CapexMD LLC Consent Order for Unlicensed Small Loans

• * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * IN THE MATTER OF: CAPEXMD, LLC NMLS # 2326897 CONSENT ORDER (“ CapexMD ”) W HEREAS, the Banking Commissi oner (“Comm issioner”) is cha rged with the a dministrati on of Part III of Chapter 668, Sections 36a - 555 to 3 6a - 573, inclusive, o f the Connecticut Gen eral Statutes, “Small Loan Lending and Related Activities,” as amended, and the regula tions promulga ted there under, Section s 36a - 570 - 1 to 36a - 570 - 17, inclusive, of the Regul ations of Connecticu t State Agencies; WHEREAS, Cap exMD is an Arizona limited liability company with an office located at 9907 E B ell R oad, S uite 110, S cottsdale, A rizon a; WHEREAS, Cap exMD has never been licensed as a small lo an company i n Connecticut; WHEREAS, on November 4, 2025, Ca pexMD applie d for a s mall l oan c ompany l icense in Connecticut through the Nationwide Multistate Licensing System and Registry (“ NMLS”), which application i s currently pe nding; WHEREAS, the Commissioner, thr ough the Consum er Credit Division (“Division”) of the Department of Banking, conduct ed an invest igation pursua nt to Section 36a - 17 (a) of the Connecticut General Statut es into the activities of CapexMD to determ ine if it had viola ted, was vi olating or was a bout to violate the provisions of the Connect icut Genera l Statutes a nd Regulations of C onnecticut Sta te Agencies within the juris diction of the Commissioner (“Investigat ion”);

WHEREAS, as a resu lt of such I nvestigation, the Commissioner alleges that, si nce at least November 2023, CapexMD mad e small loan s to forty- one (41) Connect icut borrower s without the required license, in violation of Section 36a - 556(a) (1) of the Connecticu t General Statutes, i n effect at such time, and r eceive d payments, including, but not limited to, payments for principal, interest or fees, in connection wi th such small loans, in violation of Section 36a - 556 (a)(4), in effect at such time; WHEREAS, CapexMD promptly coope rated with the Division’s In vestigation and produced the requested Connecticut small loan transactio n records; WHEREAS, the Commissioner beli eves that suc h allegation w ould support i nitiation of enforcement p roceedings again st CapexMD, including, without limitation, proceedings to issu e a n order to make restitu tion against CapexMD pursuant to Se ctions 36a -5 70 (b) and 36a - 50 (c) of the Con necticut General Statut es, to cease and desi st against CapexMD pursuant to Section s 36a - 570(b) and 36a - 52(a) of the Connecticu t General Statutes and to impos e a civil pe nalty of up to O ne H undr ed T housand D ollars ($100,000) p er violation upon CapexMD pursuant to Section s 36a - 570(b) and 36a -50(a) o f the Connecticut Gen eral Statutes; WHEREAS, in itiation of such enfo rcement proceedi ngs would constitu te a “contested case” wit hin the meani ng of S ection 4 - 166(4) of the Connectic ut General Statutes. Section 4 - 177(c) of the Connec ticut General Statut es and Section 36 a -1- 55(a) of the Regulati ons of Connecti cut State Agenc ies provide tha t a contested case may be resolved by consent order, unless p recluded by law; WHEREAS, the Commissioner and CapexMD acknowledge the po ssible consequen ces of formal administr ative procee dings, and CapexMD voluntarily a grees to consent to the ent ry of the sanc tions imposed below without admitting or denying the allegation set for th herein, a nd solely for the purpose of obviating the need for form al administ rative proceedi ngs concerning the allegat ion set forth herein; WHEREAS, Cap exMD acknowledges t hat it has had the opportuni ty to consult with and be represent ed by independent counsel in ne gotiating and re viewing this Consent Order and executes this Consent Order freel y; WHEREAS, the Commissioner and CapexMD now desire to resolve th e matter s set forth her ein; - 2 -

WHEREAS, CapexMD sp ecifically assu res the Commission er that the vio lation alleged herein shall not occ ur in the fut ure; WHEREAS, CapexMD ac knowledges that t his Consent Order is a public record and i s a reportable event for pur poses of the regulatory di sclosure questions on NMLS, as app licable; AND WHEREAS, CapexMD, thr ough its exe cution of this Co nsent Orde r, voluntarily agr ees to waive its procedural right s, including a r ight to a notice a nd an opportunity f or a hearing as it pertains to the allegation set forth herein, an d voluntaril y waives its righ t to seek judicial r eview or otherwise challenge or contest the va lidity of this Conse nt Order. WHEREAS, CapexMD, through its ex ecution of thi s Consent Orde r, consents to t he Commissione r’s entry of a C onsent Order i mposing the fol lowing sanc tions: CONSENT TO ENTRY OF SANCT IONS 1. C apexMD shall cease and desist from vio lati ng Section 36a - 556(a) of the Connec ticut General Statute s, as amended by Public Act 25 - 115, i ncluding, but not limit ed to, making s mall loans t o Connecticut borrowers a nd receiving paym ents of princi pal, interest or fees in connection with small loans made to Connecticut borro wers, without a small lo an license in Con necticut; 2. No later than th e date this Consent Ord er is executed by Cap exMD, it shall remit to the Department of Ban king by electronic f unds transfer, ca shier’s check, cert ified check or mo ney order made payab le to “Treasurer, State of Connecticu t”, the sum of Ten Th ousand Dollars ($10,000) as a civi l penalty; 3. No later than th e date this Consent Or der is executed by C apexMD, it shall remit t o the Department of Ban king by electronic f unds transfer, ca shier’s check, cert ified check or mo ney order made payab le to “Treasurer, State of Connecticu t”, the sum of Eight Hundred Dollars ($ 80 0) as back - licensi ng fees; 4. CapexMD shall limit collection on outstandi ng small loans with C onnecticut borrowers, mad e while unlicensed, to 12% annu al percentage rate; 5. CapexMD shal l reimburse the Co nnecticut borro wers identified in Exhibit A, attached hereto, in the amount s identifie d, which repre sents amounts paid by such C onnecticut bor rowers in excess of an ann ual percentage rate o f 12% while Capex MD was not licensed as a small loan company in C onnecticut. Reimbursem ents shall be m ade nolater t han April 24, 2 026. CapexMD shall provide three (3) monthly report s, due Mar ch 31, 2026, April 30, 2026 and May 31, 2026, respectively, listing the names and addresses of Con necticut borrowers list ed in Exhibit A to whom CapexMD has such payme nts, the am ount of each payme nt and status of the payment to Swarupa M adhavan, Paralegal, Consumer Credi t Divisi on, Departme nt of Banking, 2 80 Trumbull Stre et, 16th Floor, Hartford, C onnecticut 06013, or swarupa.ma dhavan@ct.gov w ithin ten da ys of remi t tance; and

Issued at Hartfo rd, Connecticut this 26 day of Febru ary 202 6. _ __ /s/ _ _______________ ______ 6. CapexMD shall hold the sum of any checks which remain un cashed in escrow f or the benefit of such Connecti cut borrower unti l such time the monies are provided to the re spective Connecticut bor rower or escheated to t he state. CONSENT ORDER NO W THEREFORE, the Commission er enters the follo wing: 1. The Sanctions set fo rth above be an d are hereby entered; 2. Upon issuance of this Conse nt Order by the Commissioner, t his matter will be resolve d and the Commissione r will not take any future en forcement action against CapexMD based up on the allegation set forth herein; provided that issua nce of this Cons ent Order is without prejudic e to the right of the Commi ssioner to tak e enforcement act ion against CapexMD based upon a violation of t his Consent O rder or the ma tters underlying it s entry, i f the Commis sioner determines that compliance with t he terms herein is n ot being observed or i f any repres entation made by CapexMD and refle cted herein is s ubsequently disc overed to be untr ue; 3. CapexMD shal l not take any acti on or make or permit to be made any public stat ement, including in r egulatory fil ings, any proc eeding in any f orum or othe rwise, denyi ng, directly o r indirectly, any allegation referenced in this Consent Ord er or create the impress ion that this Consent Order is wi thout factual basis. E xcept as specificall y provided herei n, CapexMD shall not take any position in an y proceeding broug ht by or on beha lf of the C ommissioner, or to which the Commissioner is a party, that is inc onsistent with any part of th is Consent Order. Nothing in th is provision affects CapexMD ’s (i) testimonial obligations, or (ii) right to take any legal or factual position that may contradict an allegation in this Consent Order in litigation or other legal pr oceedings i n which the Com missioner is not a party; 4. Subject to the for egoing, and s o long as this C onsent Order i s promptly discl osed by CapexMD and its control p ersons on NMLS, as ap plicable, n othing in the issuanc e of this Conse nt Order shall adversel y affect the abili ty of CapexMD to apply for or obta in an initial license or renewal license s under Part III of Chapter 66 8, Sections 36a - 555 et seq., of the Connecticut General Statutes, as amended, provided that all applicable l egal requirements for any such license are satisfied and th e terms of this Consent Order are being fol lowed; 5. This Consent Order shall be binding upon CapexMD and its successors and assig ns; and 6. This Consent Order shall become final when issued. __________ ___ Jorge L. Perez Banking Com missioner - 4 -

_ /s/ ___ ___ _________________ ____ I, Alex Shire, state on behalf o f CapexMD, LLC, that I have read the foregoing Conse nt Order; tha t I know and fu lly understa nd its contents; that I am authorized to ex ecute this Consent Order on behalf of CapexMD, LLC; that Cap exMD, LLC agrees freely a nd without thre at or coercion of any kind to c omply with the sa nctions entere d and terms a nd conditions or dered herei n; and that CapexMD, LLC voluntarily agrees to e nter into this C onsent Order, e xpressly wa iving the proce dural rights s et forth here in as to the matters describ ed herein. By: __ /s/ _________________ ____________ _______ Name: Alex Shire Title: CEO CapexMD, LLC State of: Illinois County of: DuPage On this the 3 day of February 202 6, before me, Angie Burchinal, the undersigned officer, personally ap peared Alex Shire, who acknowledge d himself/ herself to be the CEO of CapexMD, LL C, a member managed / manager managed limited liability company, and that he/ sh e as such ___________ ____, bei ng authorized s o to do, exec uted the foregoi ng instrume nt for the purpose s therein conta ined, by signi ng the name of t he limited liability company by himself/ herself as Alex Shire. In witness whereof I hereunto set my han d. _____ Notary Public Date Commission Expires: January 12, 2030 - 5 -