Final Decision & Order Affirming Initial Order on Summary Judgment

STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS 1 2 07-2025-DFI-00193 Act of DECISION & ORDER AFFIRMING INITIAL 3 : T MOTION 4 -Tots Swim School Holding LLC 5 6 THIS MATTER has come before the Director (“Director”) of the Washington State Department of 7 Financial Institutions (“Department”) for entry of the Director’s Final Decision & Order pursuant to RCW 8 34.05.464. 9 1.0 PROCEDURAL HISTORY 10 On May 5, 2025, the Director, through Securities Administrator William M. Beatty, entered a 11 Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist S-24-3853-25-SC01 (the 12 “Statement of Charges”) against Aqua-Tots Swim School Holding LLC. The Statement of Charges, together 13 with a Notice of Opportunity to Defend and Opportunity for Hearing, and an Application for Adjudicative 14 Hearing, were served on Respondent Aqua-Tots Swim School Holding LLC, by first class mail on May 8, 15

1. The Department received an Application for Adjudicative Hearing from Respondent Aqua-Tots Swim 16 School Holding LLC, on May 27, 2025. On June 30, 2025, the Department made a request to the Office of 17 Administrative Hearings (“OAH”) to assign an Administrative Law Judge (“ALJ”) to schedule and conduct 18 a hearing on the Statement of Charges. 19 On July 9, 2025, OAH issued a Notice of Prehearing Conference from ALJ Travis Dupree scheduling 20 DFI No.: S-24-3853-26-FO01 IN THE MATTER OF DETERMINING a prehearing conference on July 21, 2025, at 2:00 PM. OAH No.: Whether there has been a violation of the21 Franchise Investment Protection FINAL Washington by FINAL DECISION AND ORDER AFFIRMING 1 DEPARTMENT OF FINANCIAL INSTITUTIONS ORDER ON SUMMARY JUDGMEN22 Aqua

On July 21, 2025, Respondent and a representative for the Division attended a telephonic prehearing conference. On September 29, 2025, the Division filed a Motion for Summary Judgment. Respondent did not file 1 a response to the Department’s summary judgment motion. 2 On November 3, 2025, ALJ Dupree held a hearing on the Department’s Motion for Summary 3 Judgment, at which the Department and Respondent were both represented by counsel. 4 On December 2, 2025, ALJ Dupree issued an Initial Order on Summary Judgment Motion (“Initial 5 Order”). On December 2, 2025, OAH served the Initial Order on Respondent by first class mail. In the Initial 6 Order, ALJ Dupree granted the Department’s Motion for Summary Judgment, finding that no genuine issue 7 of fact remained, and that Respondent violated Chapter 19.100 RCW as set out in the Statement of Charges. 8 The Initial Order also ordered that Respondent cease and desist from any further violations of RCW 9 19.100.020. 10 Pursuant to RCW 34.05.464 and WAC 10-08-211, Respondent had twenty (20) days from the date of 11 service of the Initial Order to file a Petition for Review with the Director of the Department. Respondent did 12 not file a Petition for Review during the statutory period. 13 2.0 RECORD ON REVIEW 14 The record presented to the Director for his review and for entry of a Final Decision & Order was the 15 entire record on review from OAH, including the following: 16 2.1 Statement of Charges; 17 2.2 Certificate of Service of Statement of Charges; 18 2.3 Application for Adjudicative Hearing for Aqua-Tots Swim School Holding LLC; 19 2.4 Request to OAH for Assignment of Administrative Law Judge; 20 2.5 Department’s Notice of Appearance; 21

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2.6 Notice of Prehearing Conference, dated July 9, 2025, with documentation of service; 2.7 Order on Prehearing Conference; 2.8 Audio File of Prehearing Conference; 1 2.9 Notice of Motion Hearing; 2 2.10 Notice of Video Conference Hearing; 3 2.11 Department’s Motion for Summary Judgment; 4 2.12 Declaration of Edward R. Thunen, with exhibits; 5 2.13 Audio File of Hearing on Department’s Motion for Summary Judgment; and 6 2.14 Initial Order on Summary Judgment Motion, with documentation of service. 7 3.0 DIRECTOR’S CONSIDERATIONS 8 The Director reviews the record in each matter calling for entry of a final decision and order, even in 9 the absence of a petition for review. The Director has made a review of the Statement of Charges in relation 10 to the language of the Initial Order and finds (1) that the Statement of Charges sets forth claims upon which 11 relief can be granted as pleaded, (2) that the Facts for Purpose of Summary Judgment and Conclusions of Law 12 in the Initial Order are consistent with what the Securities Division pleaded in the Statement of Charges, and 13 (3) that the sanction imposed is not in excess of the prayer for relief in the Statement of Charges. On this basis, 14 the Director affirms the Initial Order of ALJ Dupree. 15 4.0 FINDINGS OF FACT AND CONCLUSIONS OF LAW 16 4.1 Findings of Fact. The Director affirms Section 3.0 of this Order and Paragraphs 5.1 through 17 5.10, inclusive, of the Initial Order. 18 4.2 Conclusions of Law. The Director affirms Section 3.0 of this Order and Paragraphs 6.1 through 19 6.18, inclusive, of the Initial Order. 20 21

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4.3 Affirmation of Initial Order. The Director affirms Paragraphs 7.1 through 7.6, inclusive, of the Initial Order. 5.0 FINAL DECISION & ORDER 1 Based upon the foregoing, and the Director having considered the record and being otherwise fully 2 advised, NOW, THEREFORE, IT IS HEREBY ORDERED: 3 5.1 Respondent, Aqua-Tots Swim School Holding LLC, shall cease and desist from any further 4 violations of RCW 19.100.020. 5 6.0 RECONSIDERATION 6 Pursuant to RCW 34.05.470, the Respondent has the right to file a Petition for Reconsideration stating 7 the specific grounds upon which relief is requested. The Petition must be filed in the Office of the Director of 8 the Department of Financial Institutions by courier at 150 Israel Road SW, Tumwater, Washington 98501, or 9 by U.S. Mail at P.O. Box 41200, Olympia, Washington 98504-1200, within ten (10) days of service of this 10 Final Decision & Order upon Respondent. The Petition for Reconsideration shall not stay the effectiveness of 11 this order nor is a Petition for Reconsideration a prerequisite for seeking judicial review in this matter. 12 A timely Petition for Reconsideration is deemed denied if, within twenty (20) days from the date the 13 petition is filed, the agency does not (a) dispose of the petition or (b) serve the parties with a written notice 14 specifying the date by which it will act on a petition. 15 7.0 STAY OF ORDER 16 The Director has determined not to consider a Petition to Stay the effectiveness of this order. Any such 17 requests should be made in connection with a Petition for Judicial Review made under chapter 34.05 RCW 18 and RCW 34.05.550. 19 20 21

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8.0 JUDICIAL REVIEW The Respondent has the right to petition the superior court for judicial review of this agency action under the provisions of chapter 34.05 RCW. For the requirements for filing a Petition for Judicial Review, 1 see RCW 34.05.510 and sections following. 2 9.0 NON-COMPLIANCE WITH ORDER 3 If the Respondent does not comply with the terms of this order, the Department may seek its 4 enforcement by the Office of the Attorney General. Failure to comply with this Final Decision & Order may 5 also prompt additional actions against the Respondent by the Department as permitted by the Franchise 6 Investment Protection Act of Washington, Chapter 19.100 RCW, for failure to comply with a lawful order of 7 the Department. 8 10.0 SERVICE 9 For purposes of filing a Petition for Reconsideration or a Petition for Judicial Review, service is 10 effective upon deposit of this order in the U.S. mail with a declaration of service attached hereto. 11 DATED this 10th day of February 2026. 12 STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS 13 14 ________________________________________ Charles E. Clark, Director 15 Washington State Department of Financial Institutions 16 17 18 19 20 21

FINAL DECISION AND ORDER AFFIRMING 5 DEPARTMENT OF FINANCIAL INSTITUTIONS 22

CERTIFICATE OF MAILING

This is to certify that the above FINAL DECISION AND ORDER has been served upon the following parties on February 10, 2026, by depositing a copy of same by one or more of the following: First Class Mail, Certified Mail, Hand Delivery via Messenger, Campus Mail, Facsimile, or by Email. 1 WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONS 2 By: 3 Jeanette Baluyut Executive Assistant 4

5 Aqua-Tots Swim School Holding LLC

☒ First Class Mail 1122 S. Greenfield Road

☒ Certified Mail, Return Receipt 6 Mesa, AZ 85206

☐ Email

7 8 Louis Manganiello, Esq. ☒ First Class Mail 9 15550 Chinquapin Drive ☒ Certified Mail, Return Receipt Helotes, TX 78023 ☐ Email 10 Respondent’s Representative 11 First Class Mail Stephen Manning, AAG ☐ Certified Mail, Return Receipt Office of the Attorney General 12 ☒ E-mail PO Box 40100 Stephen.Manning@atg.wa.gov Olympia, WA 98504 13 Trista.Hagen@atg.wa.gov

Agency Representative GCEEF@atg.wa.gov 14 Edward Thunen

☐ First Class Mail Department of Financial Institutions 15

☐ Certified Mail, Return Receipt Division of Securities

☒ Email 16 PO Box 41200 Edward.Thunen@dfi.wa.gov Olympia, WA 98504 17 Agency Contact 18 19 20 21 ☐ FINAL DECISION AND ORDER AFFIRMING 6 DEPARTMENT OF FINANCIAL INSTITUTIONS 22

WASHINGTON STATE OFFICE OF ADMINISTRATIVE HEARINGS

In the matter of: Docket No. 07-2025-DFI-00193 INITIAL ORDER ON SUMMARY Aqua-Tots Swim School Holding JUDGMENT MOTION LLC, Agency: Department of Financial Institutions Respondent. Program: Securities

1. ISSUES
   Whether genuine issues of material fact remain regarding: 1.1. Did Respondent Aqua-Tots Swim School Holding LLC’s offer and/or sale of the business arrangement constitute an offer and/or sale of a franchise as defined in RCW 19.100.010(6), RCW 19.100.010(12), and RCW 19.100.010(17)? 1.2. Did Respondent Aqua-Tots Swim School Holding LLC’s offer and/or sale of said franchise violate RCW 19.100.020 because no registration or exemption for such offer and/or sale was on file with the Securities Administrator at the time of such offer and/or sale? 1.3. If so, should Respondent Aqua-Tots Swim School Holding LLC, and its agents and employees, each cease and desist from violations of RCW 19.100.020?

2. ORDER SUMMARY
   2.1. The Department of Financial Institutions’ Motion for Summary Judgment is

GRANTED.

2.2. The Department of Financial Institutions action is AFFIRMED. 2.3. Yes. Respondent Aqua-Tots Swim School Holding LLC’s offer and/or sale of the business arrangement constituted an offer and/or sale of a franchise as defined in RCW 19.100.010(6), RCW 19.100.010(12), and RCW 19.100.010(17). 2.4. Yes. Respondent Aqua-Tots Swim School Holding LLC’s offer and/or sale of said franchise violated RCW 19.100.020 because no registration or exemption for such offer and/or sale was on file with the Securities Administrator at the time of such offer and/or sale.

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Agency No. S--

2.5. Yes. Respondent Aqua-Tots Swim School Holding LLC, and its agents and employees, should each cease and desist from violations of RCW 19.100.020.

1. SUMMARY JUDGMENT MOTION HEARING
   3.1. Hearing Dates: November 3, 2025 3.2. Administrative Law Judge: Travis Dupree 3.3. Respondent: Aqua-Tots Swim School Holding LLC 3.3.1.1. Representative: Louis Manganiello, Attorney 3.4. Agency: Department of Financial Institutions 3.4.1.1. Representative: Stephen manning, Assistant Attorney General

2. DOCUMENTS CONSIDERED
   4.1. I considered the following documents: Doc. No. Document Name No. Date 1 05/05/25 5 Cease and Desist, No. S-24-3853-25-SC01 2 Application for Adjudicative Hearing 05/22/25 3 3 Department’s Motion for Summary Judgment 09/29/25 7 4 Declaration of Edward R. Thunen in Support of 09/25/25 56 Department's Motion for Summary Judgment and Exhibits 1 - 4

3. FACTS FOR PURPOSE OF SUMMARY JUDGMENT
   On a motion for summary judgment, the decision maker only considers those facts for which the parties establish “no genuine issue as to any material fact”. “Summary 1judgment is appropriate only where the undisputed facts entitle the moving party to judgment as a matter of law.” Only evidence in the record and inferences from that 2evidence establish facts. If evidence in the record points to more than one possible finding

WAC 10-08-135. In Superior Court matters, CR 56 governs summary judgment. Where the relevant procedural 1 rules do not conflict with CR 56, it and the cases interpreting it serve as persuasive authority in the management of summary judgment under WAC 10-08-135. Verizon NW, Inc. v. Employment Sec. Dep’t, 164 Wn.2d 909, 916 (2008), citing Alpine Lakes Prot. Soc’y v. Dep’t of 2 Natural Res., 102 Wn. App. 1, 14 (1999); "Eastlake Comm. Council v. City of Seattle, 64 Wash.App. 273, 276, 823 P.2d 1132 (1992); Kettle Range Conservation Group v. Dep't of Natural Res., 120 Wash. App. 434, 456, 85 P.3d 894 (2003).

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Document PagesStatement of Charges, Notice of Intent to Enter an Order to

of fact, then summary judgment may not rest on the moving party’s version of that fact. Admissions, stipulations, procedural history, and uncontested declarations and affidavits establish facts for summary judgment. The record here supports the following facts for the purposes of summary judgment:

Jurisdiction

5.1. On May 5, 2025, the Department of Financial Institutions issued a Statement of Charges, Notice of Intent to Enter an Order to Cease and Desist, No. S-24-3853- 25-SC01. Statement of Charges, Notice of Intent to Enter an Order to Cease and

Desist.

5.2. On or about May 22, 2025, Respondent filed an appeal. Application for

Adjudicative Hearing. Summary Judgment

5.3. On September 29, 2025, the Department filed a Motion for Summary Judgment. 5.4. Respondent did not file a Response. 5.5. At the November 3, 2025 motion hearing, the Department restated their Motion for Summary Judgment. Respondent did not contest the motion but argued that since they self-reported to the Department, and were in the process of applying again; they were disputing unlimited cease and desist; and seeking a request an equitable resolution from the Department.

Aqua-Tots Swim School Holding LLC offer and/or sale of a franchise

5.6. On May 31, 2007, Aqua-Tots Swim School Holding LLC was formed as an Arizona limited liability company, with a principal place of business in Mesa, Arizona.

Declaration of Edward R. Thunen and Exhibit 1 and 2.

5.7. Aqua-Tots Swim School Holding LLC operates as a business that sells a franchise enabling franchisees to startup a business offering to the public: swimming lessons, underwater aerobics classes, and similar services. Thunen Declaration

and Exhibit 2.

5.8. On an unspecified date prior to January 31, 2023, negotiations began between the Respondent and Ben Sheedy, an Arizona resident, for the sale of an Aqua- Tots franchise. During those negotiations, Mr. Sheedy moved to Washington state and established residency. Aqua-Tots provided a Franchise Disclosure Document to Mr. Sheedy. Thunen Declaration and Exhibit 3.

Verizon NW, 164 Wn.2d 916. 3

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5.9. On January 31, 2023, Mr. Sheedy signed the Franchise Agreement on behalf of his Washington corporation, Salish Swimming 1 Inc. and paid the Respondent an Initial Franchise Fee of the $50,000. Thunen Declaration and Exhibit 2, 3, and 4. 5.10. Aqua-Tots Swim School Holding LLC is not currently registered to sell its franchises in the State of Washington and has no previous registration. Thunen

Declaration.

1. CONCLUSIONS OF LAW Based upon the facts above, I make the following conclusions:

Jurisdiction

6.1. I have jurisdiction over the persons and subject matter here under Revised Code of Washington (“RCW”) 31.04.202, Chapter 34.05 RCW, Chapter 208-08 Washington Administrative Code (“WAC”), and Chapter 10.08 WAC.

Summary judgment

6.2. “A motion for summary judgment may be granted and an order issued if the written record shows that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law. WAC 10-08-135. 6.3. “Summary judgment is appropriate ‘if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.’ CR 56(c).” American Legion Post #149

1. Washington State Dept. of Health, 164 Wn.2d 570, 584, 192 P.3d 306 (2008). 6.4. “The facts and reasonable inferences therefrom are construed most favorably to the nonmoving party.” Korslund v. Dycorp Tri-Cities Services, Inc., 156 Wn.2d 168, 177, 125 P.3d 119 (2005) (citations omitted). 6.5. “Summary judgment may be granted if reasonable persons could reach but one conclusion from the evidence presented.” Korslund, 156 Wn.2d at 177. 6.6. “The burden is on the moving party to demonstrate there is no issue as to material fact, and the moving party is held to a strict standard.” Cowiche Canyon

Conservancy v. Bosley, 118 Wn.2d 801, 811, 828 P.2d 549 (1992) (citations

omitted). 6.7. If the moving party meets this initial showing, “the non-moving party may not rest upon the mere allegations or denial of [its] pleadings, but [its] response, by affidavits or as otherwise provided in the rule, must set forth specific facts showing that there is a genuine issue for trial.” McGough v. City of Edmonds, 1 Wn.App. 164, 168, 460 P.2d 302 (1969).

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Relevant statutes

6.8. The Department is responsible for the administrative regulation of the Franchise Investment Protection Act, chapter 19.100 RCW. 6.9. RCW 19.100.010 (6) defines "Franchise" as: (a) An agreement, express or implied, oral or written, by which: (i) A person is granted the right to engage in the business of offering, selling, or distributing goods or services under a marketing plan prescribed or suggested in substantial part by the grantor or its affiliate; (ii) The operation of the business is substantially associated with a trademark, service mark, trade name, advertising, or other commercial symbol designating, owned by, or licensed by the grantor or its affiliate; and (iii) The person pays, agrees to pay, or is required to pay, directly or indirectly, a franchise fee. 6.10. RCW 19.100.010(12) regarding "Offer" or "offer to sell" definition “includes every attempt or offer to dispose of or solicitation of an offer to buy a franchise or an interest in a franchise.” 6.11. RCW 19.100.010(17) regarding "Sale" or "sell" definition “includes every contract of sale, contract to sell, or disposition of a franchise.” 6.12. RCW 19.100.020 regarding “Unlawful in certain instances to sell or offer to sell franchise if unregistered or not exempt” provides the following: (1) It is unlawful for any franchisor or subfranchisor to sell or offer to sell any franchise in this state unless the offer of the franchise has been registered under this chapter or exempted under RCW 19.100.030. (2) For the purpose of this section, an offer to sell a franchise is made in this state when: (a) The offer is directed by the offeror into this state from within or outside this state and is received where it is directed, (b) the offer originates from this state and violates the franchise or business opportunity law of the state or foreign jurisdiction into which it is directed, (c) the prospective franchisee is a resident of this state, or (d) the franchise business that is the subject of the offer is to be located or operated, wholly or partly, in this state. (3) For the purpose of this section, a sale of any franchise is made in this state when: (a) An offer to sell is accepted in this state, (b) an offer originating

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from this state is accepted and violates the franchise or business opportunity law of the state or foreign jurisdiction in which it is accepted, (c) the purchaser of the franchise is a resident of this state, or (d) the franchise business that is the subject of the sale is to be located or operated, wholly or partly, in this state. (4) For the purpose of this section, an offer to sell is not made in this state solely because the offer appears: (a) In a newspaper or other publication of general and regular circulation if the publication has had more than two- thirds of its circulation outside this state during the twelve months before the offer is published, or (b) in a broadcast or transmission originating outside this state. 6.13. RCW 19.100.248 regarding “Cease and desist orders” provides that: If it appears to the director that a person has engaged or is about to engage in an act or practice constituting a violation of a provision of this chapter or a rule adopted or order issued under this chapter, the director may, in the director's discretion, issue an order directing the person to cease and desist from continuing the act or practice. Reasonable notice of and opportunity for a hearing shall be given. The director may issue a temporary order pending the hearing, which shall remain in effect until ten days after the hearing is held and which shall become final if the person to whom notice is addressed does not request a hearing within twenty calendar days after the receipt of the notice.

Analysis

6.14. In the present case, there are no material facts in dispute. Respondent, Aqua- Tots Swim School Holding LLC’s offer and/or sale of the business arrangement to Mr. Sheedy constitutes an offer and/or sale of a franchise as defined in RCW 19.100.010(6), RCW 19.100.010(12), and RCW 19.100.010(17). Further, Respondent’s offer and/or sale of said franchise violated RCW 19.100.020 since they had no registration or exemption for such offer and/or sale was on file with the Securities Administrator in the state of Washington at the time of such offer and/or sale. 6.15. Respondent only disputes the Department’s unlimited cease and desist order and requests equitable relief because they self-reported to the Department and are in the process of reapplying. 6.16. However, the undersigned administrative law judge is unaware of an exceptions under the statute nor does the undersigned have authority to consider the

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Respondent’s equitable relief. As such, Respondent, and its agents and employees, should each cease and desist from violations of RCW 19.100.020. 6.17. For the foregoing reasons, the Department’s motion for summary judgment should be GRANTED. 6.18. The Department’s action should be AFFIRMED.

1. INITIAL ORDER IT IS HEREBY ORDERED THAT: 7.1. The Department of Financial Institutions’ Motion for Summary Judgment is

GRANTED.

7.2. The Department of Financial Institutions action is AFFIRMED. 7.3. Respondent Aqua-Tots Swim School Holding LLC’s offer and/or sale of the business arrangement constituted an offer and/or sale of a franchise as defined in RCW 19.100.010(6), RCW 19.100.010(12), and RCW 19.100.010(17). 7.4. Respondent Aqua-Tots Swim School Holding LLC’s offer and/or sale of said franchise violated RCW 19.100.020 because no registration or exemption for such offer and/or sale was on file with the Securities Administrator at the time of such offer and/or sale. 7.5. Respondent Aqua-Tots Swim School Holding LLC, and its agents and employees, should each cease and desist from violations of RCW 19.100.020. 7.6. All future events and deadlines are struck and cancelled, including but not limited to the Evidentiary Hearing scheduled to occur on January 27, 2026. SIGNED at Spokane, Washington on the date of mailing. Travis Dupree Administrative Law Judge CERTIFICATE OF SERVICE IS ATTACHED

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Office of Administrative Hearings

PETITION FOR REVIEW

Either party may appeal this Initial Order to the Director of Financial Institutions by filing You must file your petition within twenty (20) days of the day a Petition for Review. 4OAH mails you the Initial Order. Your Petition for Review must be sent to the: 5 Director of Financial Institutions PO Box 41200 Olympia, WA 98504-1200 The petition is filed the day it is received by the Director of Financial Institutions. 6Petition for Review must specify those conclusions of law and findings of fact that you disagree with, and must refer to the evidence in the record that supports the petition. 7The petitioner must serve a copy of the petition on all other parties or their representatives Any party may file a reply to a Petition for Review within at the time the petition is filed. 810 days of the date of service of the petition. The reply must be filed with the Director of Financial Institutions with a copy served on all other parties or their representatives. 9 After the time for filing a petition for review has elapsed, the Director of Financial Institutions will issue a Final Order, subject to appeal rights that will be explained at that time.

ARCW 34.05.464. 4 WAC 10-08-211. 5 WAC 10-08-110(1). 6 WAC 10-08-211(3). 7 WAC 10-08-211(2). 8 WAC 10-08-211(4). 9

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CERTIFICATE OF SERVICE FOR OAH DOCKET NO. 7-2025-DFI-00193

I certify that true copies of this document were served on those listed below, from Spokane, Washington via Consolidated Mail Services by one of the following: First Class Mail, Certified Mail, or by Email. Aqua-Tots Swim School Holding LLC ☒ First Class Mail 1122 S. Greenfield Road ☐ Certified Mail, Return Receipt Mesa, AZ 85206 ☐ E-mail Louis Manganiello, Esq. ☒ First Class Mail 15550 Chinquapin Drive ☐ Certified Mail, Return Receipt Helotes, TX 78023 ☐ E-mail Respondent’s Representative Stephen Manning, AAG ☐ First Class Mail Office of the Attorney General ☐ Certified Mail, Return Receipt PO Box 40100 ☒ E-mail: Olympia, WA 98504 Stephen.Manning@atg.wa.gov

Agency Representatives Shayla.Staggers@atg.wa.gov GCEEF@atg.wa.gov Edward R. Thunen Department of Financial Institutions - ☐ First Class Mail Securities Division ☐ Certified Mail, Return Receipt PO Box 9033 ☒ E-mail: Olympia, WA 98507 edward.thunen@dfi.wa.gov

Agency Contact

Date: Tuesday, December 02, 2025 OFFICE OF ADMINISTRATIVE HEARINGS Amber Guarnacci Legal Assistant 3

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