Jamie Worden

On December 31, 2020, the Financial Industry Regulatory Authority (FINRA) Department of Enforcement approved a Letter of Acceptance, Waiver and Consent (AWC) jointly submitted by Worden Capital Management LLC (WCM) and General Securities Principal Jamie Worden to resolve allegations of failing to establish, maintain, and enforce a supervisory system reasonably designed to achieve compliance with FINRA’s suitability rule pertaining to excessive trading. Worden is the owner and CEO of WCM since its inception in February 2009. He has been registered as the firm’s Operations Professional since November 2011.

FINRA Department of Enforcement specifically alleges in the AWC that:

1. From January 2015 to October 2019, WCM and Worden failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures, designed to supervise actively traded accounts and prevent misconduct including unsuitable and excessive trading and churning.
2. In August 2017, WCM and Worden interfered with customer requests to transfer their accounts from WCM to another broker-dealer in connection with thirteen WCM representatives leaving the firm.
3. From January 2016 to December 2020, WCM failed to maintain a system reasonably designed to achieve compliance with its FINRA disclosure rules by failing to timely disclose customer arbitrations related to its registered representatives on 59 amended Form U4s and Form U5s for 13 of its registered representatives.

As a result of WCM registered representatives’ trading activities, customers incurred over $1.2 million in commissions. The supervisory system WCM had in place utilizing daily trade blotters was not designed to flag excessive activity. Further, when reviews reflecting high levels of trading in customer accounts were provided to branch managers, the branch managers did not take reasonable actions to address these red flags nor did they train the principal responsible for supervising its representatives.

Based on the foregoing, WCM and Jamie Worden violated FINRA Rules 2140, 3110 and 2010. Worden further violated FINRA Rules 3110(a), 1122, and 2010 for failing to timely disclose customer arbitrations on its registered representatives Form U4 and Form U5 reports.

Without admitting or denying the allegations made against him, Jamie Worden signed the AWC agreeing to a 15-business day suspension in all capacities, a three-month suspension in all supervisory capacities, $15,000 fine, and completing 20 hours of continuing education regarding supervisory responsibilities. By signing the ACW, WCM consented to a censure, $350,000 fine, restitution of $1,246,471, and retaining an independent consultant to execute a comprehensive review of its compliance with FINRA Rule 3110 regarding supervisory systems, policies, and procedures as it relates to suitability.