STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION IN RE: Administrative Proceeding JGP Financial, LLC, Docket Number: 70502 Paul L. Rutherford, and Jena Glatfelter, Respondents. ADMINISTRATIVE COMPLAINT The State of Florida, Office of Financial Regulation, (“Office”) files this Administrative Complaint against JGP Financial, LLC, Paul L. Rutherford, and Jena Glatfelter, (together, “Respondents”), and alleges: GENERAL ALLEGATIONS 1. Pursuant to sections 687.143, 687.144, and 687.148, Florida Statutes, the Office is charged with administering and enforcing the provisions of chapter 687, Florida Statutes, and conducting examinations and investigations to ensure compliance with the requirements of chapter 687. 2. Failure to comply with the provisions of section 687.143, Florida Statutes, related rules, order or written agreement constitutes grounds for disciplinary action. 3. Paul L. Rutherford, and Jena Glatfelter are managers of JGP Financial, LLC (“JPG”), and as such are principals of JPG as the term “principal” is defined by section 687.14(5), Florida Statutes. 4, Respondents’ current address of record is 6080 88" Ave., Pinellas Park, FL 33782. Prior to April 19, 2016, Respondents’ address was 8846 61° Street N., Pinellas Park, FL 33782. 1 5. Atall times material hereto, Respondent JGP Financial, LLC acted as a loan broker, as that term is defined by section 687.14(4), Florida Statutes. 6. Respondent JGP, LLC arranged or attempted to arrange or offered to fund a loan of money or a line of credit, or in expectation of consideration assisted or advised borrowers in obtaining or attempting to obtain a loan of money, line of credit, guarantee, enhancement or collateral. 7. Respondent JGP, LLC held itself out as a loan broker. 8. Section 687.141(1), Florida Statutes, proscribes loan brokers from assessing or collecting an advance fee from a borrower to provide services as a loan broker. 9. In violation of section 687.141(1), Florida Statutes, JGP assessed or collected advanced fees from borrowers for providing services to borrowers as a loan broker. 10. Pursuant to 687.142, Florida Statutes, each principal of a loan broker may be sanctioned for the actions of the loan broker, 11. Pursuant to section 687.143, Florida Statutes, the Office may impose and collect a fine not to exceed $5,000 for each violation of law, rule, order or written agreement under chapter 687, Florida Statutes. 12. The Office has identified eighteen (18) borrowers who were assessed or from whom was collected an advance fee in contravention of chapter 687. Therefore, the Office seeks a fine in the sum of $90,000 from Respondents. WHEREFORE, Respondents JGP Financial, LLC, Paul L. Rutherford, and Jena Glatfelter, are hereby notified that the Office intends to enter an Order imposing an administrative fine of Ninety Thousand ($90,000) on JGP Financial, LLC, Paul L. Rutherford, and Jena Glatfelter. 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 By Hand Delivery 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 fo § 20.573, Florida Statutes, is not available. DATED and SIGNED this G ay of July, 2017. DREW J. BREAKSPEAR Commissioner By: a Sc ~Fransen ssistant General Counsel Office of Financial Regulation Fla. Bar No. 0994571 1313 N. Tampa St., Suite 615 Tampa, FL 33602 Telephone: 813.218.5364 scott. fransen687 flofr.com CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been served by U.S. certified mail to JGP Financial, LLQ, Paul L. Rutherford, and lz fay of July, 2017. Jena Glatfelter, 6080 88" Ave., Pinellas Park, FL 33782, this ott R. Fransen Assistant General Counsel Office of Financial Regulation Fla. Bar No. 0994571 ATTACHMENT II

Docket for Case No: 17-004847