The information on this site is for informational purposes only and is not intended to provide tax, legal or investment advice. You should not rely on any material contained in the web site and should seek independent advice wherever necessary. Any decisions you make based upon any information contained in this web site are done so solely at your own risk. The information contained in this web site is not an advertisement and it does not constitute an offer of any securities or investment related services, including the purchase and sale of the securities of the companies found on this web site. The information provided herein may be displayed and printed for your personal, noncommercial use only. You may not reproduce, retransmit, distribute, disseminate, sell, publish, broadcast or circulate the information to anyone, without the express written consent of Worden Capital Management, LLC.
Disclaimer on Usage of Web Site Links
The links provided on this web site are solely intended for convenience and are not intended to be advertisement whatsoever. The linked sites are not under the control of Worden Capital Management, LLC and Worden Capital Management, LLC is not responsible for the content of any linked site or any link contained in any linked site. Worden Capital Management, LLC does not endorse companies, or their products or services, to which it links. If you decide to access any of the third party sites linked to this site, you do this entirely at your own risk.
FINRA Public Disclosure
FINRA requires that FINRA member firms provide the following information concerning the FINRA public disclosure program:
• The FINRA public disclosure program hotline number is (800) 289-9999
• The FINRA web site address is www.finra.org An investor brochure that includes information describing the public disclosure program may be obtained from FINRA.
FINRA Rule 2266
Worden Capital Management LLC is a member of the Securities Investor Protection Corporation (“SIPC”). You may obtain information about SIPC, including the SIPC Brochure and information about which assets are eligible for SIPC protection, by contacting SIPC at 1-202-371-8300 or visiting its website at www.sipc.org.
SEC Rule 17a-3(a)(18) requires our Firm to maintain a record indicating that each client or investor has been provided with a notice containing the address to which you may transmit any inquiries that you may have respecting our Firm.
Additionally, our Firm must ensure that you are provided with a notice indicating the telephone number and the address at our Firm to which such inquiries may be directed.
Worden Capital Management LLC hereby provides the following address and telephone number to which any customer inquiries may be directed:
Worden Capital Management, LLC
40 Wall Street, Floor 7
New York, NY 10005
Phone: (646) 968-8000
Important Information You Need to Know About Opening a New Account
To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account.
This notice answers some questions about your firm’s Customer Identification Program.
What types of information will I need to provide?
When you open an account, your firm is required to collect the following information:
- Date of birth
- Identification number:
- U.S. citizen: taxpayer identification number (Social Security number or employer identification number)
- Non-U.S. citizen: taxpayer identification number; passport number and country of issuance; alien identification card number; or government-issued identification showing nationality, residence and a photograph of you.
You may also need to show your driver’s license or other identifying documents.
A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement.
U.S. Department of the Treasury, Securities and Exchange Commission, and FINRA rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives and risk tolerance.
What happens if I don’t provide the information requested or my identity can’t be verified?
Worden Capital Management, LLC’s Business Continuity Planning: Worden Capital Management, LLC’s Business Continuity Planning Worden Capital Management, LLC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.
Contacting Us – If after a significant business disruption you cannot contact us as you usually do at the main office telephone numbers (646-968-8000), you should call our alternative numbers (646-968-8000; 212-408-1776; or, 910-509-7242), or go to our web site at www.wordencapital.com, for instructions. If you cannot access us through either of those means, you should contact our clearing firm, Axos Clearing LLC, at their primary phone numbers (402-384-6100 or 800-811-3487) or go to their web site, www.axosclearing.com, for instructions on how it may provide prompt access to funds and securities through the following transaction types: liquidating orders, outgoing wires, and ACATs.
Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, Axos Clearing LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within one business day. Your orders and requests for funds and securities could be delayed during this period.
Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within one to two days. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area and recover and resume business within two days. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site, www.wordencapital.com, or our customer emergency number, 646-968-8000, how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.
For more information – If you have questions about our business continuity planning, you can contact us at 516-439-4192, or via our website.
Worden Capital Management, LLC Notice of Privacy
This privacy notice complies with the Gramm-Leach-Bliley Act and federal regulations governing the privacy of financial information applicable to our clients.
Worden Capital Management LLC Notice of Privacy
We are committed to providing our clients with quality service. While collecting information about you is essential to meet your needs, we recognize the importance of handling your personal information with care. Accordingly, we have established this Notice of Privacy and related policies.
Confidentiality and Security of Your Information
We maintain appropriate physical, electronic, and procedural safeguards to protect the security and confidentiality of your nonpublic personal information. We educate our employees about the terms of this Notice and the importance of customer privacy. We restrict access to nonpublic personal information about you to those employees and others who need to know that information to provide services to you, to maintain your accounts, or conduct our business.
Information We Collect About You
Collecting information from you is essential to our ability to offer quality services. As part of that process, we may collect nonpublic information about you from the following sources:
- Information we receive from you on applications and other forms;
- Information about your transactions with us;
- Based upon the services provided, information we receive from consumer reporting agencies, government agencies and from your agent banks and prime brokers where applicable; and
- Information that is used to facilitate emails from you.
Categories of Information We Disclose and to Whom
We do not disclose any information about our clients or former clients to anyone, except as permitted or required by law. We may disclose the types of information listed below to companies that help us conduct our business, that perform administrative or others services on our behalf, or other financial institutions with which we now or may have joint marketing agreements:
- Information we receive from you on applications and other forms, such as your name, address, Social Security number (if an individual), assets, income and beneficiaries;
- Information about your transactions with us, or others; and
- Information we receive from a consumer reporting agency, government agencies and from your agent banks and prime brokers where applicable, and from other sources, such as information concerning credit worthiness and history, and certain information requested pursuant to US Patriot Act anti-money laundering prevention rules and regulations.
Your brokerage firm is furnishing this document to you to provide some basic facts about purchasing securities on margin, and to alert you to the risks involved with trading securities in a margin account. Before trading stocks in a margin account, you should carefully review the margin agreement provided by your firm. Consult your firm regarding any questions or concerns you may have with your margin accounts.
When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds from your firm, you will open a margin account with the firm. The securities purchased are the firm’s collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell securities or other assets in any of your accounts held with the member, in order to maintain the required equity in the account.
It is important that you fully understand the risks involved in trading securities on margin. These risks include the following:
• You can lose more funds than you deposit in the margin account. A decline in the value of securities that are purchased on margin may require you to provide additional funds to the firm that has made the loan to avoid the forced sale of those securities or other securities or assets in
• The firm can force the sale of securities or other assets in your account(s). If the equity in your account falls below the maintenance margin requirements, or the firm’s higher “house” requirements, the firm can sell the securities or other assets in any of your accounts held at the firm to cover the margin deficiency. You also will be responsible for any short fall in the account after such a sale.
• The firm can sell your securities or other assets without contacting you. Some investors mistakenly believe that a firm must contact them for a margin call to be valid, and that the firm cannot liquidate securities or other assets in their accounts to meet the call unless the firm has contacted them first. This is not the case. Most firms will attempt to notify their customers of margin calls, but they are not required to do so. However, even if a firm has contacted a customer and provided a specific date by which the customer can meet a margin call, the firm can still take
necessary steps to protect its financial interests, including immediately selling the securities without notice to the customer.
• You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call. Because the securities are collateral for the margin loan, the firm has the right to decide which security to sell in order to protect its interests.
• The firm can increase its “house” maintenance margin requirements at any time and is not required to provide you advance written notice. These changes in firm policy often take effect immediately and may result in the issuance of a maintenance margin call. Your failure to satisfy the call may cause the member to liquidate or sell securities in your account(s).
• You are not entitled to an extension of time on a margin call. While an extension of time to meet margin requirements may be available to customers under certain conditions, a customer does not have a right to the extension.
SEC Rule 606
Report on Routing of Customer Orders – SEC Routing Disclosure Rule 606
Currently all orders of Worden Capital Management, LLC are offered through its clearing firm, Axos Clearing LLC, a subsidiary af Axos Financial, Inc.
Axos Clearing LLC has provided information pursuant to a U.S. Securities and Exchange Commission (SEC) rule (606) that requires firms to make publicly available quarterly reports on the firm’s order routing practices. The report provides information on the routing of “non-directed orders” which is generally defined as any order that the client has not specifically instructed to be routed to a particular venue for execution.
For these non-directed orders, Axos Clearing LLC has selected the execution venue on behalf of its clients.
The report is divided into four sections: one for securities listed on the New York Stock Exchange, one for securities listed on The Nasdaq Stock Market, one for securities listed on the American Stock Exchange or regional exchanges, and one for exchange-listed options.
For each section, this report identifies the venues most often selected by Axos, sets forth the percentage of various types of orders routed to the venues, and discusses the material aspects of Axos’ relationship with the venues.
Please click on the following link https://www.axosclearing.com/disclosures/ and see the information provided under Routing Disclosure-Rule 606.
New York City
40 Wall Street, Floor 7
New York, NY 10005
Phone: (646) 968-8000
1213 Culbreth Dr Suite 211
Wilmington, NC 28405
The content is developed from sources believed to be providing accurate information. The information in this material is not intended as tax or legal advice. Please consult legal or tax professionals for specific information regarding your individual situation. Some of this material was developed and produced by FMG Suite to provide information on a topic that may be of interest. FMG Suite is not affiliated with the named representative, broker - dealer, state - or SEC - registered investment advisory firm. The opinions expressed and material provided are for general information, and should not be considered a solicitation for the purchase or sale of any security.
We take protecting your data and privacy very seriously. As of January 1, 2020 the California Consumer Privacy Act (CCPA) suggests the following link as an extra measure to safeguard your data: Do not sell my personal information.