From at least April 2022 to November 2023, World Investments, LLC failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to comply with Securities Exchange Act of 1934 Rule 15/-1 (Reg BI) and supervise recommendations of exchanges of deferred variable annuities. The firm also failed to surveil for inappropriate rates of deferred variable annuity exchanges. Accordingly, the firm violated Exchange Act Rule 15/-l(a)(l) and FINRA Rules 2330(c)(d), 31 lO(a)-(b), and 2010.

Gherardi refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210. As a result, Gherardi violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.