Pro Escrow Inc and Kristin Marie Finch Must Cease and Desist, License Revoked

ORDER SUMMARY Consumer Services Division Case Number C-25-4092 Consent Orders/Consent Agreements resolve investigations. In these, companies and individuals work with us to agree to terms that resolve the alleged issues in the investigation. Names Pro Escrow, Inc. and Kristin Marie Finch Order Number C-25-4092-26-CO01 Date issued April 9, 2026 What does this Consent Order require? x Respondent Pro Escrow, Inc. and Respondent Kristin Finch must cease and desist from engaging in the business of an escrow agent and from all violations of the Escrow Agent Registration Act (Act), rules, and applicable federal laws and regulations described in the Statement of Charges (attached). x Respondent Pro Escrow, Inc. and Respondent Kristin Finch must comply with the Act and all related rules. x Respondent Pro Escrow, Inc. and Respondent Kristin Finch paid an investigation fee of $1,000.00. (Investigation fees cover the cost of DFI staff time working on the investigation.) x Respondent Pro Escrow, Inc. and Kristin Finch aren't allowed to participate in the escrow industry regulated by chapter 18.44 RCW and the chapter 208-680 WAC in Washington until April 6, 2031. x Respondent Pro Escrow, Inc.'s escrow agent license is revoked. x Respondent Pro Escrow, Inc. and Respondent Kristin Finch, its officers, employees, and agents must maintain records in compliance with the Act and provide the Director with the location of the books, records and other information relating to their escrow agent business, and the name, address, email, and telephone number of the individual responsible for maintenance of such records in compliance with the Act. 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.

Last updated 4/9/26

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Consumer Services Division Case Number C-25-4092 Statements of Charges allege wrongdoing by a company or individual. DFI issues Statements of Charges to tell the company or individual: x They have been investigated x DFI is making allegations against them x What the allegations are x What consequences could follow DFI informs the company or individual of their rights at this time. The company or individual can respond to the Charges. They also have the right to contest the Charges at an administrative hearing. Pro Escrow Inc Names Kristin Marie Finch Number

12/23/2025 Date issued Questions? 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.

Last updated 12/23/2025

1 STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS DIVISION OF CONSUMER SERVICES 2 IN THE MATTER OF DETERMINING No.: C-25-4092-25-SC01 3 Whether there has been a violation of the Escrow Agent Registration Act of Washington by: 4 STATEMENT OF CHARGES and PRO ESCROW, INC., NOTICE OF INTENT TO ENTER AN 5 ORDER TO CEASE AND DESIST, TAKE and AFFIRMATIVE ACTION, REVOKE 6 LICENSE, PROHIBIT FROM INDUSTRY, KRISTIN MARIE FINCH, IMPOSE FINE, COLLECT INVESTIGATION 7 Owner, FEE, and MAINTAIN RECORDS Respondents. 8 9 INTRODUCTION 10 Pursuant to RCW 18.44.410, the Director of the Department of Financial Institutions of the 11 State of Washington (Director) is responsible for the administration of chapter 18.44 RCW, the 12 Escrow Agent Registration Act (Act). After having conducted an investigation pursuant to RCW 13 18.44.420 and WAC 208-680-620, and based upon the facts available as of the date of this Statement 14 of Charges, the Director, through his designee, Consumer Services Division Director Ali Higgs, 15 institutes this proceeding and finds as follows: 16 I. FACTUAL ALLEGATIONS 17 1.1 Respondents. 18 A. Pro Escrow, Inc. The Washington State Department of Financial Institutions 19 (Department) licensed Pro Escrow (Respondent Pro Escrow) to conduct business as an escrow agent 20 on or about July 13, 2011, and Respondent Pro Escrow continues to be licensed to date. 1 21 B. Kristin Marie Finch. Kristin Marie Finch (Respondent Finch) is 100% owner of 22 Respondent Pro Escrow. 23 24 The escrow agent license has not been surrendered as of the date of this document. 1

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1 1.2 Did not Comply with Closure Requirements. On or about October 17, 2025, the 2 Department received an automatic email reply from Respondent Pro Escrow and Respondent Finch 3 (collectively, "Respondents") indicating Respondents closed the business on September 12, 2025. 4 On or about October 22, 2025, Respondents provided the Department with a signed "Escrow Agent 5 Office Closure Form" (Closure Form) with the "Effective Date of Closure" left blank. The Closure 6 Form specifies that notice of closure must be provided thirty days prior to the planned closure. In 7 addition, Respondents did not include with the Closure Form the trust liability (trial balance) and the 8 reconciliation reports. In correspondence with the Department received by the Department on or 9 about October 24, 2025, Respondents represented that on or about September 3, 2025, Respondents 10 closed its business. 11 1.3 Did not Comply with Requirements when Designated Escrow Officer Leaves. 12 Respondents' Designated Escrow Officer departed employment on or about September 8, 2025. 13 Respondents have not taken the required steps when a Designated Escrow Officer leaves 14 employment, including those identified in paragraph 2.6. 15 1.4 Did not Comply with Director's Authority. On or about October 1, 2025, the Department 16 sent a directive to Respondents that required Respondents to provide the Department with an 17 explanation regarding an insufficient funds notice and all relevant documentation, bank and financial 18 account information, and list of open escrow transactions by October 8, 2025. The Department did 19 not receive a response from Respondents. On or about October 17, 2025, the Department sent a letter 20 to Respondents enclosing another copy of the directive and setting a due date of October 24, 2025. 21 Respondents submitted a response to the Department on or about October 24, 2025, however, 22 Respondents' response was not complete. Respondents did not provide the requested information for 23 item 6 which asked: "For the period of August 1, 2025, to the present, all trust account ledger 24

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1 sheet(s)/check register(s) with key codes. As of the date of this Statement of Charges, the 2 Department has not received the omitted items from Respondents. 3 1.5 On-Going Investigation. The Department's investigation into the alleged violations of the 4 Act by Respondents continues to date. 5 II. GROUNDS FOR ENTRY OF ORDER 6 2.1 Definition of Escrow. Pursuant to RCW 18.44.011(7), "Escrow" means any transaction 7 wherein any person or persons, for the purpose of effecting and closing the sale, purchase, exchange, 8 transfer, encumbrance, or lease of real or personal property to another person or persons, delivers any 9 written instrument, money, evidence of title to real or personal property, or other thing of value to a 10 third person to be held by such third person until the happening of a specified event or the 11 performance of a prescribed condition or conditions, when it is then to be delivered by such third 12 person, in compliance with instructions under which he or she is to act, to a grantee, grantor, 13 promisee, promisor, obligee, obligor, lessee, lessor, bailee, bailor, or any agent or employee thereof. 14 2.2 Definition of Escrow Agent. Pursuant to RCW 18.44.011(8), "Escrow Agent" means any 15 person engaged in the business of performing for compensation the duties of the third person referred 16 to in RCW 18.44.011(7). 17 2.3 Definition of Designated Escrow Officer. Pursuant to RCW 18.44.011(4), "Designated 18 Escrow Officer" means any licensed escrow officer designated by a licensed escrow agent and 19 approved by the Director as the licensed escrow officer responsible for supervising that agent's 20 handling of escrow transactions, management of the agent's trust account, and supervision of all other 21 licensed escrow officers employed by the agent. 22 2.4 Escrow Agent License Duration. Pursuant to RCW 18.44.141, an escrow agent's license 23 shall remain in effect until surrendered, revoked, suspended, or until it expires, and shall at all times 24 be kept conspicuously posted in all places of business of the agent.

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1 2.5 Requirements to Close Business. Pursuant to WAC 208-680-245(2), thirty days prior to the 2 planned closure of an escrow agent, the designated escrow officer or a controlling person must 3 provide the Department with notice of the closure. After closure, the designated escrow officer or a 4 controlling person must provide the Department with the following within fifteen days: (a) An 5 itemized accounting of funds held in trust at the time of closure, including the names of the principal 6 parties to the transaction, the escrow number, the amount of funds held and the purpose of the funds. 7 If the trust account balance is zero, the escrow agent must provide a reconciliation of the trial balance 8 supporting the zero balance; (b) The most recent completed three-month reconciliation; (c) The 9 name, residence address and telephone number of the person responsible for the records; (d) The 10 street address and telephone number where the records are located; (e) An itemized list of the escrow 11 agent's retained records, specifying their location and quantity, including the number of files and the 12 number of boxes they are stored in; and (f) A records retention plan that identifies the ways that 13 responsible person will store, retrieve, and destroy your required records in compliance with the Act 14 and this section. The plan must identify how the responsible person will continue to pay any costs 15 associated with the storage location. Based on Factual Allegations set forth in Section 1.2 above, 16 Respondents are in apparent violation of RCW 18.44.301(2) and (10), WAC 208-680-245(2) by 17 failing to notify the Department and provide the documents specified in the rule. 18 2.6 Requirements when Designated Escrow Officer Leaves. Pursuant to WAC 208-680- 19 176(1) an escrow agent: (a) must notify the Department within one business day of the loss of or 20 change of its designated escrow officer and provide the Department with the identity its proposed 21 replacement designated escrow officer within five business days; (b) may not accept new clients or 22 new files until the proposed designated escrow officer has been approved by the Department or the 23 Department has otherwise authorized new activities. The escrow agent's employees may continue to 24 handle escrow transactions and provide escrow services on existing client files to the extent necessary

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1 to avoid prejudicing those existing clients and files; (c) must apply to the Department for approval of 2 the proposed designated escrow officer. The proposed designated escrow officer must meet the 3 requirements of WAC 208-680-110 and 208-680-135. If the escrow agent needs more than five days 4 to identify the proposed replacement designated escrow officer, it must seek approval from the 5 Department. If the identified proposed replacement is rejected by the Department, the escrow agent 6 will have an additional thirty days to provide the Department with the identity of the proposed 7 replacement designated escrow officer. Pursuant to WAC 208-680-176(1)(d), failure to identify and 8 replace the designated escrow officer, or to receive approval from the director for an extension, may 9 result in an enforcement action against the escrow agent and the suspension or revocation of its 10 license. Based on Factual Allegations set forth in Section 1.3 above, Respondents are in apparent 11 violation of RCW 18.44.301(2) and (10), WAC 208-680-176(1) for failing to notify the Department 12 and taking the steps specified in the rule. 13 2.7 Requirement to Comply with Director's Authority. Based on Factual Allegations set forth 14 in Section 1.4 above, Respondents are in apparent violation of RCW 18.44.301(2) and (10), and 15 RCW 18.44.420 by failing to provide documents and other materials required by the Director or 16 alternatively RCW 18.44.400 by failing to keep adequate records and maintain such records for a 17 period of six years. 18 III. AUTHORITY TO IMPOSE SANCTIONS 19 3.1 Authority to Issue an Order to Cease and Desist and Take Affirmative Action. Pursuant 20 to RCW 18.44.440(1) and (3) and WAC 208-680-630, if the Director determines after notice and 21 hearing that a person has violated any provision of the Act, the Director may issue an order requiring 22 the person to cease and desist from the unlawful practice and to take such affirmative action as in the 23 judgment of the Director will carry out the purposes of the Act. 24

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1 3.2 Authority to Revoke Licenses. Pursuant to RCW 18.44.430, the Director may revoke the 2 license of any escrow agent or escrow officer if the Director finds that the applicant or any partner, 3 officer, director, controlling person, or employee has committed any of the following acts or engaged 4 in (b) violating any provisions of the Act; (f) failing, upon demand, to disclose any information 5 within his or her knowledge to, or to produce any document, book, or record in his or her possession 6 for inspection of, the director or his or her authorized representatives; or (i) committing acts or 7 engaging in conduct that demonstrates the applicant or licensee to be incompetent or untrustworthy, 8 or a source of injury and loss to the public. 9 3.3 Authority to Prohibit from Industry. Pursuant to RCW 18.44.430(3) and WAC 208-680- 10 640(1)(b), the Director may prohibit from participation in the conduct of the affairs of any licensed 11 escrow agent, any officer, controlling person, director, employee, or licensed escrow officer. 12 3.4 Authority to Impose Fine. Pursuant to RCW 18.44.430(3) and WAC 208-680-640(1)(d), the 13 Director may impose a fine up to $100 per day for each violation of this Act. 14 3.5 Authority to Collect Investigation Fee. Pursuant to RCW 18.44.121, RCW 18.44.410, 15 WAC 208-680-620, and WAC 208-680-650, every licensee investigated by the Director shall pay for 16 the cost of the investigation, calculated at the rate of $62.50 per hour devoted to the investigation. 17 3.6 Requirement to Maintain Records. Pursuant to RCW 18.44.400(1), every licensed escrow 18 agent shall keep adequate records, as determined by rule by the director, of all transactions handled 19 by or through the agent including itemization of all receipts and disbursements of each transaction. 20 These records shall be maintained in this state, unless otherwise approved by the director, for a period 21 of six years from completion of the transaction. 22 IV. NOTICE OF INTENT TO ENTER ORDER 23 Respondents' violations of the provisions of chapter 18.44 RCW and chapter 208-680 WAC, 24 as set forth in the above Factual Allegations, Grounds for Entry of Order, and Authority to Impose

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1 Sanctions, constitute a basis for the entry of an Order under RCW 18.44.400, RCW 18.44.410, RCW 2 18.44.430, RCW 18.44.440, and WAC 208-680-630. Therefore, it is the Director's intent to ORDER 3 that: 4 4.1 Respondent Pro Escrow, Inc. and Respondent Kristin Marie Finch cease and desist from engaging in the business of an escrow agent. 5 4.2 Respondents Pro Escrow, Inc. and Kristin Marie Finch take the affirmative action to 6 reconcile, distribute funds, and close the company's trust account, and file required documentation with the Department to close its business. 7 4.3 Respondent Pro Escrow, Inc.'s license to conduct the business of an escrow agent be revoked. 8 4.4 Respondents Pro Escrow, Inc. and Kristin Marie Finch be prohibited from the participation in 9 the conduct of the affairs of any escrow agent subject to licensure by the Director, in any manner, for a period of five years. 10 4.5 Respondents Pro Escrow, Inc. and Kristin Marie Finch jointly and severally pay a fine that as 11 of the date of this Statement of Charges totals $800.00. 12 4.6 Respondents Pro Escrow, Inc. and Kristin Marie Finch jointly and severally pay an investigation fee that as of the date of this Statement of Charges totals $1,250.00. 13 4.7 Respondents Pro Escrow, Inc. and Kristin Marie Finch, its officers, employees, and agents 14 maintain all records involving Washington State escrow transactions within the state of Washington for a period of six years from completion of the escrow transactions. 15

1. AUTHORITY AND PROCEDURE 16 This Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Take 17 Affirmative Action, Revoke License, Prohibit from Industry, Impose Fine, Collect Investigation Fee, 18 and Maintain Records (Statement of Charges) is entered pursuant to the provisions of RCW 19 18.44.410, RCW 18.44.430, and RCW 18.44.440, and is subject to the provisions of chapter 34.05 20 RCW (the Administrative Procedure Act). Respondents may make a written request for a hearing as 21 set forth in the NOTICE OF OPPORTUNITY TO DEFEND AND OPPORTUNITY FOR HEARING 22 accompanying this Statement of Charges. 23 Dated this 23rd day of December 2025. 24

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1 2 _____________ ALI HIGGS, Director 3 Department of Financial Institutions 4 Presented by: 5 6 __ ______ JAMES R. BRUSSELBACK7 Financial Legal Examiner 8 Approved by: 9 10 _ _____ KENDALL FREED 11 Enforcement Chief 12 13 14 15 16 17 18 19 20 21 22 23 24

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