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The Miami Mirror – True Reflections 

AS THE PRESS SPINS

Correspondence with The Miami Herald and the Florida


Office of Financial Regulation in respect to the Herald’s
inaccurate and probably actually malicious coverage of the
Allen Stanford Fraud

October 27, 2010

By David Arthur Walters


THE MIAMI MIRROR

Miami Beach, Florida

PREFACE

What follows is an initial letter to Executive Editor Anders Gyllenhaal of the Miami
Herald, requesting the newspaper’s documentation supporting publication of what I
eventually discovered to be outright falsehoods in respect to its Allen Stanford Series,
and the reader will find correspondence with Deputy Director of Communications John
Kuczwanski of the Florida Office of Financial Regulation.

Mr. Gyllenhaal did not respond to any of my communications on the subject.

Mr. Kuczwanski provided the very documents the Miami Herald must have had, and
answered several of my questions as well. Two of those answers directly refute two of the
false claims repeated by the Miami Herald. And the technical information provided by
Mr. Kuczwanski, if understood in the context of circumstances surrounding Stanford
Trust’s opening and operation of a trust representative office in Miami, will provide the
researcher with ample evidence that the Miami Herald reports were misleading in other
respects as well. Copies of my ongoing series along with the files provided by Mr.
Kuczwanski can be found in my ‘As The Press Spins’ Collection at
Scribd.com/davidwalters.

I wrote several detailed articles protesting the false and probably libelous statements in
the newspaper, taking care to copy Mr. Gyllenhaal and the reporters who penned the
falsehoods. The newspaper did not publish retractions or corrections, nor did the
journalists apologize to the person whose reputation they had smeared, Arthur M. Simon.

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He was not once given an opportunity to deny actually malicious allegations prior to the
publication of those allegations.

In fact, the newspaper reporters have been given several prestigious awards for their
false, inaccurate, unfair and unbalanced coverage, the first one being presented by the
Society of Professional Journalists. The Society did not respond to my protests of the
award in my factual articles making it evident that the Society’s code of ethics had been
violated by the recipients of its award. One of the reporters, Lucy Komisar, who tried to
get Dr. Simon to implicate former Governor Jeb Bush in the Stanford Fraud, has gone so
far as to brag at length in her blog about the awards she has received.

Miami Herald publisher McClatchy promoted Mr. Gyllenhaal on 27 October 2010 to vice
president for news for its 30 daily newspapers and 43 non-dailies. McClatchy, a
traditionally liberal media organization whose ideology sometimes blinds its editors and
reporters to the truth or causes them to resort to falsehoods, had also been sent copies of
articles protesting the Miami Herald’s spurious coverage of the Allen Stanford fraud in
respect to Dr. Simon and Florida banking regulators. McClatchy did not respond. Right
or wrong, the Miami Herald “watchdog” series on Allen Stanford was good copy in terms
of self-advertising, so the paper and its parent stands by it for good effect.

May 5, 2010

Anders Gyllenhaal
Senior Vice President
Executive Editor
THE MIAMI HERALD
One Herald Plaza
Miami, Florida 33139

RE: Award-winning series on Allen Stanford Fraud

Dear Sir:

The Herald's award-winning series on the Allen Stanford fraud prompted me to make
several inquiries with The Florida Bar in respect to the law firms and lawyers named by
the Herald in that series. The Florida Bar has informed me that members of the public
occasionally file sworn complaints against or inquries into the conduct of lawyers based
on stories presented by the media, and that the complainants then have access to the
otherwise confidential files appertaining to the inquiries and/or complaints.

I am in the process in drafting a request for a formal inquisition into the activities of
Richard T. Donelan, Jr., then Chief Banking Counsel, and attorney Art Simon, then
Florida Division of Banking Director, based on various Herald reports virtually damning
the Florida Division of Banking, as if the Division and Art Simon, who signed the

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Memorandum of Agreement with Stanford Trust Company on behalf of the state, were in
collusion with or were co-conspirators with fraudster Allen Stanford and/or his lawyers.

You may recall some of the headlines:

STATE AIDED SUSPECT IN HUGE SWINDLE (7/5/09), FLA. COULDN'T CURB


SWINDLE, BUT ECUADOR DID - IN FLORIDA, INVESTIGATORS 'DROPPED
THE BALL' (8/9/09) HOW FLORIDA BLEW CHANCE TO STOP STANFORD -
STATE NEVER ACTED ON TROUBLING FINDINGS (7/19/09)

In sum, the Herald stated that Mr. Simon violated the laws of our state and nation against
the advice of Mr. Donelan. You will of course recall that several reports stated that Mr.
Donelan knew that the Agreement was in violation of law, and that he objected to the
Agreement several times. If that were the case, it seems to me that he should have asked
The Florida Bar to conduct an inquiry into the activities of Mr. Simon according to the
code of ethics embodied in the Rules of the Florida Bar.

For example:

HERALD REPORTERS HONORED FOR STANFORD STORIES, May 4, 2010


"The Miami Herald won the Society of Professional Journalists' prestigious Sigma Delta
Chi award for exposing sweeping government failures.... Reporters Michael Sallah, Rob
Barry and Lucy Komisar were recognized for their stories revealing how Florida
regulators permited the now disgraced banker - over the objections of the state's chief
banking counsel - to open an unregistered office in Miami a decade ago.... The
reporters...showed how lawyers...helped protect Stanford from government scrutiny while
he was expanding his fraudulent banking network around the world.... "

BANKING LAWS MAY BE TOUGHENED, January 10, 2010


"Over the objections of the state's chief banking lawyer, Florida permitted the banker to
operate without any fraud checks or money laundering requirements, in violation of state
and federal law, the newspaper found.... Richard Donelan, the state's chief banking
counsel, tried at least four times to change the agreement that gave Stanford the freedom
to send millions of dollars to Antigua in total secrecty. In one draft, he questioned why
the state wasn't requiring Stanford to get licensed for sending money - which would have
brought his office under government reguation. But nothing was done."

ALEX SINK - PROBE ALLEN DEAL, July 9, 2009


"Sink said she was disturbed that Florida banking officials approved the Miami office,
despite concerns by state banking counsel Richard Donelan, who said the arrangement
violated state law."

In addition, senior bank analyst David Burgess was portrayed as de facto counsel for the
Florida Division of Banking, the non-lawyer who wrote a "crucial" legal memorandum
approving the allegedly illegal structure that facilitated the big swindle, which led to
questions as to whether or not he was practicing law for the people of Florida without a

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license - however, the evidence I have obtained indicates that the Herald reports are false
and misleading in that respect.

With respect, I ask you to provide me with copies of the documents that you may have or
any other evidence whatsoever including Mr. Donelan's statements that support the claim
that Mr. Donelan actually disapproved of the final Memorandum of Agreement signed by
Mr. Simon, so that I may include the evidence with my sworn statement to the Florida
Bar asking for inquisitions.

I make this request because it would be malicious and unethical to invent or lie about or
twist facts. I have myself obtained copies of numerous documents from various sources
appertaining to the Agreement, and thus far I have no evidence whatsoever that Mr.
Donelan did in fact disapprove of the Agreement signed. I have also been assured by the
state that no disapproving statement from him can be found. I have found a hearsay
reference to his disapproval of the preliminary proposal for the issuance of a normal
Courtesy Letter for an out-of-state trust representative office - but eyebrows were raised
with the revelation that the trust in question was located in foreign country, so a
regulatory agreement was drafted. I noted that a very few pages of the drafts have very
few little notes in the margins without any initials by anyone. As for Mr. Simon, I have
seen nothing in the documentation I have that leads me to believe that he violated any
state laws at all; but I am not a lawyer, therefore Mr. Donelan's expert legal opinion on
that matter is crucial to my sworn statement to The Florida Bar.

I am looking forward to your prompt attention to my request, as I plan on filing my


inquiries with The Florida Bar next week.

Sincerely,
David Arthur Walters
Independent Journalist

THE EXECUTIVE EDITOR DID NOT RESPOND TO THIS COMMUNICATION

April 20, 2010

Holly Hinson
Office of Financial Regulation
STATE OF FLORIDA
200 E. Gaines Street
Tallahassee, Florida 32399-0370

Re: Public Records Request in re Stanford Trust and the Office of Financial Regulation

Dear Holly Hinson:

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This is a public request for records pursuant to Title I, Section 24 of the Constitution of
the State of Florida and Chapter 119 of the Florida Statutes.

I understand the records I want have already been provided by your office to Mike Sallah,
an investigative reporter for the Miami Herald (which has not responded to my several
requests for copies) therefore I believe you should not have much trouble reproducing
them again so that I may examine them in conjunction with the composition of my
article, 'As The Press Spins - An Anatomy of a Prize-Winning Expose.'

I will sincerely appreciate access to all or any of the following records mentioned by Mr.
Sallah in his article published by the Miami Herald on July 19, 2009:

1) Mr. Sallah reported that Florida regulator Keith Jasper said he found Stanford
employees funneling hundreds of thousands of dollars to Stanford's Antigua bank and
reported it to his supervisors who never responded: Please provide a copy of Mr. Jasper's
report to his supervisors and any responses they may have made.

2) Mr. Sallah reported that state banking director Art Simon approved of the "deal"
between the State of Florida (or the Office of Financial Regulation on its behalf) and
Stanford representatives to establish an international trust representative office in Florida,
signing a 7-page Agreement: Please provide me with a copy of that 7-page Agreement.

3) Mr. Sallah reported that State attorneys approved of the aforesaid deal: Please provide
me with a copy of any written approvals.

4) Mr. Sallah reported that David Burgess of the Office of Financial Regulation wrote a
"crucial memo" wherein he provided "legal justification" for the establishment of
Stanford Trust's international trust representative office in Florida: Please provide me
with a copy of that memo.

Thanking you in advance for your cooperation, I am

Very truly yours,

David Arthur Walters


Independent Journalist

On Thu, Apr 22, 2010 at 2:48 PM


John Kuczwanski, Office of Financial Regulation, wrote:

Mr. Walters,

Recently, the Office of Financial Regulation was successful in getting legislation passed
this year which makes a repeat of the Stanford case virtually impossible. Governor Crist
signed the bill (Senate Bill 1264/House Bill 707) into law on April 15, 2010. Prior to

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this, Florida Statutes were silent with respect to international trust company
representative offices. That is no longer the case. Specifically, this new law grants the
Office of Financial Regulation regulatory oversight over international trust company
representative offices, similar to the authority it has over other financial institutions. The
bill contains three major components:

First, the bill provides for the regulation of international trust company representative
offices.

Second, the bill makes it easier for the OFR to take an enforcement action against a
licensed office in those situations in which the foreign bank is the subject of
extraordinary government action in its own country.

Third, the bill raises capital requirements for international banking corporations and
makes other changes to enhance and clarify the OFR's regulatory powers.

Specifically, the bill authorizes the Office of Financial Regulation ("Office") to license
and supervise the activities of international trust company representative offices,
including providing the Office with full examination and enforcement powers, and
subjecting these offices to state and federal anti-money laundering and anti-terrorism
laws (e.g., reporting of currency transactions, suspicious activity, and the transportation
of currency or monetary instruments outside of the United States). International trust
companies desiring to operate a trust company representative office in Florida will be
required to meet minimum capital requirements and other qualifications, and their trust
company representative offices will be subject to oversight by the Office and on-going
business, examination, and recordkeeping requirements. The bill also increases capital
requirements for international banking corporations, authorizes the Office to revoke
inactive licenses, clarifies the Office's regulatory powers relating to international banking
corporations and licensed offices that are operating in an unsafe and unsound manner;
and contains other measures to enhance and strengthen safety and soundness
requirements for international banking corporations. Collectively, these measures will
strengthen Florida's international banking laws and promote a safe and sound
international banking system.

Please find attached documents fulfilling your public records request dated April 20,
2010.

Please let us know if you have any further questions.

Sincerely,

John Kuczwanski
Deputy Director of Communications
Office of Financial Regulation

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April 28, 2010


John Kuczwanski
Deputy Director of Communications
Florida Office of Financial Regulation

In Re: Stanford & OFR Agreement

Dear Mr. Kuczwanski:

Thank you again for supplying copies of various documents related to the establishment
of Stanford Trust's international trust company representative office in Florida. I
appreciate your offer to provide further assistance. I do have a few questions:

1) Miami Herald articles suggest that the final Agreement with the Stanford Trust
executed on December 14, 1998 by banking director Art Simon was signed over the dead
body of chief banking counsel Richard T. Donelan, Jr. A confidential memo dated
November 9, 1998, from David Burgess to Mr. Simon, cited by the Herald as the "crucial
legal" opinion that led to approval of Agreement, states that, "Richard Donelan (sic) is of
the opinion that they cannot establish an office. I'll let him advise as to his reasoning; I'd
probably leave out something basic to it in my translation." However, Mr. Burgess' memo
appears to refer to Greenberg Traurig's effort to establish a Domestic Trust
Representative Office, understood as an office of a domestic out-of-state trust, and not an
International Trust Representative Office. The fact that the office as proposed would
represent an offshore tax-haven trust, not mentioned in some conversations, eventually
raised eyebrows and led to scrutiny.

I do not see any written version of Mr. Donalen's legal opinion in the files that you sent
over. If not privileged, would you please forward it to me? And please do advise if it is a
fact that Mr. Donelan only disapproved of the originally proposed Domestic Trust
Representative Office and not the final Agreement for the International Trust
Representative office.

2) Miami Herald news articles imply that OFR examiner Keith Jasper was a
whistleblower whose formal visit report dated April 5, 2001 should have caused the OFR
to demand documents or to shut down the Stanford's Miami office. In fact, my first
impression of the press release was that bags of stolen cash (described by the Herald as
"money") were being shipped out of Miami and that original records of the unlawful
transactions bilking investors were being shredded right under the eyes of bank
examiners who ignored "red flags." But after reading Mr. Jasper's report and the
Agreement that the OFR had with Stanford Trust in re Stanford Fiduciary Investor
Services Inc of Miami, it appears, from the March 20, 2001 despatch log attached to the
examiners' report, that the "money" on that day was in the form of client's checks, and
various forms, instructions, internal management documents and so on were also

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despatched, that total "deposits" for that day show as $176,464, and that the shredding
was of photocopies of documents held as evidence only until the despatches arrived at
their destiny, was to be expected in consideration of the most important purpose for
having an International Trust Representative Office in Tax Havens - secrecy, so that taxes
can be avoided or evaded, and/or other debts or claims can be evaded. The Agreement
itself does not prohibit the destruction of copies of documents, and I do not understand
why their destruction should arouse suspicion given the nature of what is now normally
called offshore asset protection or asset management instead of fraudulent transfer.

Do you believe the whistle-blowing suggestion is overblown? Has there been any
admission or wrongdoing or statements of regret regarding the handling of of Mr. Jasper's
report?

Very truly yours,

David Arthur Walters

April 30, 2010

Mr. Walters,

Please see below the responses to your questions.

(1) – Despite diligent searches, we have never been able to locate any written legal
opinion from Mr. Donelan on the matter and have concluded that no written opinion was
issued.

(2) – Mr. Jasper’s visit and report did not indicate that the Stanford office was conducting
any activities that were impermissible under Florida law and the Agreement.

Thank you,

John Kuczwanski
Deputy Director of Communications
Office of Financial Regulation

May 01, 2010

John Kuczwanski
Deputy Director of Communications
Office of Financial Regulation

Re: Second Set of Questions in Re Stanford Trust

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Dear Sir:

Thank you for answering my first two questions. It appears that there is no evidence
whatsoever that the chief banking counsel disapproved of the final agreement with
Stanford Trust, and it appears that if Examiner Jasper believed something fishy was going
on at the Stanford office, he should have directly said so instead of relying on staff to
intuit his opinion.

My article 'As the Press Spins - An Anatomy of a Prize-Wining Expose' - is taking shape,
but I am proceeding carefully lest I jump to conclusions unwarranted by the facts. Your
cooperation is deeply appreciated. I shall only have a few more questions and requests for
public documents over a short period of time - I expect to have only one set besides these
below:

(1) Request: The Miami Herald reported that another Visit was made to the Stanford
office, four years after the 2001 Visit.

Please send me a copy of the examiner's report and any written observations and/or
decisions OFR staff may have made in reference to that report.

(2) Request: I am tracing the history of the moves made by the Stanford pettifoggers
leading up to the Memorandum of Agreement. At first they attempted to obtain a
Courtesy Letter to establish an out-of-state Trust Representative Office (TRO), which
they believed would be virtually unregulated. They pursued that angle until eyebrows
were raised that the TRO they wanted was for an offshore tax haven and not a domestic
TRO.

In an undated, informal recap of events apparently drafted by David Burgess in the


Florida Comptroller's office, reference is made to a November 1981 letter written by one
Paul M. Homan, specifying the parameters for said (domestic) TROs.

Please send me a copy of that letter.

(3) Request: You kindly sent me a copy of an undated List of permissible and
impermissible activities for said TROs. Under the heading on the left side, "Examples of
Impermissible Activities for a TRO" there is a subheading, "Discretionary Investment
Activities", and a handwritten parenthesis by the items thereunder refers to a "10-15-80
memo".

Please send me a copy of that memo.

(4) Question in re TROs: IF a TRO (which by the way is not a 'trust service office'
located in a bank etc as defined by law), may be established without a charter, license,
authorization or other approval document from the Division of Banking as long as the
TRO acts as a representative of the out-of-state trust company and does not make

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discretionary decisions or administer fiduciary accounts in Florida," as counsel for the


Stanford Trust wrote, and IF, as further noted by that counsel, TROs are not expressly
identified in or restricted by Florida law, and may operate by virtue of a non-statutory
convention of the Banking Division called a "Courtesy Letter", THEN how would the
Banking Division ever know if the domestic out-of-state TRO was complying with the
informal set of rules set forth in the List I mentioned above - the List that is presumably
based on Paul M. Horman's 1981 letter?

(5) Question: How many out-of-state TROs to which Courtesy Letters were issued were
in existence last year (2009)? Were any of them visited by bank examiners?

(6) Question in re International Representative Offices (of foreign banks - not trusts): Is it
true that because of the expected limited scope of activities of International
Representative Offices of offshore banks that those IROs are not examined as frequently
and as exhaustively as, for instance, international bank branches, and that before the new
law was passed IROs, although subject to a capital requirement of ten million dollars,
were subject to only a $2,000 establishment fee, and no regular annual fee thereafter, and
were not subjected at all to the semi-annual fees calculated and imposed by the
commission for recovery of examination costs?

(7) Question: How many IROs were there in Florida last year, and how many
examinations were conducted on them all?

Best regards,

David Arthur Walters


Independent Journalist

May 11, 2010

Mr. Walters,

[Documents requested were attached]

(4) Question in re TROs: IF a TRO (which by the way is not a 'trust service office'
located in a bank etc as defined by law), may be established without a charter, license,
authorization or other approval document from the Division of Banking as long as the
TRO acts as a representative of the out-of-state trust company and does not make
discretionary decisions or administer fiduciary accounts in Florida," as counsel for the
Stanford Trust wrote, and IF, as further noted by that counsel, TROs are not expressly
identified in or restricted by Florida law, and may operate by virtue of a non-statutory
convention of the Banking Division called a "Courtesy Letter", THEN how would the
Banking Division ever know if the domestic out-of-state TRO was complying with the

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informal set of rules set forth in the List I mentioned above - the List that is presumably
based on Paul M. Horman's 1981 letter?

A TRO for an out-of-state trust company can not and does not operate in Florida “by
virtue of a non-statutory convention called a “courtesy letter”. An out-of-state trust
company is able to establish and operate a TRO in Florida because the activities a TRO
engages in are not considered to be the operation of a “trust business” as defined in
Section 658.12(20), Florida Statutes. Florida law does not require an out-of-state trust
company to provide any notice to the Office of Financial Regulation (“OFR”) regarding
the establishment of a TRO in Florida. On occasion, however, out-of-state trust
companies do notify the OFR regarding the establishment of a TRO as a courtesy. The
home state regulator of an out-of-state trust company may also notify the OFR regarding
the establishment of a TRO by one its trust companies.

The state regulator that licenses or charters a trust company is responsible for regulating
the operations of the trust company, including the operations of a TRO operating in
another state. Should another state regulator determine that a TRO is engaging in
prohibited activities in Florida, that regulator would have the responsibility of notifying
the OFR so that appropriate enforcement action(s) could be coordinated between the
regulators. State regulators, including the OFR, often enter into information sharing and
joint examination agreements to enhance and coordinate the regulation of state chartered
financial institutions with operations in more than one state. The OFR is also an
accredited member of the Conference of State Bank Supervisors, a national organization
that advocates for the state banking system and promotes communication between the
various state banking departments.

Should the OFR receive information from any source that indicates a TRO operated by an
out-of-state trust company is engaging in any prohibited activities, the OFR is authorized
pursuant to Section 655.032, Florida Statutes, to conduct an investigation to determine
whether a violation of the financial institutions codes or the rules adopted by the
Financial Services Commission pursuant to such codes has either occurred or is about to
occur (e.g. conducting a trust business without a license). Should the OFR’s
investigation establish that a violation is occurring or is about to occur, the OFR’s
enforcement authority includes the ability to seek injunctive relief pursuant to Section
655.034, Florida Statutes, and impose administrative fines pursuant to Section 655.041,
Florida Statutes.

* contextual note - The operations of a TRO of an out-of-state bank with trust powers are
subject to the same regulation as the operations of a TRO of an out-of-state trust
company.

(5) Question: How many out-of-state TROs to which Courtesy Letters were issued were
in existence last year (2009)? Were any of them visited by bank examiners?

As stated in response to question number 4 above, the use of the term “courtesy letters”
to characterize or imply that the OFR issues some type of approval regarding the

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establishment of, or any authorization to operate, a TRO in Florida by an out-of-state


trust company is not accurate. An out-of-state trust company is able to establish and
operate a TRO in Florida because the activities a TRO engages in are not considered to
be the operation of a “trust business” as defined in Section 658.12(20), Florida Statutes.
The OFR does not actively track how many TROs are being operated in Florida by out-
of-state trust companies, so it can not provide an answer to your question regarding how
many may have been in existence in 2009. The OFR did not conduct any on-site
visitation at any TRO operated by an out-of-state trust company during the 2009 calendar
year.

(6) Question in re International Representative Offices (of foreign banks - not trusts): Is it
true that because of the expected limited scope of activities of International
Representative Offices of offshore banks that those IROs are not examined as frequently
and as exhaustively as, for instance, international bank branches, and that before the new
law was passed IROs, although subject to a capital requirement of ten million dollars,
were subject to only a $2,000 establishment fee, and no regular annual fee thereafter, and
were not subjected at all to the semi-annual fees calculated and imposed by the
commission for recovery of examination costs?

IROs (International Representatives Office or a foreign banking corporation) activities


are limited by Section 663.062, F.S., to promoting or assisting the deposit-taking,
lending, or other financial or banking activities of an international banking corporation.
It may serve as a liaison in Florida between an international banking corporation and its
existing and potential customers. Representatives and employees of such offices may
solicit business for the international banking corporation and its subsidiaries and
affiliates, provide information to customers concerning their accounts, answer questions,
receive applications for extensions of credit and other banking services, transmit
documents on behalf of customers, and make arrangements for customers to transact
business in their accounts. The IRO cannot conduct any banking business in Florida.

IROs do not maintain books or charts of accounts as do more full service banking entities
(agencies or branches of foreign banks). Their business is limited to being a liaison for
the head office (bank in the foreign country) and its affiliates which may include an
agency or branch in the U.S. or an off-shore affiliate. Since the IRO does not create
customer accounts or loans for its own books (cannot conduct banking business in
Florida), there is very little to examine. The IRO does pay the cost of its examination by
OFR examiners and is required to be examined once in every 18-months period. The fee
to establish an IRO is $5,000. Because the IRO has no banking “assets” to assess, there is
no semi-annual assessment, and the fee for maintenance of the license was and remains
$2,000 annually.

(7) Question: How many IROs were there in Florida last year, and how many
examinations were conducted on them all?

There are 10 state-licensed IROs, with 7 exams performed in 2009

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John Kuczwanski
Deputy Director of Communications
Office of Financial Regulation

May 14, 2010

Mr. Kuczwanski,

The Miami Herald referred to TWO visits, then reference BOTH visits, but at one time
said there was a THIRD visit, in 2007, a visit publicly acknowledged by Linda Charity.
May I have a copy of that THIRD visit report?

Thank you!

David Arthur Walters

May 14, 2010

Mr. Walters,

That report is not releasable because of an open investigation. § 655.057(1), Fla. Stat.

John Kuczwanski
Deputy Director of Communications
Office of Financial Regulation

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