FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS Department of Enforcement, Complainant, v. Worden Capital Management LLC (CRD No. 148366), Respondent. Disciplinary Proceeding No. 2019064746502 COMPLAINT The Department of Enforcement alleges: SUMMARY 1. Between January 2019 and March 2020, Worden Capital Management LLC (“WCM”), acting through its chief executive officers, JW, and its registered representatives, raised over $10 million from 121 investors in 22 private placement offerings