Administrative Code, and either Rule 28-106.201(2) or Rule 28-106.301 (2), Florida Administrative Code, and must be filed with the Agency Clerk 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 By Hand Delivery Agency Clerk Office of Financial Regulation General Counsel's Office The Fletcher Building 101 East Gaines Street Tallahassee, Florida 32399 Phone: (850) 410-9889 Your request must be filed within 21 days of the date ofreceipt of this Notice. YOUR FAILURE TO RESPOND TO THIS NOTICE WITHIN 21 DAYS OF RECEIPT WILL CONSTITUTE A WAIVER OF YOUR RIGHT TO REQUEST A HEARING AND A FINAL ORDER MAY BE ENTERED WITHOUT FURTHER NOTICE. In the event that a hearing is requested, all parties will have the right to be represented by counsel or other qualified representative, to offer written and oral testimony, to call and cross-examine witnesses, and to have subpoenas and subpoenas duces tecum issued on their behalf. Pursuant to Section 120.573, Florida Statutes, you are advised that mediation of this matter is not available. In accordance with the Americans with Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the Agency Clerk no later than seven (7) days prior to the filing deadline or proceeding, at the Office of Financial Regulation, The Fletcher Building, 101 East Gaines Street, Tallahassee, Florida 32399-0379, Phone: (850) 410-9889, or by Email: agency.clerk@flofr.gov.

Ms. Kimberly Rossa Chief Compliance Officer June 10, 2026 Page 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 10th day of June, 2026, a true and correct copy of the foregoing Notice of Intent to Approve was sent by electronic mail, to Ms. Kimberly Rossa at krossa@cogentbank.com Jason M. Guevara