Noble Escrow Services LLC - Temporary Cease and Desist Order

Last updated 2/3/202 6 ORDER SUM MARY Consumer Se rvices D ivision Case N umber C -26-4201 Temporary Orders to Ceas e and Desist require individuals or c ompanies to t emporarily stop doing t hings, usually things that could harm or have harmed consume rs. The individual or company has the right t o contest the Order at an administrat ive hearing. If the individual or compa ny does not c ontest t he temporary order, it will become permanen t when DFI issues a Final Order. Name Noble Escrow S ervices L LC Order Num ber C-26-4201-26-TD01 Date issued 3/2/2026 What do es this Tempo rary Order to Cease and Desist require? x Immediatel y deposit fu nds into the tru st accoun t sufficient t o cover the fu ll amou nt of the defici t. x Disburse funds to pay off one consumer’s mortgage and reimburse additional mortgage payments made or to be made x Immediately cease and des ist from acce pting any ne w business from cust omers. x Continue to p rocess escrow transac tions for existing customers onl y and ensur e that e xisting custo mers are not harmed as a re sult of th e d eficit in the tru st accoun t. Need m ore informa tion? You can c ontact the C onsumer S ervices Division, Enforcement unit a t (360) 902- 8703 or csenforcecom plaints@dfi.wa.gov. Please remember that w e cannot provide f inancial or legal adv ice to members of t he public. We also cannot rele ase confidenti al information.

TEMPORARY ORDER TO CEASE AND DESIST C-26- 4201-26- TD01 NOBLE ESCROW SERVICES LLC 1 of 4 DEPARTMENT OF FINANCIAL INSTITUTIONS Divisio n of Cons umer Ser vices PO Bo x 4120 0 Olympia, WA 985 04-12 00 (360) 902- 8703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Escrow Agent Registration Act of Washington by: N OBLE ESCROW SERVICES LLC, Respondent. No. C-26-4201-26-TD01 TEMPORARY ORDER TO CEASE AND DES IST THE STATE OF WAS HINGTON TO: Noble Escrow Services L LC COMES NOW the Direc tor of the Washington Stat e Departmen t of Financ ial I nstitutions, by and through h is design ee Ali Higgs, Divi sion of Consumer Services Direct or, and finding that the public inter est will be irrepar a bly harmed by de lay in issuing a cea se and desist order, enters this Temporary Order to Ceas e and Desist pursu a nt to c hapter 18.44 RCW, the Es crow Agent Registration Ac t (Act), based on the followin g findings: I. FACTUAL FINDINGS 1.1 Respondent. Noble Escrow Services LLC (Respondent) was licens ed by the Department of Financ ial Institutions of the State of Wa shington (Department) to conduct business as an escrow agent on or about Nove mber 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 ar ound February 10, 2026, Respondent mistakenly wired substantial am ounts of money from Respondent’s trust ac count to a fraudulent party. Respondent further stated that Respondent, in or around Febr uary 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 s eller’s mortgage as required b y the escrow instructions for a

TEMPORARY ORDER TO CEASE AND DESIST C-26- 4201-26- TD01 NOBLE ESCROW SERVICES LLC 2 of 4 DEPARTMENT OF FINANCIAL INSTITUTIONS Divisio n of Cons umer Ser vices PO Bo x 4120 0 Olympia, WA 985 04-12 00 (360) 902- 8703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 transaction. As of the date of this Tempor ary O rder to Cease and Desist, Respondent is operating with a substant ial deficit i n its trust acco unt. 1.3 Substantial Injury to Public. An escrow agent operating with a deficit in its trust account poses a substantial risk to its cust omers that it will not be able to make required disbursements to them. The effect of the above -d escribed conduct is that the public interest will be irreparably ha rmed by delay in issuing an order t o 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 viola tion of RCW 18.44.301(2) for directly or indirectly engaging in any unfair or deceptive p ractice toward any perso n. 2.2 Disbursements of Funds to Fraudule nt 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 fa ct in writing that the public inter est will be irrepara bly harmed by delay in issuing an order to c ease and desist, the Director may issue a temporary ce as e and desist order and require the person to cease and desist from unl awful practices and to ta ke such affirmative action as in the judgment of the Director will carry out the purposes of the Act. IV. ORDER Based on the above Fact ual Findings, Grounds for Entry of Order, and Authority to Issue Temporary Order to Ceas e and Desist, and pur suant to RCW 18.44.410, the Director determines

TEMPORARY ORDER TO CEASE AND DESIST C-26- 4201-26- TD01 NOBLE ESCROW SERVICES LLC 3 of 4 DEPARTMENT OF FINANCIAL INSTITUTIONS Divisio n of Cons umer Ser vices PO Bo x 4120 0 Olympia, WA 985 04-12 00 (360) 902- 8703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that the public inter est will be irrepa rably harmed by a delay in entering a cease and desist order. Therefore, the Directo r ORDER S 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 cur rent outstanding mortgage balance and funds sufficient to r eimburse the seller f or 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 additi onal mortgage payments made from February 2026 on. 4.3 Respondent Noble Escrow Services LLC shall immediately ceas e and desist from accepting any new business from customers. 4.4 Respondent Noble Escrow Services LLC shall co ntinue to process escrow transactions for existing customers only and ensure that exi sting customers are not harmed as a result of the deficit in the trus t account identified i n Section 1.2. 4.5 This order shall ta ke effect immediately a nd shall remain in ef fect unless set aside, limited, or suspe nded in writing by an authorized court. NOTICE PURSUANT TO CHAPTER 18.44 RCW, RESPONDENT I S ENTITLED TO A HEARING TO DETERM INE WHETHER THI S ORDER SHALL BE COME PERMANENT. IF RESPONDENT DESIRES A HEARI NG, RESPONDENT MUST RETURN THE ATTACHED APPLICATI ON FOR ADJUDICATIVE HEARING.

TEMPORARY ORDER TO CEASE AND DESIST C-26- 4201-26- TD01 NOBLE ESCROW SERVICES LLC 4 of 4 DEPARTMENT OF FINANCIAL INSTITUTIONS Divisio n of Cons umer Ser vices PO Bo x 4120 0 Olympia, WA 985 04-12 00 (360) 902- 8703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 FAILURE TO COMPLETE AND RETURN THE APPLICATION FOR ADJUDICATIVE HEARI NG SO THAT IT IS RECEI VED BY THE DEPARTMENT OF FINANCIAL INSTITUTIONS WITHI N TWENTY (20) DAYS OF THE DATE THI S ORDER WAS SERVED ON RESPONDENT WILL CONSTI TUTE A DEFAULT AND WILL RESULT IN THE LOSS OF RESPONDENT’S RI GHT TO A HEARING. SERVICE ON RESPONDENT I S DEFINED AS POSTING IN THE U.S. MAIL, POSTAGE PREPAID, TO RE SPONDENT’S LAST KNOWN ADDRESS, OR PERSONAL SERVICE. DEF AULT WILL RESULT I N THIS TEM PORARY ORDER TO CEASE AND DESIST BECOMING PERMANENT ON THE T WENTY-FIRST (21ST) DAY FOLLOWING SE RV ICE OF T HIS ORD ER. Entered this ____ day of March, 2026. ________________________ ALI HIGG S, Dir ect or Division of Consumer Services Department of Financial I nstitutions Presented by: _ _ _________ S ANDR A MENDEZ Financia l Legal Examiner Reviewed by: _____________________________________ KENDALL FREED Enforcement C hief A LI H IG GS GS S S S S S S S S Di r 2nd __ __ _ _ _ __ __ __ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ __ _ _ _ _ S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S S ANDRA MENDEZ