Final Order Revoking Money Services Business License and Imposing Fine

Index: OFR 2026 - 259 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: BAKER'S MANAGEMENT PROPERTIES INC., D/B/A DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, Respondents. FINAL ORDER Case Number: 117846 The State of Florida, Office of Financial Regulation ("Office"), being authorized and directed to administer and enforce chapter 560, Florida Statutes, hereby enters this Final Order with Notice of Rights ("Final Order") as authorized by the provisions of chapters 120 and 560, Florida Statutes, against BAKER'S MANAGEMENT PROPERTIES INC., D/B/A DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, AND VERNON DIXON II ("Respondents"). FINDINGS OF FACT

1. The Office has jurisdiction over the subject matter of this case and the parties hereto.

2. At all times material, Baker's Management Properties Inc. d/b/a Down South Beverages & Check Cashing; Cartoon Car Wash is and has been licensed in Florida as a Part III Money Services Business, having been issued license number FT340000266, pursuant to chapter 560, Florida Statutes. Vernon Dixon II is Baker's Management Properties President and Sole Owner.

3. The Office conducted an examination (No. 110542) to ascertain Respondents' compliance with chapter 560, Florida Statutes, and found that grounds existed to initiate a legal action against Respondents. The Office issued an Administrative Complaint ("Complaint"), attached as Exhibit A, alleging violations of chapter 560, Florida Statutes, and seeking an administrative fine of $44,575, and revocation of the Money Services Business license number FT340000266.

4. The Office attempted service of the Complaint by U.S. Certified Mail on June 3, 2025 to the address 720 Delaware Ave., Unit B, Fort Pierce, FL 34950 and that was returned on July 15, 2025.

5. The Office attempted service of the Complaint by U.S. Certified Mail on July 17, 2025 to the address, 420 NUS #1 Fort Pierce, FL 34950 and that was returned on July 31, 2025.

6. The Office attempted service of the Complaint by U.S. Certified Mail on July 17, 2025 to the address, 216 Behring Way, Jupiter, FL 33458 and that was returned on September 5,

8. The Office attempted service of the Complaint by U.S. Certified Mail on November 24, 2025 to P.O. Box 1746 and that was returned on January 6, 2026.

9. The Office attempted service of the Complaint by U.S. Certified Mail on November 24, 2025 to 2410 Ave D, Fort Pierce, FL 34950 and that was returned on January 22, 2026.

10. All the Complaints were returned by the USPS as undeliverable; see Exhibit B attached.

11. Additionally, the Office placed a legal advertisement that was published on November 23, 2025, November 30, 2025, December 7, 2025, and December 14, 2025; see Exhibit C attached. 2

12. The Complaint contained a Notice of Rights, which fully advised Respondents that they had twenty-one (21) days after the receipt of the Complaint within which to petition the Office for an administrative hearing to contest the allegation set forth in the Complaint, in accordance with sections 120.569 and 120.57, Florida Statutes, including the following information: TO PRESERVE THE RIGHT TO A HEARING, A WRITTEN RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION WITHIN TWENTY-ONE (21) DAYS AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. SAID RESPONSE MUST BE RECEIVED BY THE OFFICE NO LATER THAN 5:00 P.M. ON THE TWENTY￾FIRST DAY AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. A FAILURE TO TIMELY RESPOND IN WRITING WILL CONSTITUTE A W AIYER OF THE LICENSEE'S RIGHT TO REQUEST A HEARING AND A FINAL ORDER MAY BE ENTERED WITHOUT FURTHER NOTICE.

13. Using the last date of publication of the legal notice, Respondents' written response to the Complaint was due on or before January 4, 2026. To date, the Office has neither received a written response to the Complaint nor have Respondents made a claim of equitable tolling.

14. The Findings of Fact alleged in the Complaint are hereby incorporated by reference and adopted as Findings of Fact in this Final Order. CONCLUSIONS OF LAW

15. The Office is responsible for the administration and enforcement of chapter 560, Florida Statutes, and has jurisdiction over the subject matter and of Respondents pursuant to chapter 560, Florida Statutes.

16. The Findings of Fact that have been adopted herein serve as the basis of the entry of this Final Order against Respondents. 3

17. Section 120.569(2)(a), Florida Statutes, and Rule 28-106.111(2), Florida Administrative Code, require, among other things, that a response or a petition to an action which affects the substantial interests of a party be filed with the agency within 21 days of receipt of written notice of the action.

18. Section 120.569(2)(c), Florida Statutes, provides that a petition for hearing shall be dismissed if it has been untimely filed (not within 21 days).

19. Pursuant to Rule 28-106.111(4), Florida Administrative Code, the failure of Respondent to timely respond to the Complaint constitutes a waiver of Respondents' right to an administrative proceeding.

20. The doctrine of equitable tolling can be applied in administrative cases when a party has been misled or lulled into inaction, i.e., has in some extraordinary way, been prevented from asserting his rights, or has timely asserted his rights in the wrong forum. Machules v. Department of Admin., 523 So. 2d 1132 (Florida 1988).

21. Without any evidence of equitable tolling, it is appropriate for the Office to conclude there was none. Patz v. Dept. of Health, 864 So.2d 79, 80 (Fla. 3d DCA 2003).

22. When Respondents failed to submit a response to the Office on or before January 4, 2026, Respondents did not timely file a petition or any other document in response to the Complaint. Respondents also presented no claim, or evidence of equitable tolling. Therefore, it is appropriate for the Office to conclude there was no equitable tolling and Respondents waived their right to an administrative proceeding.

23. Based on the Findings of Fact adopted herein, the Office concludes that Respondents violated the specific statutes and rules charged in the Complaint and, as such, the specific charges in the Complaint are adopted in this Final Order as Conclusions of Law. 4

24. The Findings of Fact and Conclusions of Law that form the basis for the Complaint, together with the waiver of a hearing by Respondents, constitute grounds for the Office to revoke Respondents, BAKER'S MANAGEMENT PROPERTIES INC., D/B/A DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH Money Services Business license number FT340000266 and impose an administrative fine against BAKER'S MANAGEMENT PROPERTIES INC., D/B/A DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, AND VERNON DIXON II. Based on the foregoing Findings of Fact and Conclusions of Law, it 1s hereby ORDERED: A. Within thirty (30) days of the date of this Final Order, BAKER'S MANAGEMENT PROPERTIES INC., D/B/A DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, AND VERNON DIXON II shall pay an ADMINISTRATIVE FINE of Forty-Four Thousand Five Hundred Seventy-Five Dollars ($44,575.00). B. Respondents shall submit the administrative fine in the form of a wire, money order or cashier's check made payable to the "Office of Financial Regulation". Such payment shall reference Case Number 117846 and shall be sent to the attention of Agency Clerk, c/o David Tarbert, P.O. Box 8050, Tallahassee, FL 32314-8050. C. Baker's Management Properties Inc., d/b/a Down South Beverages & Check Cashing; Cartoon Car Wash Money Services Business license FT340000266 is hereby REVOKED effective thirty (30) days from the date of this Final Order. 5

DONE and ORDERED this ~ day of May, 2026, in Tallahassee, Leon County, Florida. 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, Facsimile or Email Agency Clerk Office of Financial Regulation Office of General Counsel P.O. Box 8050 Tallahassee, FL 32314-8050 Phone: (850) 410-9889 Fax: (850) 410-9663 Email: Agency.Clerk@flofr.gov OR By Hand Delivery Agency Clerk Office of Financial Regulation Office of General Counsel 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 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. 6

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order was furnished by U.S. Certified Mail to Baker's Management Properties Inc., d/b/a Down South Beverages & Check Cashing; Cartoon Car Wash, and Vernon Dixon II, Registered Agent, at 720 Delaware Avenue, Unit B, Fort Pierce, FL 34950 on this / °[f"'- day of May, 2026. 9489 0090 0027 6214 9311 50 7 egulation 50 a a assee, 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: BAKER’S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, Respondents. Case Number: 117846 ADMINISTRATIVE COMPLAINT The State of Florida, Office of Financial Regulation (“Office”), files this Administrative Complaint against BAKER’S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, (together as “Respondents”), alleging: GENERAL ALLEGATIONS

1. Pursuant to sections 560.105 and 560.109, Florida Statutes, the Office is charged with administering and enforcing the provisions of chapter 560, Florida Statutes, and conducting examinations and investigations to determine whether any provision of chapter 560, Florida Statutes, has been violated.
2. Pursuant to section 560.114(1)(a), Florida Statutes, failure to comply with any provision of chapter 560, Florida Statutes, or related rule, constitutes grounds for disciplinary action.
3. Parts II, III, and IV of chapter 560, Florida Statutes, set forth the specific requirements of money services businesses and licensees. EXHIBIT A

2 4. Section 560.103(1), Florida Statutes, defines an “affiliated party” as a control person, officer, responsible person, employee, or a person who has a controlling interest in a money services business. 5. Section 560.114(1)(a), Florida Statutes holds an “affiliated party” responsible for complying with all provisions of chapter 560, Florida Statutes, and its related rules. 6. Section 560.103(10)(a), Florida Statutes, defines a “control person” as, among other things, the president, chief executive officer, chief financial officer, chief operations officer, chief legal officer, or compliance officer of a money services business. 7. Section 560.103(6), Florida Statutes, defines a “check casher” as a person who sells currency in exchange for payment instruments or checks received, except travelers’ checks. 8. At all times material, Baker’s Management Properties Inc. d/b/a Down South Beverages & Check Cashing; Cartoon Car Wash (“Baker’s Management”) is and has been licensed as a Part III money services business pursuant to chapter 560, Florida Statutes, holding license number FT340000266. 9. At all times material, Vernon Dixon II (“Dixon”) has been the President, sole owner, Compliance Officer, and Responsible Person of Baker’s Management and by operation of law, pursuant to section 560.103(1) and 560.114(1)(a), Florida Statutes, Dixon is an “affiliated party” who is liable for any and all violations of Baker’s Management. 10. On July 18, 2017, Final Order 69412 was entered by the Office finding that Respondents had violated: section 560.310(2)(d), Florida Statutes, and Rule 69V-560.704(5), Florida Administrative Code, by entering inaccurate information into the check cashing database (“CCDB”) or by failing to timely enter required information into the CCDB; section 560.123(3)(c), Florida Statutes, and Rule 69V-560.608, Florida Administrative Code, by failing to timely and

3 accurately file all Currency Transaction Reports (“CTRs”); section 560.310(2)(a), Florida Statutes, and Rule 69V-560.704(4)(d), Florida Administrative Code, by failing to maintain complete customer files; section 560.310(2)(c), Florida Statutes, and Rule 69V-560.704(4)(a), Florida Administrative Code, by failing to maintain records of customers’ thumbprints; section 560.310(2)(b), Florida Statutes, and Rule 69V-560.704(4)(c), by failing to maintain records of legible, valid and acceptable personal identifications; section 560.126(2), Florida Statutes, by failing to timely report changes in the bank information contained in their application. 11. The Office conducted an examination (Examination number 110542) of Respondents’ business records and operations for the period of April 1, 2020 through March 31, 2022 (“examination period”). 12. Respondents produced, or attempted to produce, specified documents in response to the Office’s various records requests throughout the examination. Pursuant to section 560.1105, Florida Statutes, Respondents are required to maintain all information necessary for determining compliance with chapter 560 and related rules for 5 years. Therefore, all the payment instruments and business records referenced here were not only in Respondents’ possession and control during the examination period, but Respondents are under a legal obligation to possess and continue to maintain the subject records pursuant to section 560.1105, Florida Statutes. 13. During the examination period, Respondents cashed 27,922 payment instruments with a total face value of $14,553,611 and collected $412,721 in check cashing fees. 14. There were 449 payment instruments reviewed for compliance, 427 of which were for over $1,000. They were selected from two sources: the check cashing database (“CCDB”) and Respondents’ check cashing software. Of the 138 requested and reviewed from Respondents’

4 check cashing software, 2 were not required as duplicates or non-check cashing transactions. The remaining 136 are identified below by the date the check was cashed and the amount of the check. Cashed On Check Amount 3/11/2021 $16,438.24 10/6/2020 $10,507.90 9/11/2020 $10,200.00 3/10/2022 $9,999.99 12/8/2021 $9,750.00 11/8/2021 $8,292.34 3/13/2021 $8,258.11 1/24/2022 $8,171.29 10/7/2020 $8,128.30 4/14/2020 $8,074.04 1/19/2022 $7,901.03 9/18/2020 $7,702.99 3/3/2021 $7,682.00 1/14/2022 $7,654.00 3/13/2021 $6,820.00 3/9/2022 $6,737.00 1/28/2022 $6,654.36 6/25/2020 $6,600.00 5/11/2021 $6,330.61 7/2/2021 $6,096.45 3/12/2021 $6,088.33 5/15/2020 $6,027.69 4/27/2020 $6,000.00 6/27/2020 $6,000.00 8/4/2020 $5,940.00 3/10/2021 $5,932.02 1/20/2022 $5,908.00 8/3/2021 $5,827.68 4/7/2020 $5,819.96 4/5/2021 $5,654.98 4/13/2021 $5,600.00 3/10/2021 $5,586.10 7/6/2020 $5,424.69 3/10/2021 $5,405.57 3/7/2022 $5,280.15 6/29/2021 $5,259.05 6/17/2020 $5,171.81

5 9/7/2021 $5,142.40 3/23/2021 $5,130.21 3/26/2021 $5,102.05 11/20/2020 $4,900.00 8/14/2020 $4,860.00 9/15/2020 $4,860.00 1/19/2022 $4,762.37 3/10/2021 $4,757.52 12/4/2020 $4,610.61 1/31/2022 $4,537.56 5/7/2021 $4,500.00 3/22/2021 $4,344.44 6/12/2020 $4,320.00 4/23/2021 $4,299.17 9/28/2020 $4,286.14 1/8/2021 $4,276.64 4/9/2021 $4,200.00 4/3/2021 $4,200.00 4/5/2021 $4,200.00 3/27/2021 $4,200.00 5/11/2021 $4,200.00 5/11/2021 $4,200.00 11/9/2021 $4,063.97 11/13/2020 $4,000.00 2/19/2021 $4,000.00 1/27/2022 $4,000.00 4/3/2020 $3,976.79 2/25/2022 $3,910.74 11/5/2021 $3,832.33 2/18/2022 $3,780.00 8/4/2020 $3,780.00 7/9/2021 $3,700.00 8/4/2020 $3,600.00 2/4/2022 $3,600.00 3/15/2021 $3,581.05 1/9/2021 $3,538.70 1/28/2022 $3,517.84 1/31/2022 $3,517.84 7/27/2020 $3,408.00 3/16/2021 $3,402.00 3/30/2021 $3,368.58

6 3/31/2021 $3,353.05 6/25/2021 $3,348.56 11/9/2021 $3,338.34 7/2/2021 $3,321.85 7/31/2021 $3,321.85 8/30/2021 $3,321.85 11/30/2021 $3,321.85 10/30/2020 $3,320.00 5/28/2021 $3,250.00 5/29/2020 $3,240.00 6/27/2020 $3,240.00 9/24/2021 $3,217.66 5/1/2020 $3,200.00 9/18/2020 $3,198.48 3/4/2022 $3,182.00 3/25/2021 $3,174.05 1/14/2022 $3,166.13 7/31/2020 $3,165.39 3/31/2021 $3,154.00 6/26/2020 $3,120.16 4/14/2020 $3,015.00 5/16/2020 $3,000.00 6/12/2020 $3,000.00 4/10/2020 $2,324.27 1/13/2021 $2,146.71 9/8/2020 $2,143.90 9/20/2021 $2,004.00 10/21/2020 $2,000.00 6/29/2020 $1,869.72 11/8/2021 $1,827.86 5/28/2021 $1,795.00 10/11/2021 $1,757.21 5/2/2020 $1,700.00 12/23/2021 $1,581.00 12/23/2021 $1,570.85 10/12/2020 $1,567.08 2/8/2022 $1,548.17 10/22/2021 $1,524.85 8/11/2020 $1,516.60 3/7/2022 $888.11 6/24/2021 $868.02

7 6/9/2021 $800.00 6/14/2021 $780.00 4/7/2020 $728.88 4/10/2020 $709.44 6/14/2021 $640.00 6/24/2021 $620.04 6/9/2021 $620.00 5/4/2020 $600.00 5/4/2020 $600.00 4/3/2020 $590.00 4/10/2020 $518.81 4/3/2020 $455.92 4/7/2020 $375.00 5/4/2020 $207.00 6/24/2021 $153.99 6/24/2021 $153.99 6/24/2021 $153.99 15. The remaining 311 transactions were sampled from the CCDB and are listed below, with transaction number, transaction date, check order, actual total number of checks, actual total transaction amount, and payment instrument amount. Transaction Number Transaction Date Check Order Actual Total Number of Checks Actual Total Transaction Amount Payment Instrument Amount 6358891 5/15/2021 $4,200.00 $4,200.00 7116227 12/30/2021 $9,500.00 $9,500.00 5938575 3/1/2021 $5,926.38 $5,926.38 5980530 3/9/2021 $4,437.05 $4,437.05 6210680 4/9/2021 $5,600.00 $5,600.00 6359350 5/16/2021 $4,200.00 $4,200.00 7570966 2/22/2022 1 1 $4,195.14 $4,195.14 5983292 3/3/2021 $4,190.00 $4,190.00 5992011 3/19/2021 $6,020.05 $6,020.05 7094659 11/10/2021 $3,300.00 $3,300.00 5047864 6/6/2020 1 1 $8,954.51 $8,954.51 5005338 5/26/2020 1 1 $3,400.00 $3,400.00 5787236 12/22/2020 1 1 $3,452.32 $3,452.32 5366016 8/26/2020 1 1 $4,651.52 $4,651.52 5328112 8/7/2020 1 1 $8,945.42 $8,945.42

8 4972438 5/19/2020 1 1 $3,715.84 $3,715.84 7513579 3/28/2022 1 1 $8,539.60 $8,539.60 7116018 12/3/2021 $15,562.00 $15,562.00 6424330 6/2/2021 $4,200.00 $4,200.00 5983295 3/3/2021 $4,147.10 $4,147.10 5787244 12/28/2020 1 1 $4,890.00 $4,890.00 5938618 2/25/2021 $3,597.05 $3,597.05 6245861 4/28/2021 $5,403.54 $5,403.54 6850693 10/19/2021 $4,638.00 $4,638.00 5023057 6/7/2020 1 1 $3,600.00 $3,600.00 5570725 8/3/2020 1 1 $7,228.12 $7,228.12 6359302 5/17/2021 $5,600.00 $5,600.00 6245892 4/28/2021 $3,232.16 $3,232.16 7513610 3/25/2022 1 1 $5,611.00 $5,611.00 5664585 11/17/2020 1 1 $6,128.00 $6,128.00 5664589 11/17/2020 1 1 $3,520.25 $3,520.25 5278781 6/20/2020 1 1 $5,856.00 $5,856.00 7513571 3/29/2022 1 1 $8,379.05 $8,379.05 7097244 12/1/2021 $20,000.00 $20,000.00 6555920 7/12/2021 $4,200.00 $4,200.00 4957980 5/16/2020 1 2 $4,395.00 $3,000.00 7116060 12/7/2021 $10,000.00 $10,000.00 7094662 11/10/2021 $6,490.00 $6,490.00 4886568 4/27/2020 1 1 $3,400.00 $3,400.00 5047614 6/10/2020 1 1 $3,600.00 $3,600.00 7571236 2/23/2022 1 1 $8,588.27 $8,588.27 6808705 10/7/2021 $4,000.00 $4,000.00 5983293 3/3/2021 $6,366.05 $6,366.05 5980644 3/9/2021 $5,766.18 $5,766.18 4972769 5/22/2020 1 1 $3,000.00 $3,000.00 5630069 11/20/2020 1 1 $3,000.00 $3,000.00 4737619 4/16/2020 1 1 $4,413.10 $4,413.10 6424303 5/24/2021 $6,107.45 $6,107.45 6808747 10/13/2021 $3,058.51 $3,058.51 7604888 3/19/2022 1 1 $6,862.10 $6,862.10 6182075 4/12/2021 $5,600.00 $5,600.00 6279940 4/23/2021 $6,300.00 $6,300.00 6531265 7/14/2021 $4,394.47 $4,394.47 5983276 3/4/2021 $7,692.00 $7,692.00 5938576 2/16/2021 $5,414.00 $5,414.00 7094680 11/11/2021 $5,000.00 $5,000.00

9 5889469 2/5/2021 $3,000.00 $3,000.00 5047679 6/9/2020 1 1 $3,600.00 $3,600.00 6179218 4/12/2021 $5,600.00 $5,600.00 6424605 6/21/2021 $4,664.44 $4,664.44 5333403 7/27/2020 1 1 $5,400.00 $5,400.00 4976069 5/19/2020 1 1 $3,600.00 $3,600.00 6245113 5/1/2021 $9,147.10 $9,147.10 6322135 5/10/2021 $7,000.00 $7,000.00 7570800 3/7/2022 1 1 $5,590.05 $5,590.05 6556135 7/30/2021 $3,420.00 $3,420.00 6486543 7/1/2021 $4,500.00 $4,500.00 6484197 6/24/2021 $4,500.00 $4,500.00 6671790 7/22/2021 $5,000.00 $5,000.00 5588592 11/3/2020 1 1 $4,950.00 $4,950.00 7513544 3/30/2022 1 1 $4,900.05 $4,900.05 7570928 2/18/2022 1 1 $3,300.00 $3,300.00 7570952 2/14/2022 1 1 $3,600.00 $3,600.00 4958222 5/13/2020 1 1 $3,735.00 $3,735.00 4945523 5/7/2020 1 1 $3,900.00 $3,900.00 5297505 7/23/2020 1 1 $5,580.00 $5,580.00 4737436 4/9/2020 1 1 $5,645.00 $5,645.00 6850606 10/27/2021 $4,200.00 $4,200.00 5630039 12/1/2020 1 1 $43,709.97 $43,709.97 5328119 8/7/2020 1 1 $5,000.00 $5,000.00 4737637 4/15/2020 1 1 $4,802.90 $4,802.90 6424820 6/18/2021 $8,095.03 $8,095.03 6424567 6/21/2021 $4,444.89 $4,444.89 7602333 3/22/2022 1 1 $6,807.16 $6,807.16 6178216 4/3/2021 $4,200.00 $4,200.00 6153364 4/3/2021 $4,200.00 $4,200.00 6196060 4/10/2021 $4,200.00 $4,200.00 5023059 6/7/2020 1 1 $3,000.00 $3,000.00 5699750 12/19/2020 1 1 $3,500.00 $3,500.00 5935515 2/23/2021 $4,672.10 $4,672.10 5787234 12/22/2020 1 1 $7,269.99 $7,269.99 5876559 1/14/2021 $5,911.15 $5,911.15 6850611 10/26/2021 $3,176.00 $3,176.00 7118456 12/13/2021 $5,855.13 $5,855.13 6147818 4/2/2021 $4,200.00 $4,200.00 5935486 2/24/2021 $5,818.10 $5,818.10 5570601 11/7/2020 1 1 $5,400.00 $5,400.00

10 6147879 4/3/2021 $4,200.00 $4,200.00 5545575 10/23/2020 1 1 $13,250.00 $13,250.00 6196083 4/10/2021 $4,200.00 $4,200.00 6373705 5/25/2021 $5,871.48 $5,871.48 6203511 4/5/2021 $4,200.00 $4,200.00 5023099 6/6/2020 1 1 $3,240.00 $3,240.00 5254177 7/17/2020 1 1 $7,800.00 $7,800.00 5884424 2/8/2021 $4,472.33 $4,472.33 5630045 11/9/2020 1 1 $10,200.00 $10,200.00 4945482 5/7/2020 1 1 $7,246.00 $7,246.00 5980650 3/8/2021 $8,546.70 $8,546.70 5076976 6/17/2020 1 1 $5,400.00 $5,400.00 4949402 5/11/2020 1 1 $3,715.71 $3,715.71 5983286 3/3/2021 $6,622.10 $6,622.10 5278760 7/21/2020 1 1 $4,550.00 $4,550.00 6203505 4/5/2021 $5,600.00 $5,600.00 5935534 2/20/2021 $3,942.66 $3,942.66 4719462 4/6/2020 1 1 $5,250.00 $5,250.00 6782756 9/29/2021 $7,202.28 $7,202.28 6373777 5/25/2021 $4,200.00 $4,200.00 6206835 4/13/2021 $5,600.00 $5,600.00 4886901 4/28/2020 1 1 $4,711.00 $4,711.00 7118549 11/18/2021 $3,510.00 $3,510.00 6359264 5/18/2021 $4,956.48 $4,956.48 5297612 7/22/2020 1 1 $4,000.00 $4,000.00 7124223 12/9/2021 $3,000.00 $3,000.00 5297449 7/24/2020 1 1 $3,305.56 $3,305.56 6280212 4/27/2021 $4,220.00 $4,220.00 7513694 3/3/2022 1 1 $3,423.00 $3,423.00 4930392 5/2/2020 1 1 $3,400.00 $3,400.00 6491738 7/7/2021 $4,200.00 $4,200.00 5125308 7/3/2020 1 1 $6,000.00 $6,000.00 5491794 9/30/2020 1 1 $3,360.00 $3,360.00 6245178 5/1/2021 $3,321.85 $3,321.85 6290405 5/5/2021 $17,625.75 $17,625.75 6178233 4/3/2021 $4,200.00 $4,200.00 6245871 4/28/2021 $3,217.16 $3,217.16 7571229 2/23/2022 1 1 $5,546.49 $5,546.49 6359131 5/12/2021 $4,430.00 $4,430.00 6671638 8/2/2021 $4,000.00 $4,000.00 7118431 11/12/2021 $4,400.00 $4,400.00

11 5570617 11/3/2020 1 1 $3,838.27 $3,838.27 6808834 10/16/2021 $5,646.75 $5,646.75 7570697 11/6/2021 $3,400.00 $3,400.00 5694760 12/15/2020 1 1 $3,000.00 $3,000.00 6293228 5/7/2021 $4,500.00 $4,500.00 5468735 10/8/2020 1 1 $3,300.00 $3,300.00 4972433 5/19/2020 1 1 $4,882.00 $4,882.00 7602216 3/16/2022 1 1 $8,589.05 $8,589.05 5324903 8/17/2020 1 1 $4,860.00 $4,860.00 5125302 7/3/2020 1 1 $6,928.88 $6,928.88 6322222 4/6/2021 $4,200.00 $4,200.00 5327570 8/8/2020 1 1 $4,320.00 $4,320.00 5664594 11/16/2020 1 1 $3,000.00 $3,000.00 5047796 6/5/2020 1 1 $7,620.00 $7,620.00 6132284 4/5/2021 $4,200.00 $4,200.00 6358053 4/6/2021 $4,200.00 $4,200.00 6293235 5/6/2021 $7,424.36 $7,424.36 6556216 6/22/2021 $9,000.00 $9,000.00 6785407 8/27/2021 $4,694.32 $4,694.32 5253927 7/16/2020 1 1 $3,780.00 $3,780.00 6245280 4/30/2021 $5,142.25 $5,142.25 6322365 4/6/2021 $5,600.00 $5,600.00 6359358 5/15/2021 $8,743.70 $8,743.70 5365950 8/27/2020 1 1 $3,200.00 $3,200.00 6206933 4/22/2021 $4,161.49 $4,161.49 6424006 6/15/2021 $4,198.71 $4,198.71 6206813 4/13/2021 $4,200.00 $4,200.00 7097226 12/1/2021 $3,375.00 $3,375.00 4719463 4/6/2020 1 1 $6,666.67 $6,666.67 7605000 2/25/2022 1 1 $4,059.05 $4,059.05 6147822 4/3/2021 $4,200.00 $4,200.00 6003006 3/17/2021 $4,001.05 $4,001.05 5305711 8/15/2020 1 1 $6,330.00 $6,330.00 5980713 3/4/2021 $4,867.00 $4,867.00 5555175 11/1/2020 1 1 $3,240.00 $3,240.00 5053260 5/29/2020 1 1 $6,138.00 $6,138.00 7124384 11/2/2021 $6,258.90 $6,258.90 7570792 3/7/2022 1 1 $9,999.99 $9,999.99 5935493 2/24/2021 $9,860.10 $9,860.10 4949288 5/12/2020 1 1 $7,531.00 $7,531.00 6359289 5/17/2021 $4,189.71 $4,189.71

12 4737662 4/14/2020 1 1 $3,124.00 $3,124.00 6358624 4/7/2021 $4,200.00 $4,200.00 6561303 7/28/2021 $6,500.00 $6,500.00 5278765 7/21/2020 1 1 $19,733.10 $19,733.10 4949410 5/11/2020 1 1 $3,400.00 $3,400.00 5005352 5/26/2020 1 1 $7,620.00 $7,620.00 5389690 9/9/2020 1 1 $4,800.00 $4,800.00 4945542 5/9/2020 1 1 $3,400.00 $3,400.00 5935525 2/22/2021 $5,291.00 $5,291.00 5278861 7/14/2020 1 1 $5,400.00 $5,400.00 7605177 2/24/2022 1 1 $4,981.05 $4,981.05 5305357 8/12/2020 1 1 $4,140.00 $4,140.00 4975972 5/21/2020 1 1 $4,140.00 $4,140.00 5327588 8/9/2020 1 1 $3,700.00 $3,700.00 4937665 5/5/2020 1 1 $3,581.00 $3,581.00 7097196 12/7/2021 $3,636.56 $3,636.56 6206939 4/22/2021 $6,463.00 $6,463.00 5342404 8/21/2020 1 1 $3,240.00 $3,240.00 5053506 6/1/2020 1 1 $8,323.00 $8,323.00 6648457 8/17/2021 $3,369.02 $3,369.02 6671762 7/26/2021 $8,626.00 $8,626.00 6132396 4/5/2021 $4,200.00 $4,200.00 5278876 6/12/2020 1 1 $3,600.00 $3,600.00 6196068 4/10/2021 $1,150.00 $1,150.00 5889422 2/6/2021 $1,205.00 $1,205.00 6491737 7/7/2021 $4,200.00 $4,200.00 6688283 9/7/2021 $4,173.75 $4,173.75 6789920 9/20/2021 $4,173.75 $4,173.75 6789927 9/20/2021 $4,173.75 $4,173.75 6829775 9/14/2021 $4,173.75 $4,173.75 5184470 7/10/2020 1 1 $5,106.30 $5,106.30 4719471 4/6/2020 1 1 $5,162.10 $5,162.10 4911852 4/17/2020 1 1 $10,192.05 $10,192.05 6850614 10/26/2021 $3,000.00 $3,000.00 4972427 5/19/2020 1 1 $4,076.00 $4,076.00 5787326 1/5/2021 $4,047.37 $4,047.37 6358652 4/7/2021 $4,200.00 $4,200.00 6850671 10/20/2021 $5,985.50 $5,985.50 6203501 4/5/2021 $4,200.00 $4,200.00 5983288 3/3/2021 $4,028.05 $4,028.05 5570672 10/30/2020 1 1 $3,579.39 $3,579.39

13 6210649 4/17/2021 $4,200.00 $4,200.00 5053462 6/1/2020 1 1 $4,320.00 $4,320.00 5278844 7/14/2020 1 1 $3,015.00 $3,015.00 6627542 8/13/2021 $3,215.00 $3,215.00 6790147 9/15/2021 $3,215.00 $3,215.00 5992006 3/19/2021 $11,928.05 $11,928.05 6212923 4/9/2021 $12,600.00 $12,600.00 6245102 5/1/2021 $1,167.00 $1,167.00 6561349 7/28/2021 $6,669.99 $6,669.99 6850791 10/30/2021 $3,321.85 $3,321.85 6358443 5/31/2021 $3,321.85 $3,321.85 7118461 12/13/2021 $3,078.25 $3,078.25 6561785 7/31/2021 $3,321.85 $3,321.85 6782785 10/1/2021 $3,321.85 $3,321.85 6829762 8/30/2021 $3,321.85 $3,321.85 4911497 5/1/2020 1 1 $3,916.00 $3,916.00 5980690 3/5/2021 $5,710.05 $5,710.05 5119459 6/24/2020 1 1 $3,773.35 $3,773.35 7513540 3/30/2022 1 1 $10,000.00 $10,000.00 7094705 12/21/2021 $3,400.00 $3,400.00 6212988 4/9/2021 $4,200.00 $4,200.00 6206965 4/22/2021 $4,651.33 $4,651.33 5125268 7/4/2020 1 1 $7,200.00 $7,200.00 7605137 2/25/2022 1 1 $1,184,075.00 $1,184,075.00 4865772 4/24/2020 1 1 $1,395.00 $1,395.00 5249029 7/16/2020 1 1 $3,000.00 $3,000.00 6179107 4/13/2021 $4,973.15 $4,973.15 5983279 3/4/2021 $9,254.05 $9,254.05 7094631 12/24/2021 $3,000.00 $3,000.00 5787899 12/29/2020 1 1 $3,000.00 $3,000.00 6358450 5/29/2021 $4,200.00 $4,200.00 5876528 2/1/2021 $5,202.10 $5,202.10 5664459 11/19/2020 1 1 $6,139.50 $6,139.50 6244944 5/4/2021 $7,799.52 $7,799.52 4937639 5/5/2020 1 1 $9,395.04 $9,395.04 6358086 4/6/2021 $4,200.00 $4,200.00 7604902 3/18/2022 1 1 $6,939.99 $6,939.99 6147815 4/3/2021 $4,200.00 $4,200.00 5297622 7/22/2020 1 1 $7,020.00 $7,020.00 6178223 4/3/2021 $4,200.00 $4,200.00 5980687 3/6/2021 $5,653.25 $5,653.25

14 7571240 2/23/2022 1 1 $3,066.05 $3,066.05 5297501 7/23/2020 1 1 $3,059.13 $3,059.13 6424321 6/2/2021 $4,406.54 $4,406.54 5935508 2/24/2021 $3,500.00 $3,500.00 7513737 3/13/2022 1 1 $3,076.15 $3,076.15 6358148 4/6/2021 $4,200.00 $4,200.00 6210510 4/8/2021 $4,200.00 $4,200.00 6179194 4/12/2021 $4,200.00 $4,200.00 5253909 7/16/2020 1 1 $3,984.00 $3,984.00 5249035 7/16/2020 1 1 $3,984.00 $3,984.00 4866605 4/25/2020 1 1 $3,900.00 $3,900.00 5983314 3/2/2021 $9,302.00 $9,302.00 6413214 5/22/2021 $8,663.19 $8,663.19 5254187 7/17/2020 1 1 $5,795.14 $5,795.14 6153335 4/3/2021 $4,200.00 $4,200.00 5366012 8/27/2020 1 1 $7,200.00 $7,200.00 5468660 10/12/2020 1 1 $5,510.36 $5,510.36 6358992 5/13/2021 $3,041.03 $3,041.03 5795338 1/8/2021 $3,000.00 $3,000.00 6782845 10/4/2021 $3,245.64 $3,245.64 6491758 7/3/2021 $3,086.46 $3,086.46 5555086 11/2/2020 1 1 $10,000.00 $10,000.00 5983294 3/3/2021 $7,603.61 $7,603.61 5125246 6/22/2020 1 1 $3,000.00 $3,000.00 5884546 2/8/2021 $6,377.71 $6,377.71 5980646 3/8/2021 $3,585.38 $3,585.38 4887078 4/27/2020 1 1 $4,400.00 $4,400.00 5184390 7/13/2020 1 1 $6,630.00 $6,630.00 6392132 5/20/2021 $5,513.72 $5,513.72 7124155 11/22/2021 $5,558.85 $5,558.85 6688289 9/4/2021 $3,120.00 $3,120.00 7094701 12/22/2021 $4,222.51 $4,222.51 5630050 11/10/2020 1 1 $4,320.00 $4,320.00 4958200 5/14/2020 1 1 $5,706.00 $5,706.00 4798463 4/24/2020 1 1 $3,000.00 $3,000.00 5983284 3/4/2021 $3,054.81 $3,054.81 6648558 8/5/2021 $25,000.00 $25,000.00 5462528 9/21/2020 1 1 $15,201.00 $15,201.00 4719481 4/7/2020 1 1 $3,000.00 $3,000.00 6671594 7/20/2021 $10,000.00 $10,000.00 4911956 4/29/2020 1 1 $8,289.00 $8,289.00

15 6322620 4/6/2021 $4,200.00 $4,200.00 6245006 5/3/2021 $4,533.97 $4,533.97 5694744 12/15/2020 1 1 $6,000.00 $6,000.00 5630075 11/20/2020 1 1 $4,900.00 $4,900.00 5787254 12/24/2020 1 1 $9,583.47 $9,583.47 7570773 3/5/2022 1 1 $9,062.22 $9,062.22 5389695 9/9/2020 1 1 $3,100.00 $3,100.00 5297460 7/24/2020 1 1 $6,000.00 $6,000.00 3/19/2021 $6,862.10 $6,862.10 16. The Office also reviewed the records for financial transaction for which Respondents were required to submit Currency Transaction Reports (“CTRs”). Those are listed below with the transaction number, transaction date, payment instrument amount, and the currency amount that was provided by Respondents to the customer. Transaction Number Transaction Date Payment Instrument Amount Currency Amount Provided 5630039 12/1/2020 $43,709.97 $41,524.74 6648558 8/5/2021 $25,000.00 $23,750.00 7097244 12/1/2021 $20,000.00 $19,000.00 5278765 7/21/2020 $19,733.10 $18,746.45 6290405 5/5/2021 $17,625.75 $16,744.46 3/11/2021 $16,438.24 $15,616.00 7116018 12/3/2021 $15,562.00 $14,783.90 5462528 9/21/2020 $15,201.00 $14,744.99 5545575 10/23/2020 $13,250.00 $12,587.50 6212923 4/9/2021 $12,600.00 $12,222.00 5992006 3/19/2021 $11,928.05 $11,331.65 10/6/2020 $10,507.90 $10,507.90 7570792 3/7/2022 $9,999.99 $9,499.99 3/7/2022 $888.11 $843.70 17. Additionally, the Office reviewed the 2 corporate customer files that Respondents were required to maintain during the examination period. 18. As part of the examination, Respondents met with the Office for both an entrance

16 conference on July 20, 2022, and an exit conference on January 9, 2023. After the examination was concluded, Respondents were sent a letter dated January 10, 2023, attaching the Report of Examination. The letter specifically requested that Respondents “review the report and provide a written response to the [Office] within fifteen (15) business days.” The letter further informed Respondents that their written response “may include advising the Office of any exceptions or disagreements with the report, any actions taken to correct the possible violations, and any mitigating circumstances you would like us to consider that might reflect the need for a lesser sanction in the event a violation has occurred.” 19. The Report of Examination identified potential violations of the specific statutory provisions of chapter 560, Florida Statutes, and the accompanying rules of the Florida Administrative Code. For each finding, the Report of Examination also briefly stated how Respondents violated the applicable statute and/or rule. 20. Pursuant to Rule 69V-560.1000(5), Florida Administrative Code, the range for an “A” level fine is between $1,000 and $3,500. 21. Pursuant to Rule 69V-560.1000(5), Florida Administrative Code, the range for a “B” level fine is between $3,500 and $7,500. 22. Pursuant to Rule 69V-560.1000(5), Florida Administrative Code, the range for a “C” level fine is between $7,500 and $10,000. 23. Pursuant to section 560.114(1)(a), Florida Statutes, each money services business and its affiliated parties must comply with all provisions of chapter 560, Florida Statutes, and the Office may revoke a money services business license for failure to comply. COUNT I 24. Pursuant to section 560.310(2)(d), Florida Statutes, when payment instruments

17 (“checks”) over $1,000 are cashed, licensees are required to submit certain information into the check cashing database (“CCDB”) before providing currency to the person cashing the check. 25. Pursuant to section 560.310(2)(d), Florida Statutes, and Rule 69V-560.704(5), Florida Administrative Code, among the information required to be submitted into the CCDB are the following: • Transaction date; • Payor name; • Payee name; • Conductor’s name; • Payment instrument amount; • Amount of currency provided; • Payment instrument type; • Check cashing fee; • Branch or location where the check was accepted; • Personal identification type and number presented by payee or conductor; • Payee’s workers’ compensation policy number or exemption certificate number; • Payee’s Corporate Document Number issued by the Secretary of State; and, • Payee’s Federal Employee Identification Number. 26. As part of its examination, and as detailed in the General Allegations above, the Office reviewed records for 446 payment instruments that were required to be submitted into the CCDB. 27. The Office found that 446 of the 446 (100%) transactions were not timely submitted into the CCDB. Of the transactions that were submitted late (but before the examination), a substantial number were also inaccurate. The table below details the type and number of the deficiencies noted.

18 28. During the examination period, Respondents failed to timely enter required information into the CCDB and entered inaccurate information into the CCDB, in violation of section 560.310(2)(d), Florida Statutes, and Rule 69V-560.704(5), Florida Administrative Code. 29. On July 18, 2017, Final Order 69412 was entered by the Office finding that Respondents had violated section 560.310(2)(d), Florida Statutes, and Rule 69V-560.704(5), Florida Administrative Code, by failing to submit complete and accurate information to the check cashing database (CCDB). 30. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 96, a licensee cited for a second violation of section 560.310(2)(d), Florida Statutes, is subject to a “B” level administrative fine and revocation of license. 31. Pursuant to Rule 69V-560-1000(3)(b), Florida Administrative Code, the Office shall consider certain aggravating factors when determining whether a deviation from the range of penalties in the disciplinary guidelines is warranted. 32. Therefore, the Office is seeking an administrative fine of $9,375 and revocation of license.

19 COUNT II 33. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 34. Pursuant to section 560.123(3), Florida Statutes, licensees are required to keep a record of financial transactions involving currency or checks having a value greater than $10,000, and to maintain appropriate procedures to ensure compliance with this section. 35. Pursuant to section 560.123(3)(a), Florida Statutes, multiple financial transactions shall be treated as a single transaction if they are made by or on behalf of any one person and result in cash in or cash out totaling more than $10,000 during any day. 36. Pursuant to section 560.123(3)(c), Florida Statutes, money services businesses are required to file reports of such transactions as required by rule. 37. Pursuant to Rule 69V-560.608, Florida Administrative Code, money services businesses are required to file Currency Transaction Reports (“CTRs”) with the Financial Crimes Enforcement Network, United States Department of Treasury (“FinCEN”) using FinCEN Form 112, incorporated by reference in Rule 69V-560.1012, Florida Administrative Code, no later than the 15th calendar day after the transaction. 38. As part of its examination, and as detailed in the General Allegations above, the Office reviewed the records for 12 financial transactions for which Respondents were required to file CTRs during the examination period. 39. The Office found that, for 2 of those 12 transactions (16%), no CTRs were timely filed by Respondents. The details of these 2 transactions are:

20 40. Respondents failed to timely file CTRs, in violation of section 560.123(3)(c), Florida Statutes and Rule 69V-560.608, Florida Administrative Code. 41. On July 18, 2017, Final Order 69412 was entered by the Office finding that Respondents had violated section 560.123(3)(c), Florida Statutes, and Rule 69V-560.608, Florida Administrative Code, by failing to timely and accurately file all CTRs. 42. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR-560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 34, a licensee cited for a second violation of section 560.123(3)(c), Florida Statutes, is subject to a “B” level administrative fine and revocation of license. 43. Therefore, the Office is seeking an administrative fine of $4,200 and revocation of license. COUNT III 45. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 46. Pursuant to section 560.103(11), Florida Statutes, a “corporate payment instrument” is a payment instrument where the payee named on the check’s face is other than a natural person. 47. Pursuant to section 560.310(2)(a), Florida Statutes, licensees are required to create and maintain a customer file for each entity listed as the payee on corporate checks

21 accepted by the licensee that exceed $1,000. 48. Pursuant to Rule 69V-560.704(4)(d), Florida Administrative Code, each customer file must include the following information: ▪ Documentation from the Secretary of State (so-called “SUNBIZ”) verifying registration as a corporation showing the listed officers and FEID registration number; ▪ Articles of Incorporation or other such documentation which establishes a legal entity in whatever form authorized by law. For purposes of this rule a sole proprietor operating under a fictitious name registered with the Secretary of State shall not have to present such documentation; ▪ Documentation of the business license/occupational license, business tax receipt, or its equivalent from the county where the entity is located; ▪ A copy of the search results screen page from Compliance Proof of Coverage Query Page webpage from the Florida Department of Financial Services – Division of Workers’ Compensation website (https://dwcdataportal.fldfs.com/ProofOfCoverage.aspx); ▪ If the entity has an active workers’ compensation policy, the licensee must also maintain a copy of the policy declaration page or other document provided by the insurer indicating the amount of coverage; ▪ Documentation of individuals authorized to negotiate payment instruments on the corporation or fictitious entity’s behalf including corporate resolutions; and, ▪ A written corporate customer profile which includes: the full legal name of each beneficial owner, as defined in 31 C.F.R. s. 1010.230(d), effective July 1, 2018, is hereby incorporated by reference and available at http://www.flrules.org/Gateway/reference.asp?No=Ref￾11464, of the corporate customer; an explanation of the customer’s business model; type(s) of services offered; projected annual volume of check cashing; and annual check cashing limits as they relate to the corporate customer’s workers’ compensation policy coverage limits. 49. As part of its examination, and as detailed in the General Allegations above, the Office reviewed a sample of 427 checks over $1,000. The Office identified 2 checks payable to a corporation and therefore requiring Respondents to maintain a corporate customer file for each payee. 50. In response to the Office’s records request for these customer files, Respondents

22 signed a statement that “[a]fter a diligent search of all areas in which we maintain or store our books and records, I was unable to locate the books or records requested above and have no reasonable basis to believe that any other books or records exist that would provide such information.” 51. Respondents failed to maintain complete corporate customer files, in violation of section 560.310(2)(a), Florida Statutes, and Rule 69V-560.704(4)(d), Florida Administrative Code. 52. On July 18, 2017, Final Order 69412 was entered by the Office finding that Respondents had violated section 560.310(2)(a), Florida Statutes, and Rule 69V-560.704(4)(d), Florida Administrative Code, by failing to maintain complete customer files. 53. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR-560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 93, a licensee cited for a second violation of section 560.310(2)(a), Florida Statutes, is subject to a “B” level administrative fine and revocation of license. 54. Therefore, the Office is seeking an administrative fine of $7,500 and revocation of license. COUNT IV 55. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 56. Pursuant to sections 560.310(1) and 560.1105, Florida Statutes, and Rule 69V￾560.704(2)(a), Florida Administrative Code, a licensee engaged in check cashing must maintain a legible copy of the front and back of each payment instrument cashed for a period of 5 years.

23 57. As part of its examination, and as in the General Allegations above, the Office requested records for a sample of 446 of Respondents’ payment instruments cashed, including a copy of the front and back of each. 58. The Office found that Respondents did not maintain the required copies for 61 of the 446 (13%) checks. 59. In response to the Office’s records requests for these, Respondents signed statementsthat “[a]fter a diligent search of all areas in which we maintain or store our books and records, I was unable to locate the books or records requested above and have no reasonable basis to believe that any other books or records exist that would provide such information.” 60. Respondents failed to maintain legible copies of the front and back of each payment instrument cashed, in violation of sections 560.310(1) and 560.1105, Florida Statutes, and Rule 69V-560.704(2)(a), Florida Administrative Code. 61. Pursuant to the Disciplinary Guidelines for Money Services Businesses, Form OFR-560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2023), violation number 92, a licensee cited for violating section 560.310(1), Florida Statutes, is subject to an “A” level administrative fine and revocation of license. 62. Therefore, the Office is seeking an administrative fine of $1,300 and revocation of license. COUNT V 63. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 64. When checks exceeding $1,000 are cashed, section 560.310(2)(c), Florida Statutes, requires licensees to maintain records of customers’ thumbprints.

24 65. Pursuant to Rule 69V-560.704(4)(a), Florida Administrative Code, the check casher shall affix an original thumbprint of the conductor, which is taken at the time of acceptance, to the original of each payment instrument accepted. 66. As part of its examination, and as detailed in the General Allegations above, the Office reviewed a sample of 427 of Respondents’ check cashing transactions exceeding $1,000. 67. The Office found that for 41 of these 427 (9%) transactions, Respondents did not have a record of the customer’s original thumbprint, which was taken at the time the check was accepted, that was affixed to the original payment instrument. 68. In response to the Office’s records requests for the missing thumbprint records, Respondents signed statements that “[a]fter a diligent search of all areas in which we maintain or store our books and records, I was unable to locate the books or records requested above and have no reasonable basis to believe that any other books or records exist that would provide such information.” These are detailed below. 69. Respondents failed to maintain records of customers’ thumbprints, in violation of section 560.310(2)(c), Florida Statutes, and Rule 69V-560.704(4)(a), Florida Administrative Code.

25 70. On July 18, 2017, Final Order 69412 was entered by the Office finding that Respondents had violated section 560.310(2)(c), Florida Statutes, and Rule 69V-560.704(4)(a), Florida Administrative Code, by failing to maintain records of customers’ thumbprints. 71. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 95, a licensee cited for a second violation of section 560.310(2)(c), Florida Statutes, is subject to a “B” level administrative fine and revocation of license. 72. Therefore, the Office is seeking an administrative fine of $3,900 and revocation of license. COUNT VI 73. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 74. When a payment instrument of greater than $1,000 is cashed, section 560.310(2)(b), Florida Statutes, requires a licensee to maintain a legible copy of acceptable personal identification that bears a photograph of the customer. 75. Pursuant to section 560.310(2)(b), Florida Statutes, acceptable personal identification is limited to a valid driver license, a state identification card issued by any state of the United States or its territories or the District of Columbia and showing a photograph and signature, a United States Government Resident Alien Identification Card, a passport, or a United States Military identification card. 76. As part of its examination, and as detailed in the General Allegations above, the Office reviewed the records for 427 check cashing transactions over $1,000 that were included in the sample examined for compliance. The Office also reviewed copies of the personal

26 identification that had been presented by customers when they cashed those payment instruments, which the Office received from Respondents. 77. The Office found that for 32 of the 427 (7%) transactions, copies of valid and acceptable identifications were not maintained. 78. From its review of the CCDB, the Office found 27 instances in which valid and acceptable identifications were not maintained. Those are detailed below. Transaction Date Actual Total Transaction Amount Payment Instrument Amount Currency Amount Provided Conductor Id Type Description Comments 12/7/2021 $10,000.00 $10,000.00 $9,700.00 issued 01/25/2022 11/10/2021 $6,490.00 $6,490.00 $6,295.30 iss 01/25/2022 4/24/2020 $3,000.00 $3,000.00 $2,910.00 iss 07/21/2020 5/22/2020 $3,000.00 $3,000.00 $2,910.00 iss 07/21/2020 4/16/2020 $4,413.10 $4,413.10 $4,192.45 Iss after trans 12/13/2021 $3,078.25 $3,078.25 $2,985.90 iss 02/16/2022 5/13/2020 $3,735.00 $3,735.00 $3,622.95 exp 05/27/2019 3/3/2022 $3,423.00 $3,423.00 $3,251.85 exp 10/24/2021 12/13/2021 $5,855.13 $5,855.13 $5,562.37 exp 03/23/2020 11/7/2020 $5,400.00 $5,400.00 $5,238.00 iss 10/15/2021 4/3/2021 $4,200.00 $4,200.00 $4,074.00 iss 10/15/2021 7/22/2020 $4,000.00 $4,000.00 $3,880.00 iss 01/02/2021 4/15/2020 $4,802.90 $4,802.90 $4,562.75 missing id 4/6/2021 $4,200.00 $4,200.00 $4,074.00 exp 07/16/2020 4/6/2020 $6,666.67 $6,666.67 $6,333.34 iss 08/25/2020 11/1/2020 $3,240.00 $3,240.00 $3,142.00 exp 06/18/2020 2/22/2021 $5,291.00 $5,291.00 $5,026.45 ISS 05/24/2021 4/10/2021 $1,150.00 $1,150.00 $1,149.00 mexico voter card invalid ID TYPE 2/6/2021 $1,205.00 $1,205.00 $1,204.00 ALIEN ID invalid ID TYPE 5/1/2021 $1,167.00 $1,167.00 $1,166.00 foreign driver lic invalid ID TYPE 4/24/2020 $1,395.00 $1,395.00 $1,353.15 Florida ID iss 04/04/2022 7/16/2020 $3,000.00 $3,000.00 $2,910.00 issu 04/04/2022 7/16/2020 $3,984.00 $3,984.00 $3,846.48 missing id 7/3/2021 $3,086.46 $3,086.46 $2,993.87 iss 11/5/2021 3/8/2021 $3,585.38 $3,585.38 $3,477.82 iss 08/27/2021 4/7/2020 $3,000.00 $3,000.00 $2,910.00 issu 10/01/2020 12/24/2020 $9,583.47 $9,583.47 $9,391.00 exp 05/27/2018

27 79. From its review of Respondents’ software activity log, the Office found 5 additional instances in which valid and acceptable identifications were not maintained. Those are identified below. Cashed On Check Amount Comments 3/11/2021 $16,438.24 ID issued after 4/14/2020 $8,074.04 Exp 05/10/2019 1/19/2022 $4,762.37 Exp12/27/2021 7/31/2020 $3,165.39 illegible 5/16/2020 $3,000.00 ID issued after 80. Respondents failed to maintain records of valid and acceptable personal identifications, in violation of section 560.310(2)(b), Florida Statutes, and Rule 69V￾560.704(4)(c), Florida Administrative Code. 81. On July 18, 2017, Final Order 69412 was entered by the Office finding that Respondents had violated section 560.310(2)(b), Florida Statutes, and Rule 69V-560.704(4)(c), Florida Administrative Code, by failing to maintain records of legible, valid and acceptable personal identifications. 82. Pursuant to the Disciplinary Guidelines for Money Services Businesses, Form OFR-560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 94, a licensee cited for a second violation of section 560.310(2)(b), Florida Statutes, is subject to a “B” level administrative fine and revocation of license. 83. Therefore, the Office is seeking an administrative fine of $3,800 and revocation of license. COUNT VII 84. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein.

28 85. Pursuant to section 560.309(3), Florida Statutes, and Rule 69V-560.704(1)(b), Florida Administrative Code, a licensee must maintain and deposit payment instruments into its own commercial account in a federally insured financial institution, listing the licensee as the exclusive owner of the account. Any authorized signatory must have a controlling interest in the money services business. 86. As part of its examination, the Office reviewed records for all of Respondents’ bank accounts. 87. The Office found that Vernon Dixon (Respondent Dixon’s father) was an authorized signatory on Bank of America accounts ending in 3506 and 9690, both used by Respondents for registered activities. 88. The Office also reviewed Respondents’ last amended license application of May 31, 2017, and found that it does not list Vernon Dixon (Respondent Dixon’s father). 89. Respondents failed to maintain and deposit payment instruments into their own commercial account with only persons with a controlling interest in Respondents’ business as authorized signatories, in violation of section 560.309(3), Florida Statutes, and Rule 69V￾560.704(1)(b), Florida Administrative Code. 90. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 84, a licensee cited for violating section 560.309(3), Florida Statutes, is subject to a “B” level administrative fine and revocation of license. 91. Therefore, the Office is seeking an administrative fine of $3,500 and revocation of license.

29 COUNT VIII 92. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 93. Pursuant to section 560.126(2), Florida Statutes, and Rule 69V-560.102(5), Florida Administrative Code, a licensee must report any change in the information contained in their initial license application (or any amendments thereto) within 30 days of the change, by filing an amendment correcting such information using Form OFR-560-01, which is incorporated by reference in Rule 69V-560.1012, Florida Administrative Code. 94. Pursuant to Form OFR-560-01(7), applicants and licensees must provide a list of accounts through which registered activities are or will be conducted. 95. As part of the examination, the Office reviewed Respondents’ banking history, license application, and any amendments thereto. 96. The Office found that Respondents used Bank of America accounts ending in 3506 and 9690 for registered activities. 97. The Office also found that Respondents’ last amended license application of May 31, 2017 did not list Bank of America account ending in 9690, opened on July 11, 2011. 98. Respondents failed to report changes in the bank information contained in their application within 30 days of the changes, in violation of section 560.126(2), Florida Statutes, and Rule 69V-560.102(5), Florida Administrative Code. 99. On July 18, 2017, Final Order 69412 was entered by the Office finding that Respondents had violated section 560.126(2), Florida Statutes, by failing to timely report changes in the bank information contained in their application.

30 100. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 46, a licensee cited for a second violation of section 560.126(2), Florida Statutes, is subject to a “B” level administrative fine. 101. Therefore, the Office is seeking an administrative fine of $7,500. COUNT IX 102. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 103. Pursuant to section 560.114(1)(a), Florida Statutes, and Rule 69V-560.107(1)(a), Florida Administrative Code, every licensee that commences operations at a branch office shall file a completed Form OFR-560-02 (Location Notification Form). 104. Upon review of Respondents’ business records and their responses to records requests, the Office found that Respondents offer check cashing services at a branch at 2410 Avenue D. The Office also found that Respondents’ last amended license application of May 31, 2017 did not list any branch locations and that Form OFR-560-02 had not been filed. 105. Respondents failed to file a completed Form OFR-560-02 (Location Notification Form), incorporated by reference in Rule 69V-560.1012, Florida Administrative Code, upon commencement of operations at their branch office, in violation of Rule 69V-560.107(1)(a), Florida Administrative Code, and thereby section 560.114(1)(a), Florida Statutes. 106. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 2, a licensee cited for violating section 560.114(1)(a), Florida Statutes, is subject to an “A” level administrative fine and revocation of license.

31 107. Therefore, the Office is seeking an administrative fine of $3,500 and revocation of Respondents’ license. WHEREFORE, Respondents, BAKER’S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II are hereby notified that the Office intends to enter an Order imposing an administrative fine of $44,575 and revoking Baker’s Management Properties Inc., d/b/a as Down South Beverages & Check Cashing; Cartoon Car Wash, license number FT340000266. [this space intentionally left blank]

32 NOTICE OF RIGHTS The licensee is entitled to be represented by counsel or another qualified representative. The licensee also has the right to request a hearing pursuant to sections 120.569 and 120.57, Florida Statutes. Such request must comply with Rules 28-106.2015 and 28-106.104, Florida Administrative Code. An Election of Proceeding form is attached for your convenience. Any such request must be filed as follows: By Mail, Facsimile or Email OR By Hand Delivery Agency Clerk Agency Clerk Office of Financial Regulation Office of Financial Regulation Office of General Counsel Office of General Counsel P.O. Box 8050 The Fletcher Building, Suite 504 Tallahassee, FL 32314-8050 101 East Gaines Street Phone: (850) 410-9889 Tallahassee, FL 32399 Fax: (850) 410-9663 Phone: (850) 410-9889 Email: Agency.Clerk@flofr.gov TO PRESERVE THE RIGHT TO A HEARING, A WRITTEN RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION WITHIN TWENTY￾ONE (21) DAYS AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. SAID RESPONSE MUST BE RECEIVED BY THE OFFICE NO LATER THAN 5:00 P.M. ON THE TWENTY-FIRST DAY AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. A FAILURE TO TIMELY RESPOND IN WRITING WILL CONSTITUTE A WAIVER OF THE LICENSEE’S RIGHT TO REQUEST A HEARING AND A FINAL ORDER MAY BE ENTERED WITHOUT FURTHER NOTICE. You may not make an oral request for an administrative hearing. With regard to a written request, if you fail to follow the outlined procedure, your request may be dismissed. Any request for an administrative proceeding received prior to the date of this notice is deemed abandoned and to be considered, must be timely renewed in compliance with the procedure set forth above. Mediation of this matter pursuant to section 120.573, Florida Statutes, is not available.

33 NOTICE TO RESPONDENTS In accordance with the Americans with Disabilities Act, persons with disabilities needing 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, Suite 504, 200 East Gaines Street, Tallahassee, Florida 32399-0379, Phone: (850) 410-9889, or by Email: Agency.Clerk@flofr.gov. DATED and SIGNED this 18th day of July, 2025. By:___________________________ David J. Tarbert Fla. Bar No. 813966 Assistant General Counsel Office of Financial Regulation Office of General Counsel 1313 N. Tampa Street, S-617A Tampa, FL 33602 Tel: (813) 218-5340 Email:David.Tarbert@flofr.gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service via U.S. Certified Mail, Return Receipt Requested to Baker’s Management Properties Inc., d/b/a as Down South Beverages & Check Cashing; Cartoon Car Wash, and Vernon Dixon II, Registered Agent, at 216 Behring Way, Jupiter, FL 33458 and 420 N US #1, Fort Pierce, FL 34950 on this 18th day of July, 2025.

---

David J. Tarbert

June 3, 2025 EXHIBIT B

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STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION FECEIVED - FLORIDA iul I 5 20?5 Oficc of Financiat Regulation In Re: BAKER'S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, Case Number: I17846 Respondents. ADMINISTRATIVE COMPLAINT The State of Florida, Office of Financial Regulation ("Office"), files this Administrative Complaint against BAKER'S MAI\AGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, (together as "Respondents"), alleging: GENERAL ALLEGATIONS I . Pursuant to sections 560. 105 and 560. 109, Florida Statutes, the Office is charged with administering and enforcing the provisions of chapter 560, Florida Statutes, and conducting examinations and investigations to determine whether any provision of chapter 560, Florida Statutes. has been violated. 2. Pursuant to section 560.114(l)(a), Florida Statutes, failure to comply with any provision of chapter 560, Florida Statutes, or related rule. constitutes grounds for disciplinary action. 3. Parts II, III. and IV of chapter 560, Florida Statutes, set forth the specific requirements of money services businesses and licensees.

NOTICE TO RESPONDENTS In accordance with the Americans with Disabilities Act. persons with disabilities needing 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, Suite 504,200 East Gaines Street, Tallahassee, Florida 32399-0379, Phone: (850) 410-9889. or by Email: Agency.Clerk@)flofr.gov. DATED and SIGNED this 3'd day of June, 2025. David J. Tarbert Fla. Bar No. 813966 Assistant General Counsel Office of Financial Regulation Of fice of General Counsel l3l3 N. Tampa Street, 5-617A Tampa, FL 33602 Tel: (813) 218-5340 Emai I : David.Tarbert@)fl oli. gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the fbregoing Adrninistrative Complaint has been sent for service via U.S. Certifled Mail. Return Receipt Requested to Baker's Management Properties Inc., dlbla as Down South Beverages & Check Cashing; Caftoon Car Wash, and Vernon Dixon II, Registered Agent, al720 Delaware Avenue, Unit B, Fort Pierce. FL 34950 on this 3"rday ofJune, 2025 David.l. Tarbert 1r+81 U05D 00a? tha0 6L?e qb JJ By:

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NOTICE TO RESPONDENTS In accordance with the Americans with Disabilities Act, persons with disabilities needing 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, Suite 504, 200 East Gaines Street, Tallahassee, Florida 32399-03 79, Phone: (850) 410-9889, or by Email: Agency.Clerk@flofr.gov. DATED and SIGNED this 18th day of July, 2025. ))v'--·••· By: -- David J. Tarbert Fla. Bar No. 813966 Assistant General Counsel Office of Financial Regulation Office of General Counsel 1313 N. Tampa Street, S-617A Tampa, FL 33602 Tel: (813) 218-5340 Email:David.Tarbert@flofr.gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for serviceviaU.S. Certified Mail, Return Receipt Requested to Baker's Management Properties Inc., d/b/a as Down South Beverages & Check Cashing; Cartoon Car Wash, and Vernon Dixon II, Registered Agent, at 216 Behring Way, Jupiter, FL 33458 and 420 NUS #1, Fort Pierce, FL 34950 on this 18th day of July, 2025. David J. Tarbert 33

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RECEIVED . FLORIDA STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION Offioe of Financiat Flegulation In Re: BAKER'S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, Case Number: I17846 Respondents. ADMINISTRATIVE COMPLAINT The State of Florida. Office of Financial Regulation ("Office"). files this Administrative Complaint against BAKER'S MAI\AGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, (together as "Respondents"). al leging: GENERAL ALLEGATIONS I . Pursuant to sections 560.105 and 560.109, Florida Statutes, the Office is charged with administering and enforcing the provisions of chapter 560, Florida Statutes, and conducting examinations and investigations to determine whether any provision of chapter 560, Florida Statutes. has been violated. 2. Pursuant to section 560.1l4(l)(a), Florida Statutes, failure to comply with any provision of chapter 560, Florida Statutes, or related rule, constitutes grounds for disciplinary action. 3. Parts II. III, and IV of chapter 560, Florida Statutes, set forth the specific requirements of money services businesses and licensees. JUL 3 I 20?5

NOTICE TO RESPONDENTS ln accordancervith the Americanswith DisabilitiesAct. personswith disabilitiesneeding special accommodation to participate in this proceeding should contact the Agency' Clerk no later than seven (7) days prior to the li ling deadline or proceeding. at the Of flce of Financial Regulation, The Fletcher Building. Suite 504. 200 East Gaines Street. Tallahassec, Florida 32399-87q. Phone: (850) 410-9889" or by Email: Agency.CIerk@f1ofi.gov. DATED and SIGNED this lStr' day ot'July. 2025. By David J. Tarbert Fla. Bar No. 813966 Assistant General Counsel Ofl.ice of Financial Regulation Office of General Counsel l3 l3 N. Tampa Street. 5-617A Tampa. FL 33602 Tel: (813) 218-5340 Em a i I : Dav i d.Tarbert(-r)fl o fi. gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complainthas been sent fbr servicevia U.S. Certifled Mail. Return Receipt Requested to Baker's Management Properties Inc.. d/b/a as Down South Beverages & Clheck Cashing: Cartoon Car Wash. and Vernon Dixon II, Registered Agent. ar216 Behring Way. Jupiter. FL 33458 and 420 N US #1, Fort Pierce. FL 34950 on this l8tr'day of JuIy,2025. 00? 00P David J. Tarbert 61,73 36 Tq6 I 0 7 66e0 J-)

July 17, 2025

NOTICE TO RESPONDENTS In accordance with the Americans with Disabilities Act, persons with disabilities needing 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, Suite 504,200 East Gaines Street, Tallahassee, Florida 32399-0379, Phone: (850) 410-9889, or by Email: Agency.Clerk@flofr.gov. DATED and SIGNED this 18th day of July, 2025. PV¾QP -- By: --- David J. Tarbert Fla. Bar No. 813966 Assistant General Counsel Office of Financial Regulation Office of General Counsel 1313 N. Tampa Street, S-617A Tampa, FL 33602 Tel: (813) 218-5340 Email:David.Tarbert@flofr.gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service viaU.S. Certified Mail,Return Receipt Requested to Baker's Management Properties Inc., d/b/a as Down South Beverages & Check Cashing; Cartoon Car Wash, and Vernon Dixon II, Registered Agent, at 216 Behring Way,Jupiter, FL 33458 and 420 NUS #1,Fort Pierce,FL 34950 on this 18th day of July,2025. David J. Tarbert 33

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STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION SECEryEO . FLORIDA sEP 0 5 2025 OfllCe of Financial Regularion ln Re: BAKER'S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, Case Number: 117846 Respondents. ADMINI STRATIVE COMPLAI NT The State of Florida. Office of Financial Regulation ("Oftice"). files this Administrative Complaint against BAKER'S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, (together as "Respondents"). alleging: GENERAL ALLEGATIONS I . Pursuant to sections 560. 105 and 560. 109, Florida Statutes, the Office is charged with administering and enfbrcing the provisions of chapter 560. Florida Statutes, and conducting examinations and investigations to determine whether any provision of chapter 560, Florida Statutes. has been violated. 2. Pursuant to section 560.114(l)(a), Florida Statutes, failure to comply with any provision ol' chapter 560. Florida Statutes, or related rule, constitutes grounds for disciplinaly action. 3. Parts II, III, and IV of chapter 560, Florida Statutes, set fbrth the specific requirements olmoney services businesses and licensees.

NOTICE TO RESPONDENTS ln accordance with thc Americans r,vith Disabilities Act. persons with disabilities needing special accommodation to participate in this proceeding should contact the Agency Clerk no latcr than seven (7) days prior to the fi ling deadline or proceeding. at the Of flce ol'Financial Regulation. The Fletcher Building. Suite 504.200 East Gaines Street. Tallahassee. Florida 32399-0379. Phone: (850) 410-9889, or by [:mail: Agency.Clerk@f1ofi.gov. DATED and SIGNED this l8tr' day of July. 2025. By: David J. Tarbert Fla. Bar No. 813966 Assistant General Counsel OfTice of Financial Regulation Office of General Counsel l3l3 N. Tampa Street. S-617A Tampa. FL 33602 Tel: (813) 218-5340 Emai I : David.Tarbert@fl ofi.gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the fbregoing Administrative Complainthas been serrt lbr servicevia U.S. CertifiedMail. Return Receipt Requested to Baker's Managernent Properties Inc." d/b/a as Down South Beverages & Check Cashing: Cartoon Car Wash. and Vernon Dixon II. Registered Agent. at216 Behring Way. Jupiter. FL 33458 and 420 N US #1. Fort Pierce. FI- 34950 on this l8th day of JuIy.2025. 0t0 0 David J. Tarbert Eeo 6 9r+65 0 0E7 t L7? 33 JJ

Florida Office of Financial Regulation 200 East Gaines Street I Tallahassee, Florida 32399-0370 RETURN SERVICE REQUESTED 1111111 11 I 9489 □□ 90 0027 bb20 8157 09 8 a:i"' a. .. 0~ ~~ :x~ m~- -'"- Baker's Management Properties Inc. ATTN: V emon Dixon II P.O. Box 1746 Ft. Pierce, FL 34954-1746 November 24, 2025

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HECEIVED - FTORIDA JAN 6 2026 Ofica ot Financial Regulaflon STATE OF FLORJDA OFFICE OF FINANCIAL REGULATION FECEIVED - FLORIDA JUL I 5 2025 Oftcc ot Financiat Regutation ln Re: BAKER'S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, Case Number: I17846 Respondents. ADMINISTRATIVE COMPLAINT The State of Florida. Ofl'ice of Financial Regulation ("Olfice"). files this Administrative Complaint against BAKER'S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, (together as "Rcspondents"). alleging: GENERAL ALLEGATIONS l. Pursuant to sections 560.105 and 560.109, Florida Statutes, the Office is charged with administering and enlbrcing the provisions of chapter 560. Florida Statutes, and conducting examinations and investigations to determine whether any provision of chapter 560. Florida Statutes. has been violated. 2. Pursuant to section 560.114(lXa). Florida Statules, failure to comply with any provision of chapter 560, Florida Statutes. or related rule. constitutes grounds for disciplinary action. 3. Parts Il. III. and IV ol' chapter 560. Florida Statules, set lbrth the specific requirements ol' money services businesses and licensees.

NOTICE TO RESPONDENTS In accordance with the Americans with Disabilities Act. persons with disabilities needing special accommodation to participate in this proceeding should contact the Agency Clerk no later than seven ( 7) days prior to the I r ling deadline or proceeding. at the Office of Financial Regulation The Fletcher Building, Suite 504.200 East Gaines Street, Tallahassee, Florida 32399-0379, Phone: (850) 410-9889. or by Email: Agency.Clerk@)flofr.gov. DATED and SIGNED this 3'd day of June, 2025. By David J. Tarbert Fla. Bar No. 813966 Assislant General Counsel Ollice of Financial Regulation Olfice of Ceneral Counsel l3l3 N. Tampa Street. 5-617A Tampa, FL 33602 Tel: (813) 218-5340 Emai I : David.TarbertqrTfl oli.gov CERTIFICATE OF SERVTCE I HEREBY CERTIFY that a true and correct copy ol'the lbregoing Adminislrative Complaint has been sent for service via U.S. Certilied Mail. Return Receipt Requested to Baker's Management Properties lnc.. d/b/a as Down South Beverages & Chcck Cashing; Cartoon Car Wash, and Vernon Dixon II. Registered Agent. al72O Delaware Avenue, Unit B. Fort Pierce. FL 34950 on this 3"r day ol'June, 2025. David J. Tarbert 1q81 001U 00a? tEa0 gl,?a qb 33

NOTICE TO RESPONDENTS. In accordance with the Americans with DisabilitiesAct, persons with disabilities needirg 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 Regulatiorl The Fletcher Building, Suite 504, 200 East Gaines Street, Tallahassee, Florida 32399-0379,Phone: (850) 410-9889, or by Email: Agency.Clerk@flofr.gov. DATED and SIGNED this l8th day of July,2025. By: David J. Tarbert Fla. BarNo.8l3966 Assistant General Counsel Office of Financial Regulation Office of General Counsel l3l3 N. Tampa Street, 5-617A Tampa, FL 33602 Tel: (813) 218-5340 Emai I : David.Tarbert@fl ofr. gov CERTIFICATE OF I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for servicevia U.S. Certified Mail, Retum Receipt Requested to Baker's Management Properties Inc., d/b/a as Down South Beverages & Check Cashing; Cartoon Car Wash, and Vernon Dixon II, Registered Agent, at 216 Behring Way, Jupiter, FL 33458 and 420 N US #l , Fort Pierce, FL 34950 on this l8'h day of July, 2025. 2nd Attempt David J. Tarbert 9r{6 I 0090 00e 7EEEos L73 30 34

NOTICE TO RESPONDENTS In accordance with the Americans with Disabilities Act, persons with disabilities needing 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 Regulatiorl The Fletcher Building, Suite 504,200 East Gaines Street, Tallahassee, Florida 32399-0379,Phone: (850) 410-9889, or by Email: Agency.Clerk@flofi.gov. DATED and SIGNED this l8th day of July, 2025. By: David J. Tarbert Fla. Bar No. 813966 Assistant General Counsel Office of Financial Regulation Office of General Counsel l3l3 N. Tampa Street, 5-617A Tampa, FL33602 Tel: (813) 218-5340 Em ai I : Davi d.T arbert@fl ofr. gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service via U.S. Certified Mail, Return Receipt Requested to Baker's Management Properties lnc., dh/a as Down South Beverages & Check Cashing; Cartoon Car Wash, and Vernon Dixon II, Registered Agent, at 216 Behring Way, Jupiter, FL 33458 and 420 N US #1, Fort Pierce, FL 34950 on this l8th day of Ju!y,2025. David J. Tarbert 39 1q8? 0010 00e7 6ee0 677e 35

By David J. Tarbert Florida Bar No. 778461 Senior Attorney Office of Financial Regulation Office of General Counsel 200 E Gaines Street Tallahassee , FL 32399 Tel: (813)21 8-5340 Emai I : Dav id.Tarbert@fl ofr.eov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service via U.S. Certified Mail, Return Receipt Requested to Baker's Management Properties lnc., dlbla as Down South Beverages & Check Cashing; Cartoon Car Wash, and Vernon Dixon II. Registered Agent, at2410 Avenue D, Fort Pierce, FL34950-2756 and P.O. Box 1746. Ft. Pierce. FL 34954-1746 on this 24th day of November. 2025. 3'd Attempt 1r+85 0810 0Ee7 tha0 615? 01 David J. Tarbert 36 DATED and SIGNED this 24th day of November,2025.

-iorida Office of Financial Regulation 200 East Gaines Street I Tallahassee, Florida 32399-0370 RETURN SERVICE REQUESTED 111111 9489 □□ 9 □ □□ 27 662 □ 8156 93 "' 0 "' ~ "" "' a.." 0:1= "'0 a,Ol _,,, Ul ..JC.. Baker's Management Properties Inc. ATTN: Vernon Dixon II 2410 Avenue D Fort Pierce, FL 34950-2756 November 24, 2025

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FECE'VED . FLORIDA JAN 2 2 2026 Ofice of Financiat ReguhUon STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION RECEIVED . FLORIDA JUL I 5 2025 Oftcc ol Financial Regutation ln Re: BAKER'S MANAGEMENT PROPERTIES INC., d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON II, Case Number: I17846 Respondents. ADMINI STRATIVE COMPLAINT The State of Florida. Office of Financial Regulation ("Of fice"). files this Administrative Complaint against BAKER'S MANAGEMENT PROPERTIES INC.. d/b/a DOWN SOUTH BEVERAGES & CHECK CASHING; CARTOON CAR WASH, and VERNON DIXON lI, (together as "Rcspondents"). alleging: GENERAL ALLEGATIONS I . Pursuant to sections 560.105 and 560.109, Florida Statutes, the Office is charged with administering and enlbrcing the provisions of chapter 560. Florida Statutes, and conducting examinations and investigations to determine whether any provision of chapter 560. Florida Statutes, has been violated. 2. Pursuant to section 560.114(lXa), Florida Statutes, failure to comply with any provision of chapter 560. Florida Statutes. or related rule. constitutes grounds for disciplinary action. 3. Parts Il. III. and lV ol' chapler 560. Florida Statutes. set forth the specific requiremenls of money services busincsses and licensees.

NOTICE TO RESPONDENTS In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to participate in this proceeding should contact the Agency Clerk no later than seven(7) days priorto the filing deadlineorproceeding, at the OfficeofFinancial Regulation5 The Fletcher Building, Suite 504,200 East Gaines Street, Tallahassee, Florida 32399-0379, Phone: (850) 410-9889, or by Email: Agency.Clerk@flofr.gov. DATED and SIGNED this l8th day of July, 2025. By David J. Tarbert Fla. Bar No. 813966 Assistant General Counsel Office of Financial Regulation Office of General Counsel l3l3 N. Tampa Street, 5-617A Tampa, FL 33602 Tel: (813) 218-5340 Emai I : David.Tarbert(@fl ofr. gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for servicevia U.S. Certified Mail, Rerurn Receipt Requested to Baker's Management Properties lnc., dlbla as Down South Beverages & Check Cashing; Cartoon Car Wash, and Vernon Dixon II, Registered Agent, at 216 Behring Way, Jupiter, FL 33458 and 420 N US #1, Fort Pierce, FL 34950 on this l8th day of July, 2025. 2nd Attempt David J. Tarbert 9r{6g 00?0 008 7g6e0 d.l,zJ 36 34

NOTICE TO RESPONDENTS In accordance with the Americans with Disabilities Act, persons with disabilities needing 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 Regulatiorl The FletcherBuilding, Suite 504,200 East Gaines Street, Tallahassee, Florida 32399-0379,Phone: (850) 410-9889, or by Email: Agency.Clerk@flofr.gov. DATED and SIGNED this l8th day of July, 2025. By: David J. Tarbert Fla. Bar No. 813966 Assistant General Counsel Office of Financial Regulation Office of General Counsel l3 l3 N. Tampa Street, 5-61 74 Tampa, FL33602 Tel: (813) 218-5340 Emai I : David.Tarbert@fl ofr. gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service via U.S. Certified Mail, Retum Receipt Requested to Baker's Management Properties Inc., d/bla as Down South Beverages & Check Cashing; Cartoon Car Wash, and Vemon Dixon II, Registered Agent, at 216 Behring Way, Jupiter, FL 33458 and 420 N US # l, Fort Pierce, FL 34950 on this l 8th day of July, 2025. David J. Tarbert 1LtIt 00 90 00e7 6ae0 477a J? 35

DATED and SIGNED this 24Ih day of November.2025. By David J. Tarbert Florida Bar No. 778461 Senior Attorney Office of Financial Regulation Office of General Counsel 200 E Gaines Street Tallahassee , FL 32399 Tel: (813)21 8-5340 Emai I : Dav id.Tarbert@fl ofr.qov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the l'oregoing Administrative Complaint has been sent for service via U.S. Certified Mail. Return Receipt Requested to Baker's Management Properties lnc.. d/b/a as Down South Beverages & Check Cashing; Cartoon Car Wash. and Vernon Dixon II. Registered Agent. at 2410 Avenue D. Fort Pierce, FL 34950-2756 and P.O. Box 1746, Ft. Pierce. FL 34954-1746 on this 24th day of November, 2025. 3'd Attempt 1t{81 0010 uEa? hheE 615t 13 David J. Tarberl 36

December 9, 2025 Dear David Tarbert: The following is in response to your request for proof of delivery on your item with the tracking number: 9489 0090 0027 6620 8156 93. Thank you for selecting the United States Postal Service® for your mailing needs. If you require additional assistance, please contact your local Post Office™ or a Postal representative at 1-800-222-1811. Sincerely, United States Postal Service® 475 L'Enfant Plaza SW Washington, D.C. 20260-0004 Item Details Status: We regret to inform you that we were unable to locate any delivery information in our records for your item. Status Date / Time: N/A Location: N/A Postal Product: First-Class Mail® Extra Services: Certified Mail™ Return Receipt Electronic Shipment Details Weight: 14lb, 15.9oz

EXHIBIT C