The Financial Industry Regulatory Authority has filed a complaint alleging a broker induced a terminally ill client to lend him $28,000 and then traded in the client's accounts after his death.
Between May 2022 and April 2024, John Polemis, while registered with Park Avenue Securities LLC and later Stirlingshire Investments, requested 20 loans by misrepresenting that he would fully repay the client, often with interest and within a specified period of time, according to FINRA. However, not only did Polemis not repay any of the loans, he traded in the customer's account "in the weeks and months after his death, generating more than $3,000 in commissions," the complaint states.
Polemis solicited and obtained these 20 loans in violation of his firms' written policies and procedures.
On Feb. 23, FINRA instituted a Wells Notice investigation into Polemis' activity, according to his BrokerCheck profile.
In June and August 2024, after the customer's death, Polemis placed two trades with a total principal value of approximately $157,579 in one of the customer's accounts, without his prior authorization, according to FINRA. At the time of his death, the customer held a trust account at Stirlingshire that was not approved for discretionary trading. Neither the customer nor his estate authorized the transactions.
The trades generated $3,152 in commissions.
Polemis never repaid any of the funds he received from the customer, according to the complaint, and failed to provide information and documents in connection with two FINRA Rule 8210 requests, the first on Oct. 27, 2025, and the second on Nov. 17, 2025.
Polemis was registered as a general securities representative through an association with Park Avenue from April 21, 2022 through March 1, 2024, and through an association with Stirlingshire beginning on March 18, 2024.
On Sept. 5, 2024, Stirlingshire filed a Form U5 terminating Polemis' registration for "[c]oncerns related to failing to . . . comply with [FINRA] Rule 3240," which prohibits borrowing from customers, unless, for instance, the person is an immediate family member or in the business of lending money.
In April 2022, after a several-year hiatus from the securities industry, Polemis re-registered with FINRA through an association with Park Avenue, according to the complaint.
Immediately thereafter, the customer, who previously had been Polemis' customer, opened an account at Park Avenue, with Polemis serving as his registered rep of record.
In or around April 2022, Polemis learned that customer, then age 64, had been diagnosed with terminal cancer, with a life expectancy of 12-24 months, the complaint continues.
In May 2022, Polemis began seeking funds from the customer. Polemis told the customer that the requested funds were loans that he would repay in full, often promising to do so within a short time frame and with interest.
Polemis would plead for loans using his personal email, and the customer would send him the funds through Zelle. On April 29, 2024, for instance, Polemis emailed the customer, "yet again, asking for a loan 'to save all of my belongings' and promising to 'pay you back.'" the complaint states. When the customer didn't respond, Polemis emailed again, asking him "for a $1,000 loan, promising to pay him back as soon as he was 'active and working.'"
By the date of the customer's death on June 1, 2024, Polemis had requested and received 20 separate loans, the complaint states.
FINRA is seeking disgorgement of any and all ill-gotten gains and for Polemis to make restitution, with interest.
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