SecProbe.io

January 17, 2025
Dara Albright
President and Chief Executive Officer
Worthy Property Bonds 2, Inc.
11175 Cicero Dr., Suite 100
Alpharetta, GA 30022
Re:Worthy Property Bonds 2, Inc.
Offering Statement on Form 1-A
Post-Qualification Amendment No. 6
Filed December 31, 2024
File No. 024-12206
Dear Dara Albright:
            We have reviewed your amendment and have the following comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response. After reviewing any amendment to your offering statement and the information you
provide in response to this letter, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our December 23, 2024
letter.
Amended Offering Statement on Form 1-A
General
1.We note your response to comment 6 in our letter dated November 5, 2024. While we
do not have any further comments at this time regarding your response, please
understand that our decision not to issue additional comments on this topic should not
be interpreted to mean that we either agree or disagree with your analysis with respect
to this matter. Finally, we note that Rule 12g5-1(a)(7) of the Exchange Act only
applies to securities issued in a Tier 2 offering pursuant to Regulation A.
Cover page
We note your disclosure regarding the offering of $2,280 Worthy Property 2, Bonds
on the cover page and elsewhere. Please revise to clarify that the $2,280 bonds have
already been sold and are not being offered pursuant to this offering. Also, please tell 2.

January 17, 2025
Page 2
us under what exemption under the Securities Act these securities were offered and
sold, or advise.
Worthy Property Bond 2 Referral Program, page 55
3.We note your response to prior comment 1 and that it still appears that your
worthypropertybonds website includes the following language -   When a new user
referred by an existing user (or marketing partner link) opens a Worthy account for
the first time and completes their first bond purchase, a free, $10 bond will be
awarded to the new customer's account.   We also note that worthybonds website
states that -  When a new user referred by an existing user (or marketing partner link)
opens a Worthy account and connects a verified funding source for the first time and
enrolls in an eligible offering, a free, $10 bond will be awarded to the new customer's
account. Please reconcile and also explain what actions an investor needs to take to
enroll in an eligible offering.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact Ruairi Regan at 202-551-3269 or Jeffrey Gabor at 202-551-2544 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Frank Borger Gilligan, Esq.