Immediate Final Order Against Springwell Financial Inc.

Index: OFR 2026 - 299 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: SRPINGWELL FINANCIAL INC., and www .springwellfinancialinc.com, Respondents. IMMEDIATE FINAL ORDER CK(TE r 1912026 EGA. Case No.: 138396 The State of Florida, Office of Financial Regulation ("Office"), being authorized and directed to administer and enforce chapter 655, Florida Statutes, governing financial institutions in the State of Florida, pursuant to sections 20.121(3)(a)2, 655.001, and 655.012(1), Florida Statutes, hereby finds that the unlawful activity of Springwell Financial Inc., and www.springwellfinancialinc.com ("Respondents") constitutes an immediate danger to the public health, safety, or welfare. Therefore, the Office hereby issues and serves this Immediate Final Order pursuant to sections 120.569(2)(n), and 655.922(5), Florida Statutes. Respondents and all persons acting in concert or cooperation with Respondents shall immediately CEASE AND DESIST all continuing violations of chapter 655, Florida Statutes, and take corrective action as detailed herein. This Order is based on the findings of fact and conclusions of law set forth below which are made on behalf of the Office by Russell C. Weigel, III, Commissioner of the Office of Financial Regulation, as agency head within the meaning of sections 20.121(3)(a)2, and 120.569(2)(n), Florida Statutes. FINDINGS OFF ACT

1. The Office is the state of Florida's agency responsible for the administration and enforcement of chapter 655, Florida Statutes.
2. The Office obtained information prompting an investigation into whether

Respondents were offering or providing unauthorized banking or credit union services, contrary to provisions of chapter 655, Florida Statutes. 3. The findings of fact made herein are based, in part, upon the verified declaration of Senior Financial Investigator, Reina Rivero, Emergent Financial Crimes Unit, Bureau of Financial Investigations, Office of Financial Regulation, which includes exhibits 1 through 12. Reina Rivero's declaration, along with its exhibits, are attached hereto as Attachment "A." Respondents' Status 4. Respondent Springwell Financial Inc. is not registered to lawfully operate as a business entity in Florida. The website https://www.springwellfinancialinc.com, is managed by Respondent Springwell Financial Inc. 5. Respondents' website contains several references to a registered financial institution in Florida. These include references to the registered financial institution's mobile app, and to their website address. Therefore, Respondents have certain minimum contacts with Florida for jurisdictional purposes. 6. Respondents have never been a chartered or licensed financial institution according to the Federal Financial Institutions Examination Council's National Information Center which is a repository of financial data and institution characteristics collected by the Federal Reserve System on financial institutions worldwide. 7. Respondents have never been chartered or licensed by the Office to do business in the state of Florida as a financial institution, as defined in section 655.005(1)(i), Florida Statutes. 8. Respondents have never been members of the Federal Deposit Insurance Corporation ("FDIC"), and any funds deposited with Respondents are not insured by the FDIC. 2

Respondent's Website 9. Respondents published and operate a website with a Uniform Resource Locator (URL) of https://www.springwelffinancialinc.com that: a) offers banking services to individuals located within the state of Florida; b) offers members of the public, including individuals in Florida, to communicate with Respondent by clicking the 'Contact Us' tab; c) solicits members of the public, including individuals in Florida, to establish online personal checking accounts with Respondents; d) offers various business account services, including business checking accounts, business savings accounts; and e) offers various mortgage products for home buyers. 10. Respondents' website advertises, represents, and holds itself out to the general public, including Florida citizens, as a financial institution. 11. Respondents' website reasonably implies that the business being solicited, conducted, or advertised is the kind or character of business transacted or conducted by a financial institution. 12. The cun-ent domain registrar of https://www.springwellfinancialinc.com 1s Hostinger International Ltd. The website was registered on September 23, 2023. Ongoing Immediate Danger 13. Entities and individuals that falsely hold themselves out to the public as authorized and qualified to operate as a financial institution pose an immediate danger to the public health, safety, or welfare, and particularly to those depositors or creditors who rely upon those false representations. 3

14. As of June 9th, 2026, the URL https:/lwww.springwellfinancialinc.com is currently accessible and active with an 1Pv4 address of 66.45.244.235 and is hosted by Hostinger International Ltd.
15. The status of Respondents' website as active constitutes an ongoing and immediate danger to public health, safety, or welfare.
16. Respondents are currently using the services of Hostinger International Ltd to facilitate fraudulent activity and violations of Florida Statutes.
17. Respondents' actions, including publication of the website, are unlawful and the current circumstances constitute an ongoing and immediate danger to the public health, safety, or welfare.
18. Respondents' actions are likely to continue in the future, and an immediate final order is necessary and fair under the circumstances to stop the ongoing violation. CONCLUSIONS OF LAW
19. The Office is responsible for the administration and enforcement of chapter 655, Florida Statutes, pursuant to section 655.012, Florida Statutes.
20. The undersigned, Russell C. Weigel, III, as Commissioner of the Office, and as its agency head within the meaning of sections 20.121 (3)(a)2, and 120.569(2)(n), Florida Statutes, is authorized to make the findings of fact and conclusions of law set forth herein.
21. The Office has jurisdiction over the matter because Respondents have been found to have engaged in unauthorized banking activity in the state of Florida, contrary to sections of chapter 655, Florida Statutes.
22. Chapter 655, Florida Statutes, is designed to protect the public welfare by requiring that each entity engaged in offering banking services to the public or holding itself out to the public 4

as being a financial institution is authorized to do business in this state. None of these protections of the public health, safety, or welfare are provided when an individual or an entity engages in the business of a financial institution in this state without in fact being authorized to do business as a financial institution pursuant to state or federal law. Unauthorized Banking Activity 23. Section 655.922(1), Florida Statutes, provides that only a financial institution authorized to do business in this state may engage in the business of soliciting or receiving funds for deposit, paying checks, or establishing or maintaining a place of business in this state for any of the functions, transactions, or purposes identified in the subsection. 24. Section 655.922(1 ), Florida Statutes, is designed to protect the public health, safety, or welfare by prohibiting unauthorized persons or entities from engaging in banking activities. A violation of this statute constitutes, in addition to a regulatory violation, a felony of the third degree punishable by up to a five-year prison sentence. 25. By soliciting or receiving funds from the public through its internet website and offering to establish business and personal bank accounts, and to perform other related banking services while not being authorized to do such business in this state, Respondents are in violation of section 655.922(1 ), Florida Statutes. Unauthorized Claims 26. Section 655.922(2)(c), Florida Statutes, provides that only a financial institution authorized to do business in Florida may "circulate or use any ... electronic media, internet website, posting, or writing of any kind or otherwise advertise or represent in any manner which indicates or reasonably implies that the business being solicited, conducted, or advertised is the kind or character of business transacted or conducted by a financial institution or which is likely 5

to lead any person to believe that such business is that of a financial institution . ... " 27. By using electronic media or a website that indicates or reasonably implies that the business being solicited, conducted, or advertised is that of a financial institution or which is likely to lead a person to believe that the business is a financial institution, Respondents are in violation of section 655.922(2)( c ), Florida Statutes. Summary Administrative Action 28. Section 655.922(5), Florida Statutes, provides that the Office may issue an emergency cease and desist order without first issuing an administrative complaint against any person who violates any provision of section 655.922, Florida Statutes. 29. Section 120.569(2)(n), Florida Statutes, provides that an immediate final order may be issued when an agency head finds the existence of an immediate danger to the public health, safety, or welfare and when that danger requires an immediate final order. 30. The statutory violations committed by Respondent and the existence of and content included in its' website https://www.springwellfinancialinc.com, as outlined above, constitute an ongoing, continuing, and immediate danger to the public health, safety, or welfare. 31. The unlawful activity committed by Respondents and the status of their website, as outlined above, constitute an ongoing, continuing, and immediate danger to the public health, safety, or welfare. 32. It is necessary for the Office to immediately prevent Respondents from the ability to continue to violate Florida law and continuing to pose an immediate danger to the public health, safety or welfare, to wit: a. it is necessary to have Respondents immediately cease and desist from holding themselves out to the general public, including Florida citizens, as a financial 6

institution; and b. it is necessary to have Respondents immediately cease and desist from soliciting financial transactions or deposits from the general public, including Florida citizens, through the use of their website or other methods. 33. After careful consideration of the facts of this case and due process procedural safeguards the need for summary administrative action in the form of this Immediate Final Order is concluded to be fair, just, and necessary under the totality of circumstances herein. 34. In entering this Immediate Final Order, the Office considered but ultimately decided against using other remedies. Issuing an administrative complaint or a cease and desist order would be insufficient to adequately address Respondents' ongoing violations of the law. Neither of these options would be effective upon service, and an indeterminate amount of time would pass before a final order could be issued against Respondents. Moreover, the potential for harm to Florida's consumers posed by Respondents' ongoing conduct is severe and cannot be abated until a final order is issued. By contrast, any potential harm from issuing an immediate final order in this instance is likely to be de minimis. 35. The Office of Financial Regulation is entering this Immediate Final Order to prevent Respondents from posing a continuing and immediate danger to the public health, safety, or welfare. Accordingly, IT IS HEREBY ORDERED: A. Respondents and all persons acting in concert or cooperation with Respondents shall immediately CEASE and DESIST from: i. representing or holding themselves out as a financial institution; 11. advertising, soliciting or performing, directly or indirectly, any and all banking 7

activity, including but not limited to the solicitation or receipt of funds for deposit, opening business or personal bank accounts, issuing certificates of deposit, and paying any check in this state; m. operating, registering, storing, passively maintaining, or actively maintaining the website found athttps://www.springwellfinancialinc.com and any files or electronic data associated therewith; or 1v. operating, registering, storing, passively maintaining, or actively maintaining the domain name https:/lwww.springwellfinancialinc.com and any files or electronic data associated therewith. DONE and ORDERED this ~ day of June, 2026, in Tallahassee, Leon County, Florida. 8

NOTICE OF RIGHTS NOTICE IS HEREBY given that the foregoing Immediate Final Order is entered pursuant to section 120.569(2)(n), Florida Statutes, which provides that the Order is appealable or enjoinable from the date rendered. Section 120.68, Florida Statutes, further provides that any party to these proceedings who is adversely affected by this final agency action is entitled to judicial review. Section 120.68, Florida Statutes, and Rule 9.110, Florida Rules of Appellate Procedure, provide that judicial review must be instituted by filing a petition or notice of appeal with the Agency Clerk, Office of Financial Regulation, Office of General Counsel, Suite 504, Fletcher Building, 200 E. Gaines Street, Tallahassee, Florida 32399-0379, and a copy accompanied by filing fees prescribed by section 35.22, Florida Statutes, 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. Filings may also be made through the Florida Courts E-Filing Portal at https://www.myflcourtaccess.com. All review proceedings must be instituted within thirty (30) days after the rendition of this Order. Respondents may also apply to the District Court of Appeal for a supersedeas, or to the Office of Financial Regulation for a stay of this Order, pursuant to section 120.68(3), Florida Statutes. 9

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished 'r,.1-� by United States certified mail or,e]ectronic mail as set forth below to the following on this JQ, day of June, 2026: Springwell Financial Inc. lnfo@springwellfinancialinc.com Hostinger Internationa] Ltda compliance@hostinger.com. 61 Lordou Vyrones, Larnaca, 6023 Cyprus Betty Campuzzano bettycam puzano@hldrive.com 27 Rue Mohamed Abdallah 31000 Oran, Algeria RE 046 137 795 US RE 046 137 800 US f Financial Regu]ation Pos Office Box 8050 Ta11ahassee, Florida 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

VERIFIED DOCUMENT BY WRITTEN DECLARATION Page 1 of 3 STATE OF FLORIDA ) ) s.s. COUNTY OF ORANGE ) I, Reina Rivero, declare and state as follows;

1. I am Reina Rivero, Financial Investigator Criminal Enforcement (FICE) with the Emergent Financial Crimes Unit of the Bureau of Financial Investigations (BFI), for the Florida Office of Financial Regulation (OFR).
2. I have been working with the BFI since February 2023. Operating in an official capacity, I conduct criminal, administrative, and civil investigations within the regulatory jurisdiction of the OFR. I am experienced in reviewing complaints, interviewing witnesses and targets, collecting and processing intelligence, and preparing investigative reports. I have earned the Chainalysis Reactor Certification (hereinafter referred to as “CRC”), Chainalysis Cryptocurrency Fundamentals Certification (CCFC), and the Chainalysis Ethereum Investigations Certification (CEIC) issued by the blockchain analysis firm Chainalysis. I have successfully retested completed 40 hours of continuing professional education. The majority of these specialized courses relate to subject matter that pertains to conducting investigations that involve engaging in fraud for financial gain, forfeiture procedures, financial documents analysis, and Cyber Investigations through the National White Collar Crime Center, Florida Public Safety Institute, Association of Certified Fraud Examiners, and International Association of Financial Crimes Investigators. I have been a Certified Fraud Examiner (hereinafter referred to as “CFE”) in good standing with the International Association of Certified Fraud Examiners (hereinafter referred to as “ACFE”) since June
3. I received a Bachelor of Science Degree in Accounting.
4. On February 10, 2026, I was alerted by BFI Manager/Computer Examiner, Kris Ignatowicz of information reflecting the online presence of an unchartered/unlicensed financial institution operating as Springwell Financial Inc (“Springwell”).
5. The information centered on representations made via Springwell’s website, which is active as of the date of this declaration: a) Springwell’s website has a URL of https://springwellfinancialinc.com/index.
6. The website indicated that Springwell offers banking services that include business and personal banking, savings and checking accounts, lending, mortgages, and online and mobile banking among others (Exhibit 1). Springwell’s website provided a section for “Business Accounts” that highlights business checking and savings accounts, certificates of deposit, money market accounts, and business debit & credit cards (Exhibit 2), a “Lending” section that offers small business loans, SBA loans, USDA business loans, and business relief programs (Exhibit 3), a “Personal” section that lists checking and savings accounts, debit & credit cards, and online and mobile banking, (Exhibit 4), a “Mortgages” section that offers mortgage products such as First-Time Home Buyer, Down Payment Assistance, Fixed & Adjustable Rate, FHA, VA & USDA, and Jumbo Home Loans (Exhibit 5). Additionally, there is a section to log in that provides fields to enter an account number and password (Exhibit 6).
7. The website does not indicate the physical location for Springwell’s corporate office; however, it lists routing and NMLS numbers associated with an unrelated, registered financial entity in Florida (Exhibit 7). The website also displays in its section “Giving Back” pictures that correspond to charitable events that have been published on the unrelated financial entity's website (Exhibit 8).
8. On February 12, 2026, I verified Springwell is not and has never been a chartered or licensed financial institution, through research and review of information found on the website National Information Center (NIC), which is a Attachment A

VERIFIED DOCUMENT BY WRITTEN DECLARATION Page 2 of 3 repository of financial data and institution characteristics collected by the Federal Reserve System on financial institutions worldwide. I further confirmed that the entity is not, and has never been, a member of the Federal Deposit Insurance Corporation (FDIC). I have confirmed that Springwell has never been registered to lawfully operate as a business entity in Florida, based on research and review of the Florida Department of State, Division of Corporations, at Sunbiz.org. 8. On February16, 2026, I verified Springwell is not and has never been registered with the Financial Industry Regulatory Authority, through research and review of information found on the website FINRA.org (FINRA), which is a self-regulatory organization for member broker-dealers that is responsible under federal law for supervising member firms. I further confirmed that the entity is not and has never been licensed with the Office of Financial Regulation (OFR). 9. On February 18, 2026, using open-source tools such as WHO.is and ICANN.org, I found the Registrar of springwellfinancialinc.com is Hostinger International Ltd, and the website was registered on November 6, 2023 (Exhibit 9). According to Sitereport.NetCraft.com, the IP Address associated with the website creation is 66.45.244.235, which ARIN shows was registered on September 23, 2003 (Exhibit 10). Google search indicates that the website was first indexed in November 2023 (Exhibit 11). Utilizing WebsiteSEOChecker shows the springwellfinancialinc.com website does not receive enough traffic for daily and/or monthly figures to register (Exhibit 12). 10. On March 23, 2026, I served subpoena # 2026-12 to Hostinger International Ltd (“Hostinger”) to identify the owner of the domain springwellfinancialinc.com. On March 24, 2026, the subpoena recipient provided information showing that the email address associated with Springwell’s website is bettycampuzano@hldrive.com. Using open-source tools such as Usercheck.com, I found that hldrive.com (the e￾mail domain server associated with the e-mail account) operates as a disposable email domain, also known as a temporary or throwaway email service. These domains are often used to create short-lived email accounts with mailboxes that typically exist only briefly. The production also indicated that the IP address associated with the most recent login is 103.107.197.117 on 11/09/2025. Subsequently, I asked Hostinger to provide additional information that assists in determining the domain owner. 11. On April 3, 2026, upon reviewing further information provided by Hostinger, I found that the domain owner is Betty Campuzano, whose registered address, according to the records received is, 27 Rue Mohamed Abdallah, 31000, Oran, Algeria, with the phone number +213 41 58 34 53. The most recent payment made by the user was on 11/09/2025 through Coingate.com for $18.19 to renew the domain for 1 year. 12. On May 13, 2026, I inquired of Tammie Dull, the Records Custodian for the Florida Office of Financial Regulation, Division of Financial Institutions (the state agency responsible for chartering all state financial institutions), as to the licensure or registration status of Springwell Financial Inc. She confirmed there was no record of registration for that entity with the Office. Websites Utilized

1. Federal Deposit Insurance Corporation’s (FDIC) Details and Financials Institutions – Institutions Directory website at https://www7.fdic.gov/idasp/advSearchLanding.asp
2. Federal Financial Institution Examination Counsel’s NIC website at https://www.ffiec.gov/NPW
3. Financial Industry Regulatory Authority website at https://brokercheck.finra.org/
4. REAL System Regulatory Enforcement and Licensing website at https://real.flofr.gov/datamart/selSearchType.do
5. Florida Department of State, Division of Corporations at www.sunbiz.org
6. Google Search at https://www.google.com/search?q=About+https://www.springwellfinancialinc.com/
7. Who is Domain Lookup at https://who.is
8. ICann Look Up at www.Lookup.icann.org

VERIFIED DOCUMENT BY WRITTEN DECLARATION Page 3 of 3 9. American Registry for Internet Numbers at www.Arin.net 10. Website SEO Checker at www.websiteseochecker.com 11. User Check at https://www.usercheck.com/domain/hldrive.com Pursuant to Section 92.525, Florida Statutes, under penalties of perjury, I declare that I have read the foregoing document and that the facts stated in it are true. /s/ Reina Rivero Dated: June 9, 2026

EXHIBIT – 1

EXHIBIT – 2

EXHIBIT – 3

EXHIBIT – 4

EXHIBIT – 5

EXHIBIT – 6

EXHIBIT – 7

EXHIBIT – 8

EXHIBIT – 9

Registration data lookup tool Enter a domain name or an Internet number resource (IP Network or ASN) Frequently Asked Questions (FAQ) (/en/faq) springwellfinancialinc.com Lookup By submitting any personal data, I acknowledge and agree that the personal data submitted by me will be processed in accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy), and agree to abide by the website Terms of Service (https://www.icann.org/privacy/tos) and the registration data lookup tool Terms of Use (unsafe:javascript:void(0)). For additional information on ICANN Accredited Registrars including website and contact information, please visit https://www.icann.org/en/accredited-registrars (https://www.icann.org/en/accredited-registrars). If the registration data you are seeking is not provided in the lookup results, please use the Registration Data Request Service (RDRS) (https://rdrs.icann.org/) to submit a request for nonpublic registration data. RDRS is intended for use by requestors with a legitimate interest in accessing nonpublic registration data. Domain Information Name: SPRINGWELLFINANCIALINC.COM Registry Domain ID: 2827464452_DOMAIN_COM-VRSN Domain Status: clientTransferProhibited (https://icann.org/epp#clientTransferProhibited) Nameservers: DNS1400A.TROUBLE-FREE.NET DNS1400B.TROUBLE-FREE.NET Dates Registry Expiration: 2026-11-06 02:20:57 UTC Registrar Expiration: 2026-11-06 02:20:57 UTC Updated: 2025-11-09 14:20:26 UTC Created: 2023-11-06 02:20:57 UTC Contact Information English (/en)

Registrant: Handle: The RDAP server redacted the value Name: The RDAP server redacted the value Organization: The RDAP server redacted the value Phone: The RDAP server redacted the value Mailing Address: The RDAP server redacted the value ISO-3166 Code: LT Contact Uri: https://www.hostinger.com/whois?domain=springwellfinancialinc.com&view=contact (https://www.hostinger.co m/whois?domain=springwellfinancialinc.com&view=contact) Privacy protection provided by hostinger: registrant contact data has been redacted for privacy protection. Registrar Information Name: HOSTINGER operations, UAB IANA ID: 1636 Abuse contact email: abuse@hostinger.com Abuse contact phone: tel:+1-212-252-2172 About the Registrar: https://rdap.hostinger.com/ (https://rdap.hostinger.com/) DNSSEC Information Delegation Signed: Unsigned Authoritative Servers Registry Server URL: https://rdap.verisign.com/com/v1/domain/springwellfinancialinc.com (https://rdap.verisign.com/com/v1/dom ain/springwellfinancialinc.com) Last updated from Registry RDAP DB: 2026-03-09T19:52:55Z Registrar Server URL: https://rdap.hostinger.com/domain/SPRINGWELLFINANCIALINC.COM (https://rdap.hostinger.com/domai n/SPRINGWELLFINANCIALINC.COM) Last updated from Registrar RDAP DB: 2026-03-09T19:52:55Z Notices and Remarks

Remarks: Privacy Protection Provided by Hostinger Registrant contact data has been redacted for privacy protection. Notices: Terms of Service By using this RDAP service, you agree to Hostinger’s applicable terms of service and privacy policy. https://www.hostinger.com/legal/universal-terms-of-service-agreement (https://www.hostinger.com/legal/universal-terms-of-service -agreement) RDDS Inaccuracy Complaint Form URL of the ICANN RDDS Inaccuracy Complaint Form: https://icann.org/wicf https://icann.org/wicf (https://icann.org/wicf) Status Codes For more information on domain status codes, please visit https://icann.org/epp https://icann.org/epp (https://icann.org/epp)  Youtube (https://www.youtube.com/icannnews)  Twitter (https://www.twitter.com/icann)  Linkedin (https://www.linkedin.com/company/icann)  Flickr (https://www.flickr.com/photos/icann)  Facebook (https://www.facebook.com/icannorg)  Newletters (https://www.icann.org/resources/pages/global-newsletter-2018)  Community Wiki (https://community.icann.org/)  ICANN Blog (https://www.icann.org/news/blog) WHO WE ARE CONTACT US ACCOUNTABILITY AND TRANSPARENCY GOVERNANCE HELP DATA PROTECTION © Internet Corporation for Assigned Names and Numbers. Privacy Policy (https://www.icann.org/privacy/policy) Terms of Service (https://www.icann.org/privacy/tos) Cookies Policy (https://www.icann.org/privacy/cookies)

EXHIBIT – 10

EXHIBIT – 11

EXHIBIT – 12