Final Order — Securities Guaranty Fund Claim — OFR — US-FL

In Re:
BAOPING LIU,
CHANGYUE LIU,
DAQIN WENG,
FENG GUO,
LI ZHANG,
LING LI,
LIYANFENG,
MIN CUI,
QINGYUNYU,
SHAOPING HUANG,
SHAOQING ZENG,
TINGTING SUN,
TONGHUI LUAN,
XIAO SUN,
YAWEN LI,
YI ZHAO,
ZENG YU,
Petitioners.
Index: OFR 2026 - 477 .. CKtT£0 '
0/2026
STATE OF FLORIDA
GAL
OFFICE OF FINANCIAL REGULATION
FINAL ORDER
Case Numbers: 132866-S
132867-S
132868-S
132888-S
132891-S
132892-S
132893-S
132894-S
132896-S
132897-S
132900-S
132902-S
132903-S
132906-S
132907-S
132915-S
132918-S
These causes came on for consideration and final agency action. Upon review of the record and being otherwise fully advised in the premises, the Office of Financial Regulation ("Office") hereby finds:

The Office has jurisdiction over the subject matter of this case and the parties
hereto.
The entry of this Final Order concludes the above-referenced matter.
ORDERED:
A. The Recommended Order (Exhibit A) is incorporated by reference as if fully stated herein.

B. The Petitioners' Applications for Recovery from the Securities Guaranty Fund are DENIED. DONE and ORDERED this ~ County, Florida. day of September, 2026, in Tallahassee, Leon Commissioner

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:
Bv 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.

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order was furnished to Robert V. Cornish, Jr. and Kaitlin Harris counsel for Petitioners Baoping Liu, Changyue Liu, Daqin Weng, Feng Guo, Li Zhang, Ling Li, Liyan Feng, Min Cui, Qingyun Yu, Shaoping Huang, Shaoqing Zeng, Tingting Sun, Tonghui Luan, Xiao Sun, Yawen Li, Yi Zhao, and Zheng Yu by U.S. Mail to P.O. Box 12200, Jackson, WY 83001 and by electronic mail to rcornish@rcomishlaw.com, and kharris@rcomishlaw.com on this~ ay of September, 2026. Regulation 32314-8050 ncy.Clerk@flofr.gov Tel: (850) 410-9889

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
BAOPING LIU, et al., Case Norn her: 132866-S
Petitioners.
I -----------
RECOMMENDED ORDER
A hearing in this case was conducted on June 18, 2026, by video teleconference pursuant to sections 120.569 and 120.57(2), Florida Statutes, before Miriam S. Wilkinson, a duly designated Hearing Officer with the Florida Office of Financial Regulation ("Office"). For Petitioners:
For Respondent:
APPEARANCES
Robert V. Comish, Jr., Esquire
Kaitlin A. Harris, Esquire
Law Offices of Robert V. Comish, Jr., P.C.
1395 Brickell A venue, Suite 800
Miami, FL 331 31
George C. Bedell III, Esquire
Office of Financial Regulation
200 E. Gaines Street
Tallahassee, FL 32399-0379
STATEMENT OF THE ISSUE
Whether grounds exist for the Office of Financial Regulation ("Office") to deny Petitioners' applications for monetary relief under section 51 7 .131, Florida Statutes (2021 ), the Securities Guaranty Fund ("the Fund"). PRELIMINARY STATEMENT On September 23, 2025, Petitioners Baoping Liu, Changyue Liu, Daqin Weng, Feng Guo, Li

Zhang, Ling Li, Liyan Feng, Min Cui, Qingyun Yu, Shaoping Huang, Shaoquing Zeng, Tingting Sun, Tonghui Luan, Xiao Sun, Yawen Li, Yi Zhao, and Zheng Yu (collectively, "Petitioners"), filed applications with the Office seeking recovery from the Fund for violations of the Florida Securities and Investor Protection Act ("FSIPA") by Joseph Walsh, Sr. ("Walsh, Sr."); Joseph Walsh, Jr. (Walsh, Jr.); South Atlantic Regional Center, LLC ("SARC"), United States Regional Economic Development Authority, LLC ("USREDA"); JJW Consultancy Ltd. ("JJW"), and others (collectively, the "Judgment Debtors"). The applications included: (1) a copy of the Final Default Judgment Against Defendants Joseph Walsh, Jr., Joseph Walsh, Sr., and JJW Consultancy, Ltd., issued in a federal court proceeding styled Li
v. Walsh, Case No. 9:16-CV-81871-KAM (S.D. Fla., filed Nov. 19, 2021) in Petitioners' favor, awarding
compensatory damages in the amount of $662,990 each; (2) a related Proof of Claim filing in a bankruptcy proceeding styled In re: US. Reg'/ Econ. Dev.I Auth., LLC, Case No. 19-25780-EPK (Bankr. S.D., Fla., filed Sept. 25, 2020) (the "USREDA Bankruptcy proceeding"), along with an Addendum to Proof of Claim, a Notice of Trustee's Final Report and Application for Compensation and Deadline to Object, Summary of Trustee's Final Report and Applications for Compensation, Trustee's Summary of Requested Fees and Expenses, and a Certificate of Service of Trustee's Notice of Final Report; (3) a Proof of Claim, an Addendum to Proof of Claim, a Trustee's Notice of Final Dividends to Creditors, filed in a bankruptcy proceeding styled In re: S. Atlantic Reg'/ Center, LLC, Case No. 19-25762-EPK (Bankr. S.D. Fla., filed Sept. 25, 2020, and Dec. 26, 2023, respectively) (the "SARC Bankruptcy proceeding"); and (4) a Judgment against USREDA issued by a Florida state court February 24, 2025, in a proceeding styled Peixuan Wang, Hezhang Chen, Dong/in Gu, Jialin Han, Wen Shen, Yi Gao, Yongliang Huang, Tianjun Li
v. US. Regional Economic Development Authority, LLC, Case No. 50-2023-CA-014328 (15th Fla. Cir.
Ct., filed Oct. 3, 2023) ("Wang'').

The Office reviewed Petitioners' applications and accompanying documents, and on December 16, 2025, issued to each Petitioner a Notice oflntent to Enter a Final Order Denying Recovery from the Securities Guaranty fund ("Denial Notice") on the grounds that they failed to perfect their claims under
section 517 .131, Florida Statutes (2021 ). More specifically, the Denial Notice stated that Petitioners failed
to demonstrate that they purchased securities from the Judgment Debtors at a time when one or more of the Judgment Debtors were registered in any capacity under chapter 517, Florida Statutes, as required by
section 517.131 (2), Florida Statutes (2021 ). Based on this determination, the Office concluded it was
unnecessary to address the other statutory requirements.
Petitioners timely submitted a request for an administrative hearing pursuant to section 120.57(2), Florida Statutes, admitting the material factual allegations in the Denial Notice. By Order dated February 5, 2026, the Office granted Petitioners a proceeding pursuant to section 120.57(2), Florida Statutes, and appointed the undersigned as the Hearing Officer in this matter. On May 28, 2026, the undersigned issued a Notice of Video Teleconference Hearing, scheduling the final hearing for June 18, 2026. On June 15, 2026, the parties filed a Joint Prehearing Stipulation. Neither side presented any witnesses. Other than the federal court judgment, no exhibits were offered by the parties. The undersigned took official recognition of the applicable statutes and relevant pub1ic records. At the conclusion of the hearing, the parties were advised they could submit proposed recommended orders, which would be due no later than August 3, 2026. The one~volume transcript of the final hearing was filed with the Office's Agency Clerk on June 30, 2026. The parties filed their Proposed Recommended Orders on August 3, 2026. FINDINGS OF FACT The Findings of Fact as alleged in the Denial Notice issued to Petitioners on December 29, 2025, are hereby adopted as Findings of Fact in this Recommended Order.

CONCLUSIONS OF LAW

Under the provisions of the FSIPA, the Office is charged with the responsibility and duty
of administering the Fund, which includes the duty to approve or deny applications for payment from the Fund as set forth in sections 517 .131 and 517 .141, Florida Statutes.
In hearings pursuant to section 120.57(2), Florida Statutes, where, by definition, there
arc no disputed issues of material fact, only conclusions oflaw are to be drawn as to whether the facts support the agency's intended decision. Autoworld of America Corp. v. Department of Highway Safety and Motor Vehicles, 754 So. 2d 76, 77 (Fla. 3d DCA 2000).
The general rule is that a party asserting the affirmative of an issue has the burden of
presenting evidence as to that issue. McGraw v. Department of State Div. of Licensing, 491 So. 2d 1 193, 1195 (Fla. 1st DCA 1986).
As applicants seeking payment from the Fund, Petitioners bear the burden of proving
e1igibility for recovery by a preponderance of the evidence. Dep't of Transportation v. J W C. Co., Inc., 396 So. 2d 778 (Fla. 1st DCA 1981). Background
Petitioners are citizens of the People's Republic of China, each of whom were induced by
Walsh and his entities, including USREDA and SARC, to invest $500,000 (plus a $40,000 "administrative fee") in a purported Palm Beach, Florida, real estate project known as the "Palm House Hotel," a favade pursuant to which Petitioners' funds were stolen and distributed among the Judgment Debtors. The funds were to be held in escrow unless and until their 1-526 immigration petitions were approved by the U.S.

government. The now defunct 1 Palm House Hotel, LLLP limited partnership ("Partnership") was the vehicle through which Petitioners could become pennanent U.S. residents through the federal EB-5 visa program. Although some Petitioners may have recovered a small portion of their investment from a subsequent bankruptcy proceeding involving one or more Judgment Debtors, most of the funds were gone. Florida U.S. District Court Case
6. On November 14, 2016, Petitioners sued the Judgment Debtors in U.S. District Court,
Southern District, Florida, alleging fraud in the inducement and violations of FSIPA section 517.01 1, et seq., and seeking monetary damages and injunctive relief.
7. On November 19, 2021, the Court entered a Default Final Judgment against Walsh, Sr.,
Walsh, Jr., and JJW, awarding monetary damages of $662,900 to each of the individual Petitioners ($11,270,830 in total), plus punitive damages amounting to $25,500,000, for a total of $36,770,830 in damages for violations of the FSIPA, as codified in chapter 517, Florida Statutes (2021). The Partnership was not included in the FSIP A damages award. Florida Circuit Court Case
8. Petitioners also rely on a final judgment entered on February 24, 2025, in favor of the
named Plaintiffs in a case against USREDA filed in a Florida state court proceeding styled Peixuan Wang, Hezhang Chen, Donglin Gu, Jialin Han, Wen Shen, Yi Gao, Yongliang Huang, Tian.Jun Liv. US. Regional Economic Development Authority, LLC, Case No. 50-2023-CA-014328 (15th Fla. Cir. Ct., filed Oct. 3,
2023) ("Wang''). The court determined that the Plaintiffs were entitled to rescission of their investments,
and said the Plaintiffs could apply to the Fund for payment. Petitioners were not a party in the Wang case. 1 As of September 27, 2019, the business entity was administratively dissolved after failing to file an annual report with the Florida Department of State.

The Securities Guaranty Fund
9. The Fund was original1y enacted in 1978 to provide relief to victims ofFSIPA violations
who were entitled to monetary damages, but were unable to recover those damages from the offender (Cherdack, M. and White, R., Florida's Securities Guaranty Fund: An Instagram Worthy Model. The Florida Bar Journal, Vol. 99, No. 6, Nov./Dec. 2025:37). At that time, the Fund provided for disbursements to any person adjudged by a court of competent jurisdiction to have suffered monetary damages as a result of any Florida licensed dealer, salesman, or investment advisor who was adjudged to have committed a violation of section 517.07 (registration of securities) or 517.301 (fraudulent transactions) or 51 7.311 (false representation), Florida Statutes.
10. In 1984, the statute was amended as to eligibility and payment, including a notice
requirement and 2-year waiting period after filing a claim against a licensed dealer, investment advisor, or associated person. Id. at 2, 3. In 2024, the statute was again amended, raising the claim cap to $15,000, eliminating the 2-year waiting period, and, among other things, changing the requirement that the offender be a Florida-licensed dealer, investment advisor, or associated person under chapter 517, Florida Statutes. Id. at 5. I 1. Under amended section 517 .131, Florida Statutes (2025), payment from the Fund for an unsatisfied final judgment or restitution order that was entered before October 1, 2024, in which a wrongdoer was found to have violated section 517.07 or section 517.301, Florida Statutes, is to be governed by the terms of section 517 .131 and 517 .141 that were in effect on the date the final judgment or restitution order was entered.
12. Pursuant to section 517 .131 (2), Florida Statutes (2020), to recover from the Fund in 2021,
the claimant must have been adjudged by a court of competent jurisdiction to have suffered monetary

damages as a result of any of the following acts committed by a dealer, investment advisor, or associated person who was licensed under chapter 517, Florida Statutes, at the time the acts were committed: (a) a violation of section 517.07 and/or (b) a violation of section 517.301.
13. Pursuant to section 517.131(3)(a), Florida Statutes (2020):
[A]ny person is eligible to seek recovery from the Securities Guaranty Fund if:
(a) Such person has received final judgment in a court of competent jurisdiction in any action wherein the cause of action was based on a violation of those sections referred to in subsection (2). (b) Such person has made all reasonable searches and inquiries to ascertain whether the judgment debtor possesses real or personal property or other assets subject to being sold or applied in satisfaction of the judgment, and by her or his search the person has discovered no property or assets; or she or he has discovered property and assets and has taken all necessary action and proceedings for the application thereof to the judgment, but the amount thereby realized was insufficient to satisfy the judgment. To verify compliance with such condition, the office may require such person to have a writ of execution be issued upon such judgment, may require a showing that no personal or real property of the judgment debtor liable to be levied upon in complete satisfaction of the judgment can be found, or may require an affidavit from the claimant setting forth the reasonable searches and inquiries undertaken and the result of those searches and inquiries. (c) Such person has applied any amounts recovered from the judgment debtor, or from any other source, to the damages awarded by the court. (d) The act for which recovery is sought occurred on or after January 1, 1979.
14. Petitioners acknowledge that Walsh, Sr. and the other Judgment Debtors who induced
Petitioners to invest in the project(s) were not at any time licensed with the Office as securities dealers, investment advisors, or associated persons under chapter 517, Florida Statutes.
15. Petitioners have also acknowledged there are statutory prerequisites that must be met in
order to recover from the Fund, but argue that the governing statutes should be liberally construed so as to a11ow recovery for those who cannot satisfy the prerequisites. Whether a statute is to be given a strict or liberal construction depends on the nature of the statute, the purpose to be subserved, and the conduct

to be remedied. A strict construction yields an interpretation that closely adheres to the exact meaning of the black letter language of the statute. A liberal construction typically involves a broader interpretation of the statutory language in order to accomplish its purpose, carry out its intent, or promote justice as a matter of equity.
16. The Securities Guaranty Fund is a statutory recovery and restitution mechanism for victims
of securities fraud who cannot recover from the offender monetary damages awarded in a final judgment entered by a court of competent jurisdiction. It is remedial in nature. Remedial statutes are usually liberally construed to meet their protective purpose. See Florida Convalescent Centers, etc. v. Somberg, etc., 840 So. 2d 998 (Fla. 2003) ("It is well settled that legislative intent is the polestar that guides a court's statutory construction analysis"). Yet, it is one thing to broadly construe a statute based solely on legislative intent when the language may be ambiguous or open to varying interpretations, but it's another thing to ignore plain language the Legislature intentionally put into place setting forth distinct and clear eligibility requirements for recovering on a claim. See State v. Rife, 789 So.2d 288, 292 (Fla.2001); McLaughlin v. State, 721 So.2d 1170, 1172 (Fla.1998) ("When the language of the statute is clear and unambiguous and conveys a clear and definite meaning, there is no occasion for resorting to the rules of statutory interpretation and construction; the statute must be given its plain and obvious meaning." Holly v. Auld, 450 So.2d 217,219 (Fla.1984) (quoting A.R. Douglass, Inc., v. McRainey, 102 Fla. 1141, 137 So. 157, 159 (1931)).
17. The conditions for recovery set forth in the statute were intended by the Florida Legislature
to be applied by the Office in determining an applicant's eligibility. See, e.g., DeMaria v. Construction Industry Licensing Board, 386 So.3d 208 (Fla. 1st DCA 2023) (where claimants failed to obtain a monetary damages award as required by statute, the appellate court set aside an order from the Board

granting claimants' application for recovery from the Fund, stating, "[t]he Legislature makes perfectly clear that a key criterion for recovery from the fund is that the amount of claimant's damages has already been reduced to a civil judgment, arbitration award, or restitution order that specifies the actual damages suffered as a consequence of such violation ... The Legislature allows us to set aside agency action when the agency's exercise of discretion was ... [o]utside the range of discretion delegated to the agency by law ... "); see also, Bessey v. Department of Business & Professional Regulation, 396 So.3d 847 (Fla. 2nd DCA 2024) (The Board's order granting applicants' claim for recovery was reversed by the appellate court because applicants failed to reduce their claim to a final judgment on damages). The Office does not have the discretion to grant a claim made on the Fund if a claimant has not satisfied aJl of the stated conditions for recovery. See 517.14 I (I), Florida Statutes (202 I) ("Any person who meets all of the conditions prescribed in s. 517 .131 may apply to the office for payment to be made to such person from the Securities Guaranty Fund ... ").
18. The catastrophic financial harm suffered by Petitioners as a direct result of the financial
fraud scheme that was perpetrated by the Judgment Debtors in this case cannot be overstated, and the undersigned is sympathetic to their plight. However, the eligibility requirements established by the Legislature for recovering from the Fund are clear and unambiguous prerequisites that must be met in order to apply to the Fund. Analysis
19. The federal court order was issued November 19, 2021, and therefore Petitioners claims
must be analyzed under the statutes as they existed on the effective date of that order.
20. To recover from the Fund in 2021, the Petitioners must have been adjudged by a court of
competent jurisdiction to have suffered monetary damages as a result of a violation of either section 517 .07

or 517.301, Florida Statutes, by a dealer, investment advisor, or associated person who was licensed under
chapter 517, Florida Statutes at the time the act was committed.
21. Pursuant to section 517.141 (1), Florida Statutes (2021 ), "[a]ny person who meets all of the
conditions prescribed ins. 517.131 may apply to the office for payment to be made to such person from the Securities Guaranty Fund in the amount equal to the unsatisfied portion of such person's judgment or $10,000, whichever is less, but only to the extent and amount reflected in the judgment as being actual or compensatory damages ... " (Emphasis added)
22. Petitioners' argument that, based on the placement of the commas in section 517.131(2),
the licensing/registration requirements were intended to apply only to an associated person, and not an investment advisor or dealer, is meritless. Pursuant to section 517.12, Florida Statutes (2021):
(1) No dealer. associated I erson. or issuer of securities shall se11 or offer for sale anv securities in or from offices in this state, or sell securities to persons in this state from offices outside this state, by mail or otherwise, unless the person has been registered with the office pursuant to the provisions of this section. The office shall not reeister anv person as an associated person of a dealer unless the dealer with which the applicant seeks registration is lawful) v re!!istered with the office pursuant to this chapter. (Emphasis added) ( 4) No investment adviser or associated person of an investment adviser or federal covered adviser shall enga!.!e in business from offices in this state, or render investment advice to persons of this state, by mail or otherwise, unless the federal covered adviser has made a notice-filing with the office pursuant to s. 517.1201 or the investment adviser is re!!istered pursuant to the provisions of this chapter and associated persons of the federal covered adviser or investment adviser have been registered with the office pursuant to this section. A dealer, associated person, or investment adviser, in order to obtain registration, must file with the office a written application ... (Emphasis added)
23. Under Petitioners' interpretation, a securities dealer would not have to register, but a person
associated with a securities dealer would have to register. When read within the broad context of the entire
chapter of laws relating to every aspect of securities regulation in Florida, Petitioners' interpretation does

not make sense from a regulatory standpoint, and would lead to an absurd result in its real-world appHcation.
24. Among other things, section 5 J 7 .30 I, Florida Statutes (2021 ), concerns fraudulent
transactions. Section 517.301 (I) states, "It is unlawful and a violation of the provisions of this chapter for a person: ... " Likewise, section 517.07(1) states, "It is unlawful and a violation of this chapter for any person to sell or offer to sell a security within this state ... " (Emphasis added). The Legislature intentionally wrote these laws to apply to anyone who violated those subsections, not just licensees. Conversely, the Securities Guaranty Fund (2021) applies only to acts committed by a dealer. investment adviser, or associated person who was licensed at the time the act was committed ... " (Emphasis added). The Florida Legislature could have instead written this statute in conformance with other sections of chapter 517 to apply to acts committed by "a person" or "any person" (which they finally did in 2024), so it is significant that the Legislature specifically required that the statutory violations be committed by licensed investors, dealers and associated persons."
25. Petitioners argue that, with the 2024 amendments to section 517.131 "[t]he Legislature
clarified what it always intended: that victims of securities fraud should be able to access the Fund regardless of the wrongdoer's registration status." The official record of the legislative history of the Fund Jaw directly contradicts this assertion. When House Bill 324 was passed in 1977, updating the Sale of Securities Law, a Memorandum dated February 17, 1978, entitled "Legislative Intent," was subsequently issued by House Commerce Committee Chairman, John R. Forbes, to Representative Paul B. Steinberg, Chainnan of the Florida Securities Law Revision Project, stating:
"Due to increased judicial emphasis on "legislative intent," the Speaker's Office has suggested that such intent be obtained on each bill being considered. Because "intent" can best be explained by the author and introducer of the bill, I am asking each member to provide this (in a short paragraph) for the House's records." See Session Law 78~435, Laws 1 ]

of Florida I 978, in Series 19, Carton 333, Florida State Archives, Florida Department of State. Attached to this memo is a "Statement of Legislative Intent, Bill No. HB 324" submitted by Paul Steinberg, stating:
"6. The implementation of a Security Guaranty Fund for payment of investors with unsatisfied claims authorized by court orders. The payments would be made onlv when the claims are a~ainst individuals or entities registered with the Division of Securities." See Session Law 78-435, Laws of Florida 1978 in Series 19, Carton 327, Florida State Archives, Florida Department of State. (Emphasis added) Clearly, it was the Florida Legislature's original intent to exclude claims made on the Fund for violations of the Florida securities laws by unregistered persons. Petitioners offered no documentary or testimonial evidence that would demonstrate otherwise. The circumstances of this case are deeply unfortunate, but the remedy is not for the agency to re-interpret its laws in a manner that is at odds with the legislative purpose of the law as it existed in 2021 . Petitioners are therefore foreclosed from recovering from the Fund under the law in effect at that time.
26. Petitioners are also foreclosed from recovering payment from the Fund under the 2025
Wang judgment, in which a Florida Circuit Court ordered rescission of the Wang Plaintiffs' investments. As an equitable remedy, Plaintiffs were only entitled to cancel or unwind the contract they had with the Judgment Debtors, which theoretically would have restored them to their precontractual positions. However, none of the Petitioners here were a party in the Wang lawsuit, therefore none of the Petitioners are a judgment creditor in an unsatisfied final judgment or a name beneficiary or victim in an unsatisfied restitution order entered on or after October I, 2024, as required by section 517 .131 (3)(a)3, Florida Statutes.
27. At the time this Order was issued, the Securities Guaranty Fund statute had again been

amended so that now an applicant was required to be "a natural person who was a resident of Florida, or is a business entity that was domiciled in this state at the time of the violation of section 517.07 or 517.30], Florida Statutes." No evidence was offered establishing the Florida residency of any Petitioner in this case, as required by subsection 5 l 7.131(3)(a)(3.), Florida Statutes. RECOMMENDATION Based on the foregoing Findings of Fact and Conclusions of Law, it is recommended that the Office of Financial Regulation enter a final order denying Petitioners' applications to the Securities Guaranty Fund. Respectfully submitted this 3rd day of September 2026, in Tallahassee, Leon County, Florida. MM-~ s. w~ MIRIAM S. WILKINSON Hearing Officer Office of Financial Regulation 200 E. Gaines Street Tallahassee, FL 32399-0370

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Recommended Order has been furnished via electronic mail to Counsel for the Petitioners Robert V. Comish, Jr., Rcomish@rcomishlaw.com, Law Offices of Robert V. Comish, Jr., P.C., 680 South Cache Street, Suite 100, Jackson, WY 83001, and Kaitlin Harris, Kharris@rcomishlaw.com, Law Offi~ of Robert
V. Comish, Jr., P.C., 1395 Brickell Avenue, Suite 800, Miami, Florida 33131 on this ____ day of
September 2026.
Cc: George Bedell, Chief Counsel
George.Bedell@flofr.gov f Financial Regulation lC OX 8050 Ta a . e, FL 32314-8050 a·.Agency.Clerk@tlofr.gov

: (850) 410-9889