FLORIDA OFFICE OF FINANCIAL REGULATION : www.FLOFR.com DREW J. BREAKSPEAR COMMISSIONER October 30, 2014 a 5 §2Y Via U.S. Certified Mail S & G Multi Services, LLC. c/o George Valeus, Manager 945 W. Sunrise Blvd Ft. Lauderdale, FL 33311 To: Mr. Valeus, Enclosed you will find a copy of an Administrative Complaint filed against S & G Multi Services, LLC., alleging violations of Chapter 560, Florida Statutes. If S & G Multi Services, LLC. does not respond to the Complaint within 21 days after receipt, a Final Order will be entered against it as indicated in the Administrative Complaint. If you have any questions or concerns, please do not hesitate to contact me at 850-410-9716. Sincerely, Shes ; 31 7299 9991 7034 6890 9439 Sheila Y. ry rt Assistant General Counsel 101 EAST GAINES STREET, TALLAHASSEE, FLORIDA® (850) 410-9887¢ FAX (850) 410-9914 MAILING ADDRESS: 200 EAST GAINES STREET, TALLAHASSEE, FLORIDA 32399-0376 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION IN RE: S & G MULTI SERVICES, LLC., Respondent. _ Administrative Proceeding Docket Number: 0925-M-10/13 ADMINISTRATIVE COMPLAINT Comes now, the State of Florida, Office of Financial Regulation, (“Office”) and files this Administrative Complaint against S & G MULTI SERVICES, LLC. (“Respondent”), alleging: ENE. 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 subsection 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. At all times material hereto, Respondent is or has been a Part III Money Transmitter licensee pursuant to Chapter 560, Florida Statutes, and specifically a “money services business,” as defined in section 560.103(22), Florida Statutes, having been issued license number FT30900544. 4, Atall times material, Respondent’s address of record is and has been 945 W. Sunrise Blvd, FL 33311, whose owner of record with the Office is and has been George Valeus. 3. From July 15, 2013 to July 23, 2013, the Office conducted an examination (#44520) for the time period of July 1, 2011 through June 30, 2013 (“examination period”) of Respondent's business records. 6. Pursuant to Rule 69V-560.1000(150), Florida Administrative Code, the range for an “A” level fine is between $1,000 and $3,500; and pursuant to Rule 69V-560.1000(151), Florida Administrative Code, the range for an “A” suspension is 3 to 10 days. 7. Pursuant to Rule 69V-560.1000(150), Florida Administrative Code, the range for a “B” level fine is between $3,500 and $7,500; and, pursuant to Rule 69V-560.1000(151), Florida Administrative Code, the range for a “B” suspension is 10 to 20 days. 8. During the examination period, Respondent conducted money services business as a check casher. COUNTI 1. The above general allegations 1 through 8 are hereby re-alleged and incorporated by reference as if fully stated herein. 2. During the examination period, Respondent cashed payment instruments exceeding $1,000. 3. When payment instruments of greater than $1,000 are cashed, subsection 560.310(2)(d), Florida Statutes (2012), and Rule 69V-560.704(5)(a), Florida Administrative Code, require licensees to maintain a detailed electronic payment instrument (check) log that includes at least eleven categories of information. 4. Respondent failed to maintain a complete payment instrument log in contradiction and violation of subsection 560.310(2)(d), Florida Statutes, and Rule 69V 560.704(S)(a), Florida Administrative Code. 5. Pursuant to Rule 69V-560.1000(98), Florida Administrative Code, a licensee cited for 2 the first time for failing to maintain a complete payment log is subject to a “B” fine and a “B” suspension. 6. Therefore, the Office is seeking an administrative fine of $3,900 and no suspension. COUNT II 7,,.The above general allegations 1 through 8 are hereby re-alleged and incorporated by reference as if fully stated herein. 8. During the examination period, Respondent cashed payment instruments exceeding $1,000. 9. Subsection 560.310(2)(a), Florida Statutes, requires licensees to maintain customer files on all customers who cash corporate or third-party instruments exceeding $1,000. 10. Respondent failed to maintain customer files on all customers who cash corporate or third-party instruments exceeding $1,000, in contradiction and violation of subsection 560.310(2)(a), Florida Statutes. 11. Pursuant to Rule 69V-560.1000(95), Florida Administrative Code, a licensee cited for the first time for failing to maintain customer files on all customers who cash corporate or third- party instruments exceeding $1,000 is subject to a “B” fine and a “B” suspension. 12. Therefore, the Office is seeking an administrative fine of $7,500 and no suspension. COUNT IL 13. The above general allegations 1 through 8 are hereby re-alleged and incorporated by reference as if fully stated herein. 14. During the examination period, Respondent cashed payment instruments. 15. Subsection 560.309(2), Florida Statutes, requires that when licensees cash payment instruments, the payment instrument must be endorsed using the legal name under which the licensee is licensed. 16. Respondent failed to endorse cashed payment instruments using the legal name under which it was licensed in contradiction and violation of subsection 560.309(2), Florida Statutes. 17. Pursuant to Rule 69V-560.1000(84), Florida Administrative Code, a licensee cited for the first time for failing to endorse payment instruments using the legal name under which it is licensed is subject to a “B” fine and a “B” suspension. 18. Therefore, the Office is seeking an administrative fine of $7,500. COUNT IV 19, The above general allegations 1 through 8 are hereby re-alleged and incorporated by reference as if fully stated herein. 20, Form OFR-560-01 , which is incorporated by reference into Rule 69V-560.1012, Florida Administrative Code, requires license applicants to list every bank account through which registered activities are or will be conducted. 21. Respondent submitted its initial money services business application! in April of 2007, and represented that it did not currently have a bank account through which registered activities are or would be conducted. 22. In 2007, Respondent opened two Wells Fargo bank accounts (for the purpose of conducting registered activities). 23. On July 16, 2013, Respondent amended its application to reflect two Wells Fargo bank accounts, which are the same bank accounts that were opened in 2007. 24. Pursuant to subsection 560.126(2), Florida Statutes, and Rules 69V-560.1012, and 69V-560.102(5), Florida Administrative Code, licensees are required to report any change in the information contained in its application form within 30 days of a change. 1 /K/A money transmitter application, 25. In contradiction and violation of subsection 560.126(2), Florida Statutes, and Rules 69V-560.1012 and 69V-560.102(5), Florida Administrative Code, Respondent failed to report (within 30 days) the openings of its Wells Fargo bank accounts. 26. Pursuant to Rule 69V-560.1000(52), Florida Administrative Code, a licensee cited for the first time for failing to report (within 30 days) the openings of bank accounts is subject to an “A” fine. 27. Therefore, the Office is seeking an administrative fine of $2,000. WHEREFORE, Respondent, § & G MULTI SERVICES, LLC., is hereby notified that the Office intends to enter an Order imposing a fine of $20,900 and/or imposing other penalties that may be provided for in Chapter 560, Florida Statutes. NOTICE OF RIGHTS The licensee is entitled to be represented by counsel or other 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 or Fax OR B d Deliv. Office of Financial Regulation Office of Financial Regulation P.O. Box 8050 General Counsel’s Office Tallahassee, FL 32314-8050 The Fletcher Building, Suite 118 Phone: (850) 410-9987 101 East Gaines Street Fax: (850) 410-9914 Tallahassee, FL 32399-0379 Phone: (850) 410-9987 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. DATED and SIGNED this QMay of { x! Oles , 2014. DREW J. BREAKSPEAR Commissioner By: Sheila 6 Assistant General Counsel Office of Financial Regulation Fla. Bar No. 844241 101 E. Gaines Street Tallahassee, FL 32399-0379 (850) 410-9887 (850) 410-99 14 (fax) Sheila.harley@ flofr.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been furnished by certified U.S. mail, Return Receipt Requested to S & G MULTI SERVICES, LLC., c/o George Valeus, Manager, at 945 W. Sunrise Blvd, Fort Lauderdale, FL 33311 on this 3M. of _OCIRRET , 2014. Sheila Harley Assistant General Counsel Office of Financial Regulation Fla. Bar No. 844241 101 E. Gaines Street Tallahassee, FL 32399-0379 (850) 410-9887 (850) 410-9914 (fax) Sheila-harley @ flofr.com STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION OFR Case No: 0925-M-10/13 S & G Multi Services, LLC. 945 W. Sunrise Blvd Ft. Lauderdale, FL 33311 ELECTION OF PROCEEDING | have received and read the Administrative Complaint, including the Notice of Rights, filed by the Office of Financial Regulation (“Office”) regarding the above-referenced licensee. As the licensee or the authorized representative of the licensee, | am requesting disposition as indicated below. (CHECK A BOX FOR NUMBER 1, 2, OR 3) 1. [ ] Ido not dispute any of the Office’s factual allegations and application of the law as stated in the Administrative Complaint. Therefore, | do not request a hearing in this matter. | understand that upon my waiving the right to a hearing, the Office may enter a final order imposing a penalty as set forth in the Administrative Complaint. 2. 1 do not dispute any of the Office’s factual allegations but dispute the Office’s application of the law to those factual allegations, and request disposition of this matter pursuant to Section 120.57(2), Florida Statutes. | request to (CHECK ONE OF THE FOLLOWING OPTIONS): [ ] Submit a written statement with supporting documentation to a Hearing Officer in lieu of a hearing; OR [ ] In person, attend a hearing conducted by a Hearing Officer; OR ( ] By telephone conference call, attend a hearing conducted by a Hearing Officer. 3. [ ] 1 do dispute one or more of the Office’s factual allegations. | request a section 120.57(1), Florida Statutes, formal hearing before the Division of Administrative Hearings. Pursuant to the requirements of Rule 28-106.2015(5)(c), Florida Administrative Code, |_ am attaching the material facts that | dispute (SEE PAGE 2). TO PRESERVE THE RIGHT TO A HEARING, A RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION WITHIN TWENTY-ONE (21) DAYS OF THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. THE 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. The address for filing is: P.O. Box 8050, Tallahassee, Florida 32314-8050. If hand delivery Is preferred, the physical address Is: General Counsel’s Office, The Fletcher Building, Suite 118, 101 E. Gaines Street, Tallahassee, FL 32399. Signature of Licensee or Mailing Address Authorized Representative of Licensee Printed Name & Title City State Zip Date E-mail Address Telephone Number Fax Number Date Administrative Complaint was Received: Election of Proceeding Page 1 of 2 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION OFR Case No: 0925-M-10/13 S & G Multi Services, LLC. 945 W. Sunrise Blvd Ft. Lauderdale, FL 33311 **YOU ARE TO COMPLETE THE FOLLOWING ONLY IF YOU HAVE CHECKED NUMBER 3 ON THE PRECEDING PAGE, If you need more space, you may provide additional pages. As the licensee or the authorized representative of the licensee, | am disputing the following material Signature of Licensee or Authorized Representative Date Election of Proceeding Page 2 of 2

Docket for Case No: 15-002642