Luminate Home Loans Fined $100k, Surrenders License

Last upda ted 2/20 /26 ORDER SUM MARY Consumer Services Divi sion Case Number C-2 5-4017 Consent Orders resolve investigations. In t hese, compa nies and indivi duals work w ith us to agree to t erms that resolve the issues in the investigat ion. Name Luminate Home Loa ns, Inc., NM LS #150953 Order Num ber C-25-4017 -25-CO 01 Date issued February 20, 2026 What doe s this C onsent Order require? x Must pay a fine of $100, 000.00. $50,00 0.00 of this fine is st ayed (doesn’t have to be paid) unt il February 20, 2031 a s long a s Lumina te Home Loan s, Inc. comp lies with th e or der. Th e fine goes away on that date if Luminat e Home Loans, Inc. h as complied. x Must pay an investigation fee of $2,522.31. (Investigation fees cover the cost of DFI staff time working on the investiga tion.) x Luminate Hom e Loans, Inc. isn’t allowed to pa rtic ipate in th e mortgage brok er or consum er loan industry i n Washingt on until F ebruary 2 0, 2031. x Luminate Hom e Loans, Inc. ’s consume r lo an licen se is voluntar ily surrende red. x Luminate Hom e Loans, I nc. must c ease and desis t violating the Cons umer Loan Ac t, rules, and applicable federal laws a nd regula tions desc ribed in the St atemen t of Char ges. x Luminate Hom e Loans, I nc. admi ts to the allega tions i n Section One of t he Sta tement of C harges that pertai n to them. x Luminate Hom e Loans, I nc. must no t apply for a l icense f rom DFI until Feb ruary 20, 2 031. Need m ore inform ation? You can c ontact t he Con sumer Services Divisio n, Enfo rcement unit a t (360) 902-870 3 or csenforcecom plaints@dfi.wa.gov. Ple ase remember that we c annot provide financial or legal adv ice to members of t he public. We also cannot rele ase confidenti al information.

February 20th 6

STATEMENT O F CH ARGES C-25- 4017- 25- SC0 1 LUMINATE HOM E LOANS, INC. and JOEL JOHN SARYSZ 1 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er Ser vic es PO Box 41200 Olympia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS DIVISION OF CONSUMER SE RVICES IN THE MATTER OF DETERMINING Whether there has been a violation of the Consumer Loan Act of Washington by: LUMINATE HOME LOANS, INC., N MLS #150953, and JOEL JOHN SARYSZ, N MLS #1134506, Respondents. No. C-25-4017-25-SC01 STATEMENT OF CHARGES and NOTICE OF INTENT TO ENTER AN ORDER TO CEASE AND DES IST, REVOKE LICENSE, PROHIBIT F ROM INDUSTRY, IMPOSE FINE, COLLEC T INVESTIGATION FEE, and RECOVER C OSTS AND EXPENSES INTRODUCTION Pursuant to RCW 31.04.093 and RCW 31.04.165, the Direct or of the Dep artment of Financial Institutions of the State of Washi ngton (Director) i s responsible for the administration of chapter 31.04 RCW, the Consumer Loan Act (Act). After having conducted an inve stigation pursuant to RCW 31.04.145, and based upon the facts availabl e as of the date of this Statement of Charges, the Director, through his designee, Divi sion of Consumer Services Acti ng Dire ctor Ali Higgs, institutes this proceeding and finds as follows: I. FACTUAL ALLEGATIONS 1.1 Respondent s. A. The Washington State Department of Financial Institutions (De partment) lice nsed Luminate Home Loans, Inc. (Respondent Luminat e) to conduct business as a consumer loan company under the Act on or about June 25, 2018, and Respondent Luminat e continues to be licensed to date.

STATEMENT O F CH ARGES C-25- 4017- 25- SC0 1 LUMINATE HOM E LOANS, INC. and JOEL JOHN SARYSZ 2 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er Ser vic es PO Box 41200 Olympia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 B. Joel John Sarysz (Respondent Sarysz) b ecame an employee of Respondent Luminate starting in January 2024 and continues to be employed to date. Responde nt Sarysz is not licensed by the Department as a mort gage loan originator. 1.2 Prior Regulatory Acti on. On or about June 6, 2017, the De partment filed Statement of Charges and Notice of Intention to Enter an Or der to Prohibit from Industry No. C-17-2204-17-SC01 (Statement of Charges). The Statement of Charg es alleged that in February 2016, Respondent Sarysz submitted false loan documents and made a misstatem ent to the Dep artment. On or about September 17, 2017, the Department entered Consent Order No. C-17-2204-17-CO01 (Consent Order). The Consent Order prohibited Respondent Sarysz from participating, in any capacity, in the conduct of the affairs of any consumer loan or mortgag e broker company licensed by t he Department or subject to licensure by the Direct or, for seven years. 1.3 Examination. Between about May 5, 2025, and May 9, 2025, the Depart ment examined the books and records of Res pondent Luminate for th e period of January 1, 2023, through January 31, 2025. The examination revealed multiple violations of the Act, including those identified below. 1.4 Violation of Prior Order. Between at least Janu ary 11, 2024, and September 21, 2024, Respondents acted in violation of the Consent Ord e r. For example, Res pondent Luminate employed Respondent Sarysz to partic ipate, and Respondent Sary sz did participate, in the conduct of the affairs of a consumer loan company subject to licensure b y the Director under the Act, in violation of the Consent Order. In particular, from about January 22, 2024, to September 21, 2024, Respondent Sarysz, while working on beha lf of Respondent Luminate and also while pr ohibited from participating in the conduc t of the affairs of a consumer loan company, assisted at least 55 borrowers in applying for residential mortgage loans for properties located in the stat e of Washington. 1.5 Did Not Maintai n a Sufficien t Surety Bon d. Between about January 1, 2 023, and January 31, 2025, Respondent Luminate did not maintain a sufficient surety bond for its activity in the State

STATEMENT O F CH ARGES C-25- 4017- 25- SC0 1 LUMINATE HOM E LOANS, INC. and JOEL JOHN SARYSZ 3 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er Ser vic es PO Box 41200 Olympia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 of Washington. Respondent Luminate also did not determine the required b ond amount and provide the Department with proof of having an adequate bond by March 1 st of each year during that time. 1.6 Did Not Licen se Managers. Between about Janu ar y 1, 2023, and January 31, 2025, Respondent Luminate employed at least two managers who wer e not licensed as a mortgage loan originators and who superv ised underwriting employees. 1.7 Transacted Business Usin g Only a Trade Name. Between about April 11, 2024, and December 6, 2024, Respondent Luminate used a t rade name without also using its main office licen se name or main office licen se num ber on at least one document in at least three loan files. 1.8 Did Not Accurately and Completely Date Mort gage Loan Applications. Between about January 1, 2023, and January 31, 2025, Responde nt Luminat e did not date or did not accurately date at least 35 residential mortgage loan applications related to prope rties located in Washington State. 1.9 Did Not Provide Rate L ock Agreem ents. Between about January 1, 2023, and January 31, 2025, Respondent Luminate did not provide rate lock agreements to at leas t 11 borrowers within three business days of lo cking interest ra tes. 1.10 Did Not Timely Provide a List of Ho me ownership Co unseling Organiz ations. Between about September 11, 2024, and Dece mber 3, 2024, Respondent Luminate did not deliver to at least two borrowers a homeownership counseling organ i zations list within three business days after receiving a lo an applicati on. 1.11 Did Not Complete Closing Disclosu res. Between about January 1, 2023, and January 31, 2025, and in at least 27 instances, Respondent Luminat e did not provide complete closing disclosures to Washington borrowers. 1.12 Did Not Adh ere to Toleran ce Limi ts. Between about January 18, 2023, and January 13, 2025, Respondent Luminate provided at least six borrowe rs an initial loan estima te which disclosed a

STATEMENT O F CH ARGES C-25- 4017- 25- SC0 1 LUMINATE HOM E LOANS, INC. and JOEL JOHN SARYSZ 4 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er Ser vic es PO Box 41200 Olympia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 lower final inspect ion fee, recordi ng fee, processi ng fee, tr ansfer tax, or app raisal fee than was charged to the borrower. 1.13 On-Going Investigation. The Department’s investigation in to the alleged violations of the Act by Respondents c ontinues to date. II. GROUNDS FOR ENTRY OF ORDER 2.1 Definition of Borrower. Pursuant to RCW 31.04.015(4), “Bo rrower” mean s any person who consults with or retains a licensee or person subjec t to the Act in an ef fort to obtain, or who seeks information about obtaining a loan, regardless of whether that pe rson actually obtains such a loan. 2.2 Responsibilit y for Co nduct of Employee s. Pursuant to WAC 208-620-372, a consumer loan company is responsible for any conduct violating the Act or thes e rules by any person you employ, or engage as an independ ent c ontractor, to work in the bus iness covered by yo ur license. 2.3 Unfair or Deceptive Pr actice. Based on the Factual Allegations set forth in Section 1.4-1.12 above, Respondents are in appare nt violation of R CW 31.04.027(1)(b) for directly or indirectly engaging in any unfai r or deceptive pr actice towar d any person. 2.4 Violation of Prior Order. Based on the Factual Allegations set forth in Section 1.4 above, Respondents are in apparent violation of RCW 31.04.027(1)(a) and WAC 208-620-550(14) for failing to comply with an order issued by the Department, including by allowing at least one individual to participate in the conduct of the affairs of Respondent Luminate, while the individual was prohibited from doing so by the Department. 2.5 Requirem ent to Maintai n a Suffi cient Su rety Bond. Based on the factual alle gations set forth in Section 1.5 above, Respondent Luminat e is in apparent vi olation of RCW 31.04.045(4), WAC 208-620-320, and WAC 208-620-327 for fa iling to ma intain a surety bond and provide proof of an adequate bond as re quired by the Act.

STATEMENT O F CH ARGES C-25- 4017- 25- SC0 1 LUMINATE HOM E LOANS, INC. and JOEL JOHN SARYSZ 5 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er Ser vic es PO Box 41200 Olympia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2.6 Requirem ent to Licen se Managers. Based on the Factual Allegati ons set forth in Section 1.6 above, Respondent Luminate is in appare nt violation of RCW 31.04.035(1) and WAC 208-620- 301 for engaging in the business of a consumer lo an company and employing individuals not licensed by the Department to assist borrowers in applying for residential mortgag e loans. 2.7 Trade Name. Based on the Factual Allegations set forth in Section 1.7 ab ove, Respondent Luminate is in apparent violation of RCW 31.04.027(1)(a) and WAC 208-6 20-420 for transacting business using only a trade name without also using the name on Respondent Luminate’s license o r Respondent Luminate’s main office licens e number. 2.8 Inaccurately Dated Residential Mortgage Loan Applications. Based on the Factual Allegations set forth in Section 1.8 above, Respondent Luminate is in apparent violation of RCW 31.04.027(1)(a), RCW 31.04.027(1)(f), RCW 31.04.102(2), and W AC 208-620-550(8) and (18) for failing to date or accurately da te a residentia l mortgage loan a pplication. 2.9 Incomp lete Rate Lock Agreem ents. Based on the Factual Allega tions set forth in Section 1.9 above, Respondent Luminate is in apparent violation of RCW 31.04.027(1)(a), RCW 31.04.027(1)(f), RCW 31.04.102, WAC 208-620-510(3) and (5) for not providing complete rate lock agreements. 2.10 Untimely Lists of Homeowners hip Counseling Or ganizations. Based on the Factual Allegations set forth in Section 1.10 above, Respondent Luminate is in apparent vi olation of RCW 31.04.027(1)(a) and (m), RCW 31.04.102(2), and 12 C.F. R. § 1024.20(a) for not timely providing a list of homeownership counseling organizations to borrowers. 2.11 Inaccurate and Incomplete Closing Disclosures. Based on the Factual A llegations set forth in Section 1.11 above, Respondent Luminate is in apparent violation of RCW 31.04.027(1)(a), RCW 31.04.027(1)(m), RCW 31.04.102(2), and 12 C.F.R. § 1026.38(g)(1) and (4), and (r)(3) and (7), for failing to provide accurate and complete closing disc losures.

STATEMENT O F CH ARGES C-25- 4017- 25- SC0 1 LUMINATE HOM E LOANS, INC. and JOEL JOHN SARYSZ 6 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er Ser vic es PO Box 41200 Olympia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2.12 Nonadh erence to Toler ance Lim its. Based on the Factual Allegati ons set forth in Section 1.12 above, Respondent Luminate is in appare nt violation of RCW 31.04.027(1)(m) and RCW 31.04.102(2) for violating 12 C.F.R. § 1026.19(e)(3)(i) a nd (ii) for not adhering to tolerance limits. III. AUTHORITY TO IMPOSE SANCTIONS 3.1 Authority to Issue an Ord er to Cease and Desist. Pursuant to RCW 31.04.093(5)(a), the Director may issue orders directing a license e, its employee or loan originator, or other pe rson subject to the Act to cease and d esist from conducting business in a manner that is injurious to the public or violates any provision of the Act. 3.2 Authority to Revoke License. Pursuant to RCW 31.04.093(3), the Direct or may revoke a license issued under the Act if the Dire ctor finds th at (b) the licensee, eithe r knowingly or without the exercise of due car e, has violat ed any provision of the Act or a ny rule adopted under the Act; (c) a fact or condition exists tha t, if it had existed a t the time of the original applic ation for the lic ense, clearly would have allowed the Director to deny t h e application for the original license; or (d) the licensee failed to comply with any directive, order, or subpoena issued by t he Director under the Act. 3.3 Authority to Prohibit from the Industry. Pursuant to RCW 31.04.093(6), the Director m ay issue an order prohibiting from participation in th e affairs of any license e, or both, any officer, principal, employee or mortgage loan originator, or any other p erson subject to the Act for (d) failure to comply with any order or subpoena issued under the Act; (e) a violation of RCW 31.04.027, RCW 31.04.102, RCW 31.04.155, or RCW 31.04.221; or (f) failure to obtain a license for activity that requires a license. 3.4 Authority to Impose F ine. Pur suant t o RCW 31.04.093(4), the Di re cto r m ay im po se f in es o f up to one hundred dollars per day, per violation, upon th e licensee, its empl oyee or loan originator, o r any other person subject to the Act for (a) any viola tion of the Act; or (b) failure to comply with a ny order or subpoena issued by the Director under the Act.

STATEMENT O F CH ARGES C-25- 4017- 25- SC0 1 LUMINATE HOM E LOANS, INC. and JOEL JOHN SARYSZ 7 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er Ser vic es PO Box 41200 Olympia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3.5 Authority to Charge Investigation Fee. Pursuant to RCW 31.04.145(3), WAC 208-620- 590, and WAC 208-620-610(7), every licensee ex amined or investigated by the Director o r the Director’s designee must pay for the cost of the in vestigation, calculated at the rate of $69.01 per staff hour devoted to the investigation. 3.6 Authority to Recover C osts and Expenses. Pursuant to RCW 31.04.205(2), the Director may recover the stat e’s costs and expenses fo r prosecuting violations of the Act. IV. NOTICE OF INTE NT TO ENTER ORD ER Respondents’ violations of the provisions of chapter 31.04 RCW and ch apter 208-620 WAC, as set forth in the above Factu al Allegations, Grounds for Entry of Order, and Authority to Impose Sanctions, constitute a basis for the entr y of an Or der under RCW 31.04.093, RCW 31.04.165, RCW 31.04.202, and RCW 31.04.205. Therefore, it is the Director’s intent to OR DER that: 4.1 Respondent Luminate Home Loans, Inc. ceas e and desist from conducting business in a manner tha t is injurious to the public or violates any provision of the Act, including violations cited in this Statement of Charges. 4.2 Respondent Joel John Sarysz cease and de sist fro m conducting business in a manner that is injurious to the public or violates any order issued under the Act or provision of the Act, including violations cited in this Statement of Cha rges. 4.3 Respondent Luminate Home Loans, Inc.’s license to conduct the business of a consumer loan company be revoked. 4.4 Respondent Luminate Home Loans, Inc. be prohi bited from participation in the conduct of the affairs of a ny consumer loan company subject to licensure b y the Director, in any manner, for a pe riod of five years. 4.5 Respondent Joel John Sarysz be prohibited from participation in the conduct of the affairs of any consum er loan company subj ect to l icensure by the Director, in any manner, for a period of te n (10) years. 4.6 Respondents Luminate Homes Loans, Inc. and Joe l John Sarysz jo intly and severally pay a fine, which as of th e date th is Statement of Charges totals $25,500.00. 4.7 Respondents Luminate Homes Loans, Inc. pa y a fi ne, which as of the date t his Statement of Charges totals $100,000.00.

STATEMENT O F CH ARGES C-25- 4017- 25- SC0 1 LUMINATE HOM E LOANS, INC. and JOEL JOHN SARYSZ 8 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er Ser vic es PO Box 41200 Olympia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4.8 Respondents Luminate Homes Loans, Inc. and Joe l John Sarysz jo intly and severally pay an investigation fee, which as of the d ate of this Statement of Charges totals $2,522.31. 4.8 Respondents Luminate Homes Loans, Inc. and Joe l John Sarysz jo intly and severally pay the Department’s cost s and expenses for prosecuting violations of the Act in an amount to be determined at hearing or by declarati on with supporting documentation in event of default by a Respondent. / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / /

STATEMENT O F CH ARGES C-25- 4017- 25- SC0 1 LUMINATE HOM E LOANS, INC. and JOEL JOHN SARYSZ 9 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er Ser vic es PO Box 41200 Olympia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 V. AUTHORITY AND PROCE DURE This Statement of Charges and Notice of Intent to Enter an Ord er to Cease and Desist, Revoke License, Prohibit from Industry, Impose Fine, Collect Investigation Fee, and Recover Costs and Expenses (Statement of Char ges) is entered pursu ant to the provisions of RCW 31.04.093, RCW 31.04.165, RCW 31.04.202, and RCW 31.04.205, and is subject to the provisions of chapter 34.05 RCW (The Administra tive Proce dure Act). Respondents may make a written request for a hea ring as set forth in the NOTICE OF OPP ORTUNITY TO DEFEND AND OPPOR TUNITY FOR HEARING accompanying this S tatement of Charges. Dated this 5th day of September, 2025. _ _ _______________ ALI HI GGS, D ire ctor Division of Consumer Services Department of Financial I nstitutions Presented by: ______________________ _________ MEGAN GUTHRIE Financia l Legal Examiner Approved by: _______________________________ KENDALL FREED Enforcement C hief _ _ AL I H I GG G G G G G G G G G S S S S S S S S S S S S S D D D D D D Di D D D D D rec,