FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2021070239501 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Jayanth Hebbar (Respondent) Former Securities Trader CRD No. 5244889 Pursuant to FINRA Rule 9216, Respondent Jayanth Hebbar submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted on the condition that,

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018058292301 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Jon Stankovich (Respondent) General Securities Representative CRD No. 4810172 Pursuant to FINRA Rule 9216, Respondent Jon Stankovich submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

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