Noble Escrow Services LLC - Final Order Cease and Desist

Last updated 3/12/26 ORDER SUMMARY Consumer Services Division Case Number C-26-4201 Final Orders resolve investigations where companies or individuals have been charged. Once DFI serves the Final Order on the individual or company, the company or individual has 10 days to petition (formally ask) the Director of DFI to reconsider. The company or individual can appeal in superior court. Name NOBLE ESCROW SERVICES LLC Order Number C-26-4201-26-FO01 Date issued 03/12/2026 What does this Final Order require? x All terms of this order are complete. x Temporary Order to Cease and Desist is terminated. Need more information? You can contact the Consumer Services Division, Enforcement unit at (360) 902-8703 or csenforcecomplaints@dfi.wa.gov. Please remember that we cannot provide financial or legal advice to members of the public. We also cannot release confidential information.

1 DEPARTMENT OF FINANCIAL INSTITUTIONS () 902.8703 DIVISION OF CONSUMER SERVICES IN THE MATTER OF INVESTIGATING Whether there has been a violation of the Escrow Agent Registration Act of Washington by: NOBLE ESCROW SERVICES LLC, Respondent. No. C-26-4201-FO01 TEMPORARY ORDER TO CEASE AND DESIST I. DIRECTOR’S CONSIDERATION A. This matter has come before the Director of the Department of Financial Institutions of the State of Washington (Director), through his designee, Consumer Services Division Director Ali Higgs, pursuant to RCW 34.05.416. On or about March 3, 2026, the Director, through the Director’s designee, issued a Temporary Order to Cease and Desist (TCD) against Noble Escrow Services LLC (Respondent) after the Department became aware of a deficit in Respondent’s trust account. The TCD ordered Respondent to cease and desist from accepting new business from customers in the state of Washington, and to immediately deposit funds into the trust account sufficient to cover the full amount of the deficit. On or about March 10, 2026, Respondent stated to the Department that it had deposited funds into the trust account sufficient to cover the full amount of the deficit and provided copies of documents evidencing such. II. FINAL ORDER Based upon the foregoing, and the Director’s designee having considered the record and being otherwise fully advised, NOW, THEREFORE: A. IT IS HEREBY ORDERED, that the Temporary Order to Cease and Desist is TERMINATED.

2 DEPARTMENT OF FINANCIAL INSTITUTIONS () 902.8703 B. Reconsideration. Pursuant to RCW 34.05.470, Respondent has the right to file a Petition for Reconsideration stating the specific grounds upon which relief is requested. The Petition must be filed in the Office of the Director of the Department of Financial Institutions by courier at 150 Israel Road SW, Tumwater, Washington 98501, or by U.S. Mail at P.O. Box 41200, Olympia, Washington 98504-1200, within ten (10) days of service of the Final Order upon Respondent. The Petition for Reconsideration shall not stay the effectiveness of this order nor is a Petition for Reconsideration a prerequisite for seeking judicial review in this matter. A timely Petition for Reconsideration is deemed denied if, within twenty (20) days from the date the petition is filed, the agency does not (a) dispose of the petition or (b) serve the parties with a written notice specifying the date by which it will act on a petition. C. Stay of Order. The Director’s designee has determined not to consider a Petition to Stay the effectiveness of this order. Any such requests should be made in connection with a Petition for Judicial Review made under chapter 34.05 RCW and RCW 34.05.550. D. Judicial Review. 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, see RCW 34.05.510 and sections following. E. Service. For purposes of filing a Petition for Reconsideration or a Petition for Judicial Review, service is effective upon deposit of this order in the U.S. mail, declaration of service attached hereto. // // // // //

3 DEPARTMENT OF FINANCIAL INSTITUTIONS () 902.8703 DATED this 1 th day of March, 2026. _ __________________________ Ali Higgs, Director__A li Higgs DiDiDDDDDiDiDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDreeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeecctccor

Last updated 2/3/2026 ORDER SUMMARY Consumer Services Division Case Number C-26-4201 Temporary Orders to Cease and Desist require individuals or companies to temporarily stop doing things, usually things that could harm or have harmed consumers. The individual or company has the right to contest the Order at an administrative hearing. If the individual or company does not contest the temporary order, it will become permanent when DFI issues a Final Order. Name Noble Escrow Services LLC Order Number C-26-4201-26-TD01 Date issued 3/2/2026 What does this Temporary Order to Cease and Desist require? x Immediately deposit funds into the trust account sufficient to cover the full amount of the deficit. x Disburse funds to pay off one consumer’s mortgage and reimburse additional mortgage payments made or to be made x Immediately cease and desist from accepting any new business from customers. x Continue to process escrow transactions for existing customers only and ensure that existing customers are not harmed as a result of the deficit in the trust account. Need more information? You can contact the Consumer Services Division, Enforcement unit at (360) 902-8703 or csenforcecomplaints@dfi.wa.gov. Please remember that we cannot provide financial or legal advice to members of the public. We also cannot release confidential information.

1 of 4 DEPARTMENT OF FINANCIAL INSTITUTIONS () 902-8703 DIVISION OF CONSUMER SERVICES IN THE MATTER OF DETERMINING Whether there has been a violation of the Escrow Agent Registration Act of Washington by: NOBLE ESCROW SERVICES LLC, Respondent. No. C-26-4201-26-TD01 TEMPORARY ORDER TO CEASE AND DESIST THE STATE OF WASHINGTON TO: Noble Escrow Services LLC COMES NOW the Director of the Washington State Department of Financial Institutions, by and through his designee Ali Higgs, Division of Consumer Services Director, and finding that the public interest will be irreparably harmed by delay in issuing a cease and desist order, enters this Temporary Order to Cease and Desist pursuant to chapter 18.44 RCW, the Escrow Agent Registration Act (Act), based on the following findings: I. FACTUAL FINDINGS 1.1 Respondent. Noble Escrow Services LLC (Respondent) was licensed by the Department of Financial Institutions of the State of Washington (Department) to conduct business as an escrow agent on or about November 19, 2018, and continues to be licensed to date. 1.2 Fraud and Deficit in Trust Account. On or about February 26, 2026, Respondent represented to the Department that in or around February 10, 2026, Respondent mistakenly wired substantial amounts of money from Respondent’s trust account to a fraudulent party. Respondent further stated that Respondent, in or around February 23, 2026, discovered the fraudulent activity and that Respondent did not have funds to deposit in the trust account to cover the deficit and to pay off a seller’s mortgage as required by the escrow instructions for a

2 of 4 DEPARTMENT OF FINANCIAL INSTITUTIONS () 902-8703 transaction. As of the date of this Temporary Order to Cease and Desist, Respondent is operating with a substantial deficit in its trust account. 1.3 Substantial Injury to Public. An escrow agent operating with a deficit in its trust account poses a substantial risk to its customers that it will not be able to make required disbursements to them. The effect of the above-described conduct is that the public interest will be irreparably harmed by delay in issuing an order to cease and desist. II. GROUNDS FOR ENTRY OF ORDER 2.1 Prohibited Practices. Based on the Factual Findings set forth in Section I above, Respondent is in violation of RCW 18.44.301(2) for directly or indirectly engaging in any unfair or deceptive practice toward any person. 2.2 Disbursements of Funds to Fraudulent Party. Based on the Factual Findings set forth in Section I above, Respondent is in violation of RCW 18.44.430(1)(e) and WAC 208-680-560(1) for failing to disburse funds as set forth in the escrow instructions. III. AUTHORITY TO ISSUE OF ORDER 3.1 Pursuant to RCW 18.44.440, if the Director makes a finding of fact in writing that the public interest will be irreparably harmed by delay in issuing an order to cease and desist, the Director may issue a temporary cease and desist order and require the person to cease and desist from unlawful practices and to take such affirmative action as in the judgment of the Director will carry out the purposes of the Act. IV. ORDER Based on the above Factual Findings, Grounds for Entry of Order, and Authority to Issue Temporary Order to Cease and Desist, and pursuant to RCW 18.44.410, the Director determines

3 of 4 DEPARTMENT OF FINANCIAL INSTITUTIONS () 902-8703 that the public interest will be irreparably harmed by a delay in entering a cease and desist order. Therefore, the Director ORDERS that: 4.1 Respondent Noble Escrow Services LLC shall immediately deposit funds into the trust account sufficient to cover the full amount of the deficit identified in Section 1.2, including amounts sufficient to pay off the seller’s current outstanding mortgage balance and funds sufficient to reimburse the seller for all additional mortgage payments that it would have to incur from February 2026 on. 4.2 Respondent Noble Escrow Services LLC shall disburse funds pursuant to the escrow instructions to pay off the seller’s current outstanding mortgage balance and shall disburse funds to the seller to reimburse for additional mortgage payments made from February 2026 on. 4.3 Respondent Noble Escrow Services LLC shall immediately cease and desist from accepting any new business from customers. 4.4 Respondent Noble Escrow Services LLC shall continue to process escrow transactions for existing customers only and ensure that existing customers are not harmed as a result of the deficit in the trust account identified in Section 1.2. 4.5 This order shall take effect immediately and shall remain in effect unless set aside, limited, or suspended in writing by an authorized court. NOTICE PURSUANT TO CHAPTER 18.44 RCW, RESPONDENT IS ENTITLED TO A HEARING TO DETERMINE WHETHER THIS ORDER SHALL BECOME PERMANENT. IF RESPONDENT DESIRES A HEARING, RESPONDENT MUST RETURN THE ATTACHED APPLICATION FOR ADJUDICATIVE HEARING.

4 of 4 DEPARTMENT OF FINANCIAL INSTITUTIONS ()902-8703FAILURE TO COMPLETE AND RETURN THE APPLICATION FOR ADJUDICATIVE HEARING SO THAT IT IS RECEIVED BY THE DEPARTMENT OF FINANCIAL INSTITUTIONS WITHIN TWENTY (20) DAYS OF THE DATE THIS ORDER WAS SERVED ON RESPONDENT WILL CONSTITUTE A DEFAULT AND WILL RESULT IN THE LOSS OF RESPONDENT’S RIGHT TO A HEARING. SERVICE ON RESPONDENT IS DEFINED AS POSTING IN THE U.S. MAIL, POSTAGE PREPAID, TO RESPONDENT’S LAST KNOWN ADDRESS, OR PERSONAL SERVICE. DEFAULT WILL RESULT IN THIS TEMPORARY ORDER TO CEASE AND DESIST BECOMING PERMANENT ON THE TWENTY-FIRST (21ST) DAY FOLLOWING SERVICE OF THIS ORDER. Entered this ____ day of March, 2026. ________________________ ALI HIGGS, Director Department of Financial Institutions Presented by:__ _________ SANDRA MENDEZ Financial Legal Examiner Reviewed by: _____________________________________ KENDALL FREED Enforcement Chief ALIHIGGSGSSSSSSSSSDir2nd____________________________________SSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSSANDRA MENDEZ