STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

OFFICE OF FINANCIAL REGULATION,

vs.

Petitioner,

Case No. 14-2545

GREENLAND FOOD MARKET, INC.,

Respondent.

/

RECOMMENDED ORDER

This case came before Administrative Law Judge John G. Van Laningham for final hearing by video teleconference on July 25, 2014, at sites in Tallahassee and Miami, Florida.

APPEARANCES

For Petitioner: Jennifer Leigh Blakeman, Esquire

Office of Financial Regulation

400 West Robinson Street, Suite S-225 Orlando, Florida 32801

For Respondent: Bassam Dimiati, pro se

Greenland Food Market, Inc. 5723 Southwest 23rd Street Hollywood, Florida 33023

STATEMENT OF THE ISSUES

The primary issues in this case relate to whether Respondent, a licensed check cashing concern, failed to make and maintain various records documenting regulated financial transactions undertaken during a two-year audit period (2011- 2012), as Petitioner alleges. If Respondent is found guilty of

any disciplinable offense(s), then it will be necessary to determine the appropriate penalties for such violation(s).

PRELIMINARY STATEMENT

On March 28, 2014, Petitioner Office of Financial Regulation issued an Administrative Complaint against Respondent Greenland Food Market, Inc., charging the licensed check casher with several disciplinable offenses relating to noncompliance with the statutes and rules governing the business of cashing payment instruments.

The licensee timely exercised its right to be heard in a formal administrative proceeding. On May 29, 2014, the agency referred the matter to the Division of Administrative Hearings, where the case was assigned to an Administrative Law Judge.

Thereafter, the agency sought, and on July 15, 2014, was granted, leave to file an Amended Administrative Complaint, which it did.

The final hearing took place as scheduled on July 25, 2014, with both parties present. The agency called three witnesses: Maykel Rico, Ronald Cap, and Andrew Grossmaire. Petitioner's Exhibits 1 through 10 were received in evidence as well. The licensee's president and sole shareholder, Bassam Dimiati, testified on Respondent's behalf and offered Respondent's Exhibits B and E, which were admitted into evidence without objection.

The final hearing transcript was filed on August 18, 2014.

Following that, each party timely submitted a Proposed Recommended Order on or before September 8, 2014, in accordance with the deadline established at the conclusion of the hearing.

Unless otherwise indicated, citations to the Florida Statutes refer to the 2014 Florida Statutes, except that all references to statutes or rules defining disciplinable offenses or prescribing penalties for committing such offenses are to the versions that were in effect at the time of the alleged wrongful acts.

FINDINGS OF FACT

1. At all times relevant to this case, Respondent Greenland Food Market, Inc. (the "Market"), held a license to engage in the business of cashing payment instruments, such as checks, pursuant to chapter 560, part III, Florida Statutes. Bassam Dimiati is the Market's president and sole shareholder.

2. Petitioner Office of Financial Regulation ("OFR" or the "Office") is the state agency charged with licensing and supervising money services businesses in Florida. Licensed check cashers, such as the Market, fall within the Office's regulatory and disciplinary jurisdiction. On at least one previous occasion, the Office imposed discipline against the Market for failing to maintain books and records.1/

   
   

3. On May 6, 2013, OFR conducted a routine on-site examination of the Market's records to evaluate the licensee's compliance with the statutes and rules governing the check cashing business. OFR had given the Market advance notice of the examination. The two-year period under review was from January 1, 2011, through December 31, 2012. The examiners found, and OFR proved at hearing, that the Market had not complied fully with the applicable record-creation and

   -retention requirements, as detailed below.

   
   

   Missing Identification Numbers

   
   

4. Check cashers must maintain an electronic payment instrument log documenting each transaction involving a check in the amount of $1,000 or more. For each such transaction, the log must include, among other required information, the identification number——e.g., the Florida driver license number—— of the person seeking to cash the check, who is referred to formally as a "conductor."2/

5. The Market's log for 2012 lists 156 transactions. Of these, the conductor's identification number was not recorded

   57 times, in violation of section 560.310(1)(c), Florida Statutes (2011),3/ and Florida Administrative Code Rule 69V- 560.704(5)(a). Thus, it is determined, as a matter of ultimate fact, that the Market is guilty as charged of failing to include identification numbers in its electronic payment instrument log.

   
   

   Missing Endorsements

   
   

6. A licensed check cashing business is required to make and keep a legible, complete copy (including both sides) of every check accepted. Further, at the time the licensee accepts a payment instrument, the licensee must endorse the instrument using the legal name appearing on its license. Thus, if the licensee is fully compliant, the licensee's copy of each check cashed will show the requisite endorsement.

7. The Market failed properly to maintain copies of every payment instrument received. Showing leniency, OFR allowed the Market to obtain copies of canceled checks from its bank, even though a licensee is not entitled to rely upon bank records as a substitute for the licensee's own records.4/ Out of 720 payment instruments retrieved from the bank, 280 lacked an endorsement, or at least a legible endorsement, in contravention of

   section 560.309(2) and rule 69V-560.704(2)(a). It is therefore determined, as a matter of ultimate fact, that the Market is guilty as charged of failing to endorse all payment instruments accepted during the period under review, or alternatively of failing to maintain a legible copy of each such check containing an identifiable facsimile of the endorsement.

   Missing Thumbprints

   
   

8. For each payment instrument accepted having a face value of $1,000 or greater, the licensee must——at the time of

   
   

   acceptance——affix the conductor's original thumbprint to the original payment instrument, a copy of which must be maintained, as mentioned above.

9. Of 720 payment instruments retrieved from the Market's bank, 38 exceeded $1,000. Only 23 of these checks bear a visible thumbprint, which means that the Market either accepted at least 15 checks without taking the required thumbprints, or alternatively failed to maintain legible copies of such prints, in violation of section 560.310(1)(b)2.5/ and rule 69V- 560.704(4)(a). Consequently, it is determined, as a matter of ultimate fact, that the Market is guilty as charged of failing to take, or alternatively of failing to maintain a legible copy of, a thumbprint of the customer in connection with every transaction involving a check having a face value of $1,000 or

   more.

   
   

   Missing Records of Fees Charged

   
   

10. For each check accepted, the licensee must keep a record showing the fee charged to cash the payment instrument. The Market created, kept, and made available to the Office a record showing the fee charged for each check having a face amount of $1,000 or more, but it failed to maintain a record of the fees charged for cashing any other checks.

11. Thus, when asked in writing on May 10, 2013, to produce "records that show the fee charged to customers for each

    
    

    payment instrument cashed prior to May 10, 2013," the Market responded that it could not provide additional documentation. On May 17, 2013, Mr. Dimiati signed a statement attesting that "[a]fter a diligent search" of all the Market's books and records, he was unable to locate the requested materials and had "no reasonable basis to believe" that information regarding the fees charged for cashing checks for amounts less than $1,000 would become available.

12. Accordingly, it is determined, as a matter of ultimate fact, that the Market is guilty as charged of failing to maintain and produce records reflecting the fee charged to each customer for the service of cashing a check, in violation of rule 69V-560.704(2)(b).

    Missing Corporate Customer Files

    
    

13. When accepting a check payable to a corporation, which is referred to as a "corporate payment instrument,"6/ the licensee must create and maintain a customer file on the payee if the amount of the check exceeds $1,000. This file must include: (i) documentation from the Secretary of State verifying registration as a corporation or fictitious entity and showing the officers and Federal Employer Identification Number;

    (ii) articles of incorporation or similar documentation; (iii) documentation of the occupational license; (iv) documentation from the Division of Workers' Compensation website showing proof

    
    

    of coverage; and (v) documentation of individuals authorized to negotiate payment instruments on the corporation or fictitious entity's behalf, including corporate resolutions or powers of attorney. See Fla. Admin. Code R. 69V-560.704(4)(d).

14. During the period under review, the Market cashed corporate payment instruments in amounts exceeding $1,000 for Impact Collision and Main Line Trucking. On May 10, 2013, OFR submitted a written request for the Market's customer files on Impact Collision and Main Line Trucking. Mr. Dimiati replied that, after a diligent search, he was unable to locate in the Market's records all of the information relating to these customers that rule 69V-560.704(4)(d) requires be kept on corporate payees.

15. The Market was unable to provide the following information about Impact Collision: (i) articles of incorporation or similar documentation; (ii) documentation of the occupational license; and (iii) documentation of individuals authorized to negotiate payment instruments on the corporation or fictitious entity's behalf, including corporate resolutions or powers of attorney.

16. The Market was unable to provide the following information about Main Line Trucking: (i) documentation of the occupational license and (ii) documentation of individuals authorized to negotiate payment instruments on the corporation

    
    

    or fictitious entity's behalf, including corporate resolutions or powers of attorney.

17. Consequently, it is determined, as a matter of ultimate fact, that the Market is guilty as charged of failing to maintain a complete customer file, i.e., one meeting all of the requirements prescribed in rule 69V-560.704(4)(d), for each corporate entity named as the payee in a corporate payment instrument, in violation of section 560.310(1)(a), Florida Statutes (2011).7/

    CONCLUSIONS OF LAW

    
    

18. The Division of Administrative Hearings has personal and subject matter jurisdiction in this proceeding pursuant to sections 120.569 and 120.57(1), Florida Statutes.

19. Section 560.114 sets forth the acts for which OFR may impose discipline. This statute provides, in pertinent part, as follows:

    1. The following actions by a money services business, authorized vendor, or affiliated party constitute grounds for the issuance of a cease and desist order; the issuance of a removal order; the denial, suspension, or revocation of a license; or taking any other action within the authority of the office pursuant to this chapter:

       
       

       * * *

       
       

       (e) Failure to maintain, preserve, keep available for examination, and produce all books, accounts, files, or other documents required by this chapter or related rules or

       
       

       orders, . . . , or by any agreement entered into with the office.

       
       

20. Regarding the charge that the Market failed to include identification numbers in its payment instrument log,

    section 560.310 provided at all relevant times that:

    
    

    A payment instrument log . . . must be maintained electronically as prescribed by rule. For purposes of this paragraph, multiple payment instruments accepted from any one person on any given day which total

    $1,000 or more must be aggregated and reported on the log.

    
    

    § 560.310(1)(c), Fla. Stat. (2011); § 560.310(2)(d), Fla. Stat. (2012).

21. By rule, the Department of Financial Services has established the following minimum requirements for the contents of payment instrument logs:

    In addition to the records required in subsections (1) and (2) for payment instruments $1,000.00 or more, the check casher shall create and maintain an electronic log of payment instruments accepted which includes, at a minimum, the following information:

    
    

    1. Transaction date;

    2. Payor name;

    3. Payee name;

    4. Conductor name, if other than the payee;

    5. Amount of payment instrument;

    6. Amount of currency provided;

    7. Type of payment instrument;

       1. Personal check;

       2. Payroll check;

       3. Government check;

       4. Corporate check;

       5. Third party check; or

          
          

       6. Other payment instrument;

    8. Fee charged for the cashing of the payment instrument;

    9. Branch/Location where instrument was accepted;

    10. Identification type presented by conductor; and

    11. Identification number presented by conductor.

    
    

    Fla. Admin. Code R. 69V-560.704(5)(a).

    
    

22. As for endorsements, section 560.309(2) provides:

    
    

    At the time a licensee accepts a payment instrument that is cashed by the licensee, the payment instrument must be endorsed using the legal name under which the licensee is licensed.

    
    

23. Rule 69V-560.704(2) amplifies and further defines not only the duty to endorse, but also the obligation to maintain legible records, providing in pertinent part as follows:

    1. Every check casher shall maintain legible records of all payment instruments cashed. The records shall include the following information with respect to each payment instrument accepted by the registrant:

       
       

       1. A copy of all payment instruments accepted and endorsed by the licensee to include the face and reverse (front and back) of the payment instrument. Copies shall be made after each payment instrument has been endorsed with the legal name of the licensee. Endorsements on all payment instruments accepted by the check casher shall be made at the time of acceptance.

          
          

       2. The fee charged to cash the payment instrument[.]

    
    

24. Section 560.310(1)(b)2., Florida Statutes (2011), obligated licensees, for any check having a face value of $1,000 or more, to maintain a "thumbprint of the customer taken by the licensee." See also § 560.310(2)(c), Fla. Stat. (2012).

    Rule 69V-560.704(4)(a) further specifies that the check casher must "[a]ffix an original thumbprint of the conductor to the original of each payment instrument accepted which is taken at the time of acceptance."

25. Section 560.310(1)(a), Florida Statutes (2011), directed the licensee to maintain, for all corporate payment instruments exceeding $1,000, "[c]ustomer files, as prescribed by rule, on all customers" presenting such checks for payment. See also § 560.310(2)(a), Fla. Stat. (2012).

26. The Department of Financial Services prescribed by rule the following granular requirements respecting corporate customer files:

    [F]or payment instruments exceeding

    $1,000.00, the check casher shall:

    
    

    * * *

    
    

    (d) Create and maintain a customer file for each entity listed as the payee on corporate payment instruments and third party payment instruments accepted by the licensee. Each customer file must include, at a minimum, the following information:

    
    

    1. Documentation from the Secretary of State verifying registration as a corporation or fictitious entity showing the

       
       

       listed officers and FEID registration number. If a sole proprietor uses a fictitious name or is a natural person, then the customer file shall include the social security number of the business owner and documentation of the fictitious name filing with the Secretary of State.

    2. 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.

    3. Documentation of the occupational license from the county where the entity is located.

    4. 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 . . . .

    5. Documentation of individuals authorized to negotiate payment instruments on the corporation or fictitious entity's behalf including corporate resolutions or powers of attorney.

    
    

    Fla. Admin. Code R. 69V-560.704(4).

    
    

27. In regard to records retention generally,

    
    

    section 560.1105 provided at all relevant times as follows:

    
    

    Each licensee and its authorized vendors must maintain all books, accounts, documents, files, and information necessary for determining compliance with this chapter and related rules for 5 years unless a longer period is required by other state or federal law.

    
    

    1. The records required under this chapter may be maintained by the licensee at any location identified in its license application or by amendment to the application. The licensee must make such

       
       

       records available to the office for examination and investigation in this state within 3 business days after receipt of a written request.

       
       

28. The foregoing statutes and rules "must be construed strictly, in favor of the one against whom the penalty would be imposed." Munch v. Dep't of Prof'l Reg., Div. of Real Estate,

    592 So. 2d 1136, 1143 (Fla. 1st DCA 1992); see Camejo v. Dep't

    
    

    of Bus. & Prof'l Reg., 812 So. 2d 583, 583-84 (Fla. 3d DCA 2002); McClung v. Crim. Just. Stds. & Training Comm'n, 458 So.

    2d 887, 888 (Fla. 5th DCA 1984)("[W]here a statute provides for revocation of a license the grounds must be strictly construed because the statute is penal in nature. No conduct is to be regarded as included within a penal statute that is not reasonably proscribed by it; if there are any ambiguities included, they must be construed in favor of the licensee."); see also, e.g., Griffis v. Fish & Wildlife Conserv. Comm'n, 57

    So. 3d 929, 931 (Fla. 1st DCA 2011)(statutes imposing a penalty must never be extended by construction).

29. A proceeding, such as this one, to suspend, revoke, or impose other discipline upon a license is penal in nature. State ex rel. Vining v. Fla. Real Estate Comm'n, 281 So. 2d 487,

    491 (Fla. 1973). Accordingly, to impose discipline, the Office must prove the charges against the Market by clear and convincing evidence. Dep't of Banking & Fin., Div. of Sec. &

    
    

    Investor Prot. v. Osborne Stern & Co., 670 So. 2d 932, 933-34

    
    

    (Fla. 1996)(citing Ferris v. Turlington, 510 So. 2d 292, 294-95 (Fla. 1987)); Nair v. Dep't of Bus. & Prof'l Reg., Bd. of Med.,

    654 So. 2d 205, 207 (Fla. 1st DCA 1995).

    
    

30. Regarding the standard of proof, in Slomowitz v.

    
    

    Walker, 429 So. 2d 797, 800 (Fla. 4th DCA 1983), the court developed a "workable definition of clear and convincing evidence" and found that of necessity such a definition would need to contain "both qualitative and quantitative standards." The court held that:

    clear and convincing evidence requires that the evidence must be found to be credible; the facts to which the witnesses testify must be distinctly remembered; the testimony must be precise and explicit and the witnesses must be lacking in confusion as to the facts in issue. The evidence must be of such weight that it produces in the mind of the trier of fact a firm belief or conviction, without hesitancy, as to the truth of the allegations sought to be established.

    
    

    Id. The Florida Supreme Court later adopted the Slomowitz

    
    

    court's description of clear and convincing evidence. See In re Davey, 645 So. 2d 398, 404 (Fla. 1994). The First District

    Court of Appeal also has followed the Slomowitz test, adding the

    
    

    interpretive comment that "[a]lthough this standard of proof may be met where the evidence is in conflict, . . . it seems to preclude evidence that is ambiguous." Westinghouse Elec. Corp.

    
    

    v. Shuler Bros., Inc., 590 So. 2d 986, 988 (Fla. 1st DCA 1991),

    
    

    rev. denied, 599 So. 2d 1279 (Fla. 1992)(citation omitted).

    
    

31. As discussed above, the undersigned has determined, based on the clear and convincing evidence adduced by OFR, that the Market is guilty, as a matter of ultimate fact, of failing to comply with the following laws: section 560.310(1)(c) and rule 69V-560.704(5)(a), due to the identification numbers missing from the payment instrument log; section 560.309(2) and rule 69V-560.704(2)(a), because of the missing endorsements; section 560.310(1)(b)2. and rule 69V-560.704(4)(a), by virtue of the missing thumbprints; rule 69V-560.704(2)(b), for being unable to produce records reflecting the fee charged to each customer; and section 560.310(1)(a) and rule 69V-560.704(4)(d), as a result of having only incomplete customer files for two corporate payees.

32. In determining that the Market committed these violations, the undersigned concluded that the plain language of the applicable statutes and rules, being clear and unambiguous, could be applied in a straightforward manner to the historical events at hand without resorting to principles of interpretation or examining extrinsic evidence of legislative intent. It is therefore unnecessary to make additional legal conclusions concerning these violations.

    
    

33. The Office imposes penalties upon licensees in accordance with the disciplinary guidelines prescribed in rule 69V-560.1000.

34. The penalties for a first offense involving the failure to maintain a complete electronic payment log by, e.g., omitting some required customer identification numbers, as here, are a fine in an amount between $3,500 and $7,500 together with a suspension for a period lasting from ten to 20 days. Fla. Admin. Code R. 69V-560.1000(98), (150), & (151).

35. The penalties for a first offense involving the failure to endorse a payment instrument accepted or cashed are a fine in an amount between $3,500 and $7,500 together with a suspension for a period lasting from ten to 20 days. Fla. Admin. Code R. 69V-560.1000(84), (150), & (151).

36. The penalties for a first offense involving the failure to take all required customer thumbprints are a fine in an amount between $3,500 and $7,500 together with a suspension for a period lasting from ten to 20 days. Fla. Admin. Code

    R. 69V-560.1000(97), (150), & (151).

    
    

37. The penalties for a first offense involving the failure to maintain and produce records reflecting the fee charged to each customer are a fine in an amount between $1,000 and $3,500 together with a suspension for a period lasting from

    
    

    three to ten days. Fla. Admin. Code R. 69V-560.1000(5), (150), & (151).

38. The penalties for a first offense involving the failure to maintain a complete customer file for each corporate entity named as the payee in a corporate payment instrument are a fine in an amount between $3,500 and $7,500 together with a suspension for a period lasting from ten to 20 days. Fla. Admin. Code R. 69V-560.1000(95), (150), & (151).

39. Cumulatively, the penalties called for under the disciplinary guidelines for the violations OFR has established in this case are a fine in an amount between $15,000 and $33,000 together with a suspension for a period lasting from 43 to 90 days.

40. Rule 69V-560.1000(148) provides as follows:

    
    

    In accordance with Sections 560.1141(2)

    and (3), F.S., the Office shall consider the following circumstances in determining an appropriate penalty within the range of penalties prescribed in this rule for each violation as based upon the citation number. The Office also shall consider these circumstances in determining a penalty that deviates from the range of penalties prescribed for each violation and citation number as a result of such circumstances:

    
    

    1. Whether the violation rate is less than 5% when compared to the overall sample size reviewed;

    2. The degree of harm to the customers or the public;

    3. The disciplinary history of the licensee;

       
       

    4. Whether the licensee detected and voluntarily instituted corrective responses or measures to avoid the recurrence of a violation prior to detection and intervention by the Office;

    5. Whether the licensee's violation was the result of willful misconduct or recklessness;

    6. Whether at the time of the violation, the licensee had developed and implemented reasonable supervisory, operational or technical procedures, or controls to avoid the violation;

    7. Where the violation is attributable to an individual officer, director, responsible person, or authorized vendor, whether the licensee removed or otherwise disciplined the individual prior to detection and intervention by the Office;

    8. Whether the licensee attempted to conceal the violation or mislead or deceive the Office;

    9. The length of time over which the licensee engaged in the violations;

    10. Whether the licensee engaged in numerous violations or a pattern of misconduct;

    11. The number, size and character of the transactions in question;

    12. Whether the licensee provided substantial assistance to the Office in its examination or investigation of the underlying misconduct;

    13. Other relevant, case-specific circumstances.

    
    

41. The Office has urged the undersigned to recommend that the Market be fined $20,400 and its license be suspended for 30 days. The Office regards the Market's disciplinary history as an aggravating factor, but concedes that the lack of proven harm to the customers or public is a mitigating factor. The undersigned concurs with the Office's observations and adds that

    
    

    none of the violations here involved a total lack of compliance with the regulatory scheme, but rather each entailed the failure to comply fully with the various recordkeeping requirements.

    The Market, in other words, was compliant up to a point, albeit a point somewhat below the mark. Therefore, although the Market must be punished as a violator, in fairness it should not be treated as a scofflaw.

42. The undersigned acknowledges that the penalties which OFR proposes conform to the guidelines and fall within the agency's discretion. Indeed, the suggested 30-day suspension reflects a 30 percent reduction of the minimum suspension of

43 days prescribed by the guidelines. To be consistent, the undersigned recommends that an equivalent downward departure be made for the fine. Applying a 30 percent discount to the minimum fine (per the guidelines) of $15,000 reduces the monetary sanction to $10,500, which the undersigned views as a more reasonable amount under the circumstances.

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 finding Greenland Food Market, Inc., guilty of the offenses charged in the Amended Administrative Complaint. It is further RECOMMENDED that the Office impose a fine against

the Market in the amount of $10,500 and suspend its license for a period of 30 days.

DONE AND ENTERED this 17th day of September, 2014, in Tallahassee, Leon County, Florida.

S

JOHN G. VAN LANINGHAM

Administrative Law Judge

Division of Administrative Hearings The DeSoto Building

1230 Apalachee Parkway

Tallahassee, Florida 32399-3060

(850) 488-9675 SUNCOM 278-9675

Fax Filing (850) 921-6847 www.doah.state.fl.us

Filed with the Clerk of the Division of Administrative Hearings this 17th day of September, 2014.

ENDNOTES

1/ In re Greenland Food Market, Inc., Case No. 0277-M-02/09 (Fla. OFR Feb. 25, 2009)(available from the agency clerk).

2/ Pursuant to section 560.103(9), Florida Statutes, the term "conductor" "means a natural person who presents himself or herself to a licensee for purposes of cashing a payment instrument."

3/ Legislation enacted in 2012 relocated the operative statutory language to section 560.310(2)(d), Florida Statutes (2012).

4/ A licensee is permitted to store its business records with any third party except a depository institution. See

§ 560.310(2), Fla. Stat. (2011); § 560.310(3), Fla. Stat.

(2012).

5/ In 2012, the relevant statutory language was moved to section 560.310(2)(c), Florida Statutes (2012).

6/ See § 560.103(10), Fla. Stat. (defining "corporate payment instrument" as "a payment instrument on which the payee named on the instrument's face is other than a natural person").

7/ The relevant statutory language was transferred in 2012 to section 560.310(2)(a), Florida Statutes (2012).

COPIES FURNISHED:

Jennifer Leigh Blakeman, Esquire Office of Financial Regulation

400 West Robinson Street, Suite S-225 Orlando, Florida 32801

(eServed)

Bassam Dimiati, pro se Greenland Food Market, Inc. 5723 Southwest 23rd Street Hollywood, Florida 33023 (eServed)

Drew J. Breakspear, Commissioner Office of Financial Regulation

200 East Gaines Street Tallahassee, Florida 32399-0350 (eServed)

Colin M. Roopnarine, General Counsel Office of Financial Regulation

The Fletcher Building, Suite 118

200 East Gaines Street Tallahassee, Florida 32399-0370 (eServed)

NOTICE OF RIGHT TO SUBMIT EXCEPTIONS

All parties have the right to submit written exceptions within

15 days from the date of this Recommended Order. Any exceptions to this Recommended Order should be filed with the agency that will issue the Final Order in this case.

Docket for Case No: 14-002545

Orders for Case No: 14-002545