Final Order on Petition for Declaratory Statement Regarding Use of Name Mineral Bank, LLC

Index: OFR 2026 - 426 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: Petition for Declaratory Statement MINERAL BANK, LLC, Case No.: 140294 Petitioner. FINAL ORDER THIS CAUSE having come to the Office of Financial Regulation ("Office") on the Petition for Declaratory Statement ("Petition") of MINERAL BANK, LLC, ("Petitioner"), filed July 17, 2026, the Office, after evaluating the petition and all relevant law and pursuant to section 120.565, Florida Statutes, and rule 28-105.002, Florida Administrative Code, issues this Declaratory Statement. FINDINGS OF FACT

1. The Office is the State of Florida agency responsible for the administration and enforcement of chapter 655, Florida Statutes.
2. On July 17, 2026, Petitioner, MINERAL BANK, LLC, filed with the Office a Petition for Declaratory Statement (dated July 15, 2026) which is attached hereto and incorporated herein as Exhibit "A."
3. On July 24, 2026, pursuant to section 120.565(3), Florida Statutes, and rule 28- 105.0024, Florida Administrative Code, the Office published notice of the Petition in the Florida Administrative Register at Volume 52, Number 143.
4. The Office received no comments regarding the Petition, nor any motion for intervention pursuant to rule 28-105.0027, Florida Administrative Code, and at least 21 days have elapsed since publication in the Florida Administrative Register.
5. The Petitioner requests the Office to issue a Declaratory Statement addressing

whether it may use its name MINERAL BANK, LLC, in Florida in light of section 655.922(2), Florida Statutes, which prohibits the use of the word "bank" by non-financial institutions. 6. The Office considered all the information Petitioner provided and, pursuant to rule 28-105.003, Florida Administrative Code, has taken such information as fact for the purpose of this Final Order. The facts set forth in the Petition are hereby adopted and incorporated herein by reference as the findings of fact of the Office. 7. The Office's conclusions are based upon the assertions of fact contained in the Petition. Any modification of the assertions of fact could alter the Office's conclusions. None of Petitioner's assertions of fact are admitted by the Office as being true, and Petitioner's question is viewed as purely hypothetical. If any facts asserted by Petitioner are untrue or materially incomplete, the Office's conclusions provided herein would not apply. 8. Petitioner asserts, in part, the following facts and arguments: a) It is a limited liability company (unknown state organization); b) It is, or is to be, engaged in the business of strategic mineral vaulting and custody services with operations consist solely of physical vaulting, safekeeping, and custody of strategic minerals; c) It intends to develop multi state operations and establish global headquarters in Florida; d) It is not a financial institution and does not offer traditional banking services; e) It serves institutional clients, does not market to retail consumers, and there will not exist any consumer confusion with regard to financial services offered; t) That the term "bank" has a recognized non-financial meaning (blood bank, food bank, seed bank, data bank) and that "Mineral Bank" fits this category as a repository, not a financial institution; g) It is "registered" in Texas and Wyoming as "Mineral Bank" without restriction. h) That the Office's declaratory statement in Final Order (case# 129239) entered July 21, 2025, supports Petitioner's position herein and is relevant to the distinction 2

between financial and non-financial naming contexts. 1 CONCLUSIONS OF LAW 9. Pursuant to section 120.565(1), Florida Statutes, any substantially affected person may seek a declaratory statement regarding an agency's opinion as to the applicability of a statute as it applies to the petitioner's particular set of circumstances. 10. It is well established that the purpose of a declaratory statement is to afford a petitioner the opportunity to seek an agency's position regarding the applicability of the agency's statutory provisions, orders, or rules to the petitioner's particular circumstances. Adventist Health System/Sunbelt, Inc. v. Agency for Health Care Admin. , 955 So. 2d 1173, 1176 (Fla. 1st DCA 2007) ( citing Chiles v. Div. of Elections, 711 So. 2d 151, 154 (Fla. 1st DCA 1998)). 11. A declaratory statement can be used to avoid costly administrative litigation by informing the petitioner in advance as to the agency's views regarding the petitioner's contemplated conduct. Agency for Health Care Admin. , 955 So. 2d at 1176; Chiles, 711 So. 2d at 154; Nat 'l Ass 'n of Optometrists & Opticians v. Fla. Dep 't of Health, 922 So. 2d 1060, 1062 (Fla. 1st DCA 2006). 12. A declaratory statement must thus be sought from an agency in advance of taking a particular course of action. Agency for Health Care Admin., 955 So. 2d at 1176 ( citing Novick v. Dept of Health, Bd. of Med., 816 So. 2d 1237, 1240 (Fla. 5th DCA 2002)). 13. Petitioner possesses the requisite interest and is the proper party to request a declaratory statement under section 120.565, Florida Statutes, and Rule 28-105, et seq., Florida Administrative Code. 1 The Office's declaratory statement in Final Order case# 129239, entered July 21 , 2025, is not relevant to the instant issue and concerned whether an entity would be required to obtain a money services business license pursuant to chapter 560, Florida Statutes. The declaratory statement does not concern financial institutions, the financial institutions codes, nor any naming issue. 3

14. The Petition is filed for an allowable purpose, that is, to resolve a question or doubt concerning statutory provisions as they may apply to Petitioner's particular set of circumstances, in advance of taking a particular course of action.
15. The Office has jurisdiction over this matter pursuant to sections 20.121(3)(a)2. and (c), 120.565, and 655.012, Florida Statutes.
16. The Office is responsible for the administration and enforcement of chapter 655, Florida Statutes.
17. Section 655.922(2)(a), Florida Statutes, provides: Only a financial institution authorized to do business in this state as provided under subsection (1) may: Transact or solicit business under any name or title that contains the words "bank," "bane," "banco," "banque," "banker," "banking," "trust company," "savings and loan association," "savings bank," or "credit union," or words of similar import, in any context or in any manner. 1 ~- The Petitioner is not a financial institution. Florida law dictates that only financial institutions may solicit or transact business under any name that contains the word "bank."
18. There exists no exception or carve out in the statute allowing non-financial institution repositories to utilize the term "bank."
19. There exists no exception or carve out in the statute allowing non-financial institutions to use the tenn "bank" provided there is no public confusion regarding services to be rendered.
20. This Declaratory Statement applies solely to Petitioner and to the issue of whether it may utilize the name "Mineral Bank" or "Mineral Bank LLC" in Florida, and not for any other purpose. 4

Based on the foregoing Findings of Fact and Conclusions of Law, it is DECLARED THAT: The use of the name "Mineral Bank" or "Mineral Bank LLC" by the Petitioner, a non￾financial institution, to solicit or transact business in Florida would violate section 655.922, Florida Statutes. DONE and ORDERED this 2-f day of August, 2026, in Tallahassee, Leon County, Florida. RusJUe~ , ~ Commissioner 5

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 General Counsel's Office P.O. Box 8050 Tallahassee, FL 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, FL 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 ORA YTON 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. 6

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order and Notice of Rights has been furnished to Petitioner, c/o William Conway, Jr., Managing Member of Mineral Bank LLC, by email to Conwayw2611@gmail.com, on this? 7!; of August, 2026. cial Regulation ice , 8050 a lorida 32314-8050 Email. gency.Clerk@flofr.gov Tel: (850) 410-9889 7

Mineral Bank LLC 2050 NE 39th Street, W207 Lighthouse Point, Florida 33064 Tel: {754) 801-9641 Email: Conwayw2611@gmail.com July 15, 2026 Exhibit "A" Florida Office of Financial Regulation Division of Consumer Finance Subject: Petition for Declaratory Statement - Use of the Term "Bank" To Whom It May Concern, Mineral Bank LLC respectfully submits the enclosed Petition for Declaratory Statement pursuant to F.S. §120.565 and F.A.C. Chapter 28-105. The Petition seeks clarification regarding the lawful use of the term "Bank" under F.S. §655.922(2) as applied to our non-financial, physical-custody business model. Mineral Bank LLC does not engage in any financial institution activities. Our operations consist solely of physical vaulting, safekeeping, and custody of strategic minerals. We request the Office's determination confirming that Mineral Bank LLC may lawfully operate under its existing name within the State of Florida. Respectfully submitted, 4'~~ William Conway, Jr. Managing Member Mineral Bank LLC MINERAL BANK..,

PETITION FOR DECLARATORY STATEMENT Declaration of Institutional Naming Rights for Mineral Bank LLC Before the Florida Office of Financial Regulation I. Petitioner Information Petitioner: Mineral Bank LLC Headquarters: 2050 NE 39th Street, W207, Lighthouse Point, Florida 33064 Contact: William Conway, Jr., Managing Member Jurisdictions: Florida, Texas, Wyoming Business Classification: Strategic Mineral Vaulting & Custody Services II. Statutory Provisions at Issue • F.S. §120.565 - Declaratory Statements • F.S. §655.922 - Restrictions on use of the term "Bank" • F.A.C. Chapter 28-105- Declaratory Statement Procedures Requested interpretation: §655.922(2) as applied to a non-financial, physical-custody business model. Ill. Statement of Facts

1. Nature of Business Mineral Bank LLC is not a financial institution. It does not accept deposits, issue loans, extend credit, or engage in regulated banking activity. Operations consist solely of physical vaulting, safekeeping, and custody of strategic minerals.
2. Existing Registrations Registered under the same name in Texas and Wyoming without restriction. Texas formation confirmed by Northwest Registered Agent LLC (Order #38W5WCBH).
3. Intended Operations Multi-state operations and establishment of Global Headquarters in South Florida.
4. Non-Financial Meaning of "Bank" The term "bank" has a recognized non-financial meaning (blood bank, food bank, seed bank, data bank). "Mineral Bank" fits this category as a repository, not a financial institution. IV. Legal Analysis
5. Applicability of §655.922(2) ..

Mineral Bank LLC satisfies all statutory conditions: • no implication of financial services • clear differentiation • no consumer confusion 2. Declaratory Statement Framework (F.A.C. 28-105)** Petition satisfies all requirements of Rule 28-105.002. 3. OFR Precedent OFR Final Order (Case No. 129239) supports the distinction between financial and non-financial naming contexts. 4. No Consumer Confusion Mineral Bank LLC serves institutional clients, does not market to retail consumers, and clearly discloses its non-financial nature. 5. Multi-State Recognition Texas and Wyoming registrations demonstrate interstate acceptance of the non-financial usage. V. Evidence Supporting the Declaration

1. OFR Letter (June 2, 2026)

2. OFR Declaratory Statement Final Order (Case No. 129239)

3. Florida Bar Article on Declaratory Statements

4. Texas Registration Confirmation (Order #38W5WCBH)

5. Draft Petition Form

6. External Draft Version VI. Requested Determination Mineral Bank LLC requests confirmation that:

7. The use of the term "Bank" does not violate §655.922(2) when used in a non-financial, physical-custody context.

8. Mineral Bank LLC may lawfully operate under this name in Florida.

9. The naming is consistent with multi-state precedent.

10. Mineral Bank LLC's operations do not constitute banking or financial services. VII. Representations & Undertakings Mineral Bank LLC affirms: • No engagement in financial institution activities. • Clear disclosures in all public materials. • Full cooperation with OFR. • Adherence to all statutory and administrative requirements. VIII. Signature & Attestation Respectfully submitted, William Conway, Jr. Managing Member Mineral Bank LLC Lighthouse Point, Florida 33064 Date: July 15, 2026 NOTARY CERTIFICATE State of Florida County of Broward Sworn to (or affirmed) and subscribed before me, by means of ~ sical presence or □ online notarization, this 15th d~ July, 2026, by William Conway, Jr., who is personally known to me or has produced ~ ---~ ~ '- r-'1 l--; 1 e. i....l>e. as identification. Notary Public - State of Florida (Signature of Notary)£___/ /j . (Print, Type, or Stamp Commissioned Name of Notary) My Commission Expires: tJ 'OJ K 2J:L C\ ~v,11., 4'; ....... "'t< RICHARD BEHARRY ~~: Commission# HH 723958 .,~ 0 , ,~o•~ Expires November 8, 2029