FINRA files complaint against former Park Avenue Securities and Stirlingshire Investments broker John Polemis alleging $28,000 in unrepaid loans from a terminally ill customer and unauthorized trades after the customer’s death

If a family member with a serious illness lent money to a San Diego financial advisor, or if trades showed up in a loved one’s account after that person died, a FINRA action against John Polemis may sound familiar. On May 13, 2026, FINRA’s Department of Enforcement filed a disciplinary complaint against John Polemis (CRD# 4270012), who was registered with Park Avenue Securities LLC in San Diego from 04/2022 to 03/2024 and with Stirlingshire Investments from 03/2024 to 09/2024. BrokerCheck records state that “This broker is not currently registered.”

The record contains one pending regulatory event, two customer disputes, one employment separation after allegations in 2024, and three financial disclosures from 2018. In the first dispute, a 2004 health insurance complaint, BrokerCheck lists the status as Closed/No Action, and Polemis’s broker statement denies the allegations. In the second, customers alleged unauthorized mutual fund transactions in or around March 2008, and the dispute settled on 06/17/2009 for $750, with no individual contribution from Polemis.

What the FINRA complaint alleges: 20 loans from a terminally ill customer

The FINRA complaint opens with this summary: “Respondent John Polemis induced a customer he knew to be terminally-ill to lend him $28,000 by pretending he would repay the loans.” According to the complaint, “between May 2022 and April 2024, while registered with FINRA through Park Avenue Securities LLC (CRD No. 46173) and later Stirlingshire Investments (CRD No. 310576), Polemis induced a terminally-ill customer (Customer A) to provide him with 20 loans, totaling $28,000, by misrepresenting to Customer A that he would fully repay Customer A, often with interest and within a specified period of time.”

The complaint alleges that the customer, “who previously had been Polemis’ customer,” opened an account at Park Avenue in 2022, and that “In or around April 2022, Polemis learned that Customer A, 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 Customer A.” According to the complaint, “By the date of Customer A’s death on June 1, 2024, Polemis had requested and received 20 separate loans from Customer A, totaling $28,000.” The complaint also states that “Customer A was not Polemis’s immediate family member and was not in the business of lending money.”

The complaint describes several of the loans individually. It alleges that “On August 16, 2022, Polemis emailed Customer A from his personal email account, requesting that Customer A provide him with a $1,500 loan, promising to repay Customer A $2,000 on August 30, 2022,” and that “Polemis never repaid any amount of the August 16, 2022 loan.” The complaint alleges that in the final weeks before the customer’s death, “Between April 25 and April 29, 2024, Polemis emailed Customer A five times, using Polemis’s personal email account, seeking funds with the promise of repayment to pay a series of delinquent bills and other personal expenses, totaling approximately $1,500.” According to the complaint, one of those emails asked for a loan “to save all of my belongings” and promised to “pay you back.” The complaint’s Appendix A lists all 20 payments, one by ACH and the rest by Zelle, ranging from $500 to $2,500.

The complaint also alleges that the loans broke both firms’ rules. According to the complaint, “While associated with Park Avenue, Polemis solicited and received 18 loans totaling $26,000 from Customer A, in violation of the firm’s prohibition on borrowing money from customers,” and “While associated with Stirlingshire, Polemis solicited and received two loans totaling $2,000 from Customer A, in violation of the firm’s written supervisory procedures.” The complaint charges violations of FINRA Rules 2010 and 3240 for this conduct.

Alleged trades in the customer’s account after the customer’s death

According to the complaint, “At the time of his death, Customer A held a trust account at Stirlingshire that was not approved for discretionary trading.” The complaint alleges that “On June 27 and August 1, 2024, Polemis purchased securities in Customer A’s non-discretionary trust account, generating $3,151.59 in commission,” and that “Neither Customer A nor any representative of Customer A or his estate authorized these transactions.” The complaint’s Appendix B lists two purchases, with principal amounts of $47,875.50 and $109,704.00, both marked “Solicited.” The complaint charges a violation of FINRA Rule 2010 for the trades.

The alleged failure to respond to FINRA

According to the complaint, FINRA sent requests for documents and information under FINRA Rule 8210 on October 27 and November 17, 2025. The complaint alleges that on October 28, 2025, “Polemis replied by email to FINRA’s October 27 email, indicating that he had met with an attorney and would be in contact,” and that “Polemis never provided FINRA with the documents and information FINRA requested in the First and Second Requests.” The complaint asks the hearing panel to impose sanctions, including an order “that Polemis be required to disgorge fully any and all ill-gotten gains and/or make full and complete restitution, together with interest.”

BrokerCheck records describe the regulatory action as Pending, list the employing firms when the activity occurred as Park Avenue Securities LLC; Stirlingshire Investments, and list the sanction sought as Other: N/A.

It is important to note that, as of the time of this report, the complaint is still pending. No findings of wrongdoing have been made. The BrokerCheck report reviewed for this post lists the matter’s current status as Pending. BrokerCheck employment history, which the report cautions may not reflect current status, lists Sphinx Investments LLC as an “Investment Advisor” position from 12/2024 to Present. The loan and trading allegations concern conduct while Polemis was registered through Park Avenue Securities and Stirlingshire Investments; the complaint does not mention Sphinx Investments.

The 2024 termination and earlier financial disclosures

BrokerCheck records show that Stirlingshire BD LLC discharged Polemis on 08/19/2024. The firm’s allegation reads: “The Firm is concerned that the registered representative failed to comply with FINRA regulations due to information from a customer representative that, before joining the Firm, the registered representative had received a loan from the customer that had not been disclosed or approved by the Firm. The Firm learned that the registered representative had connected his personal bank account with the customer’s brokerage account (no evidence of transfers to this account has been identified).” Polemis disputes part of that account. The broker statement reads: “The personal bank account alleged to have been connected to a customer’s brokerage account was not established by Mr. Polemis, and in fact it was a business account not connected to Mr. Polemis.” The statement adds that “Mr. Polemis believes the allegations asserting the violations of industry standards of conduct were false and appear to be unsubstantiated or erroneous.”

BrokerCheck also discloses three compromises with creditors dated 10/01/2018, with original amounts owed of $23,354.00 to JP Morgan Chase, $10,524.00 to Macy’s, and $5,080.00 to NC Financial. Each is listed as satisfied or released. The broker statement says: “This debt was incurred from my divorce that started in the fall of 2014.” BrokerCheck records also show an earlier registration with NYLife Securities LLC in San Diego from 05/2001 to 09/2010.

Why rules bar brokers from borrowing from clients

A broker who borrows from a client may become a debtor to the person whose money the broker manages, and a client may find it hard to say no to someone who manages the client’s investments. FINRA Rule 3240 generally prohibits registered representatives from borrowing from customers unless the firm’s written procedures allow it, the arrangement meets one of five conditions listed in the rule, and the rule’s notification and approval requirements are satisfied, such as a loan from an immediate family member, from an institution regularly in the business of lending, or one based on a personal or business relationship outside the broker-customer relationship. The complaint alleges that Customer A was not Polemis’s immediate family member and was not in the business of lending money, and that both firms’ policies barred the loans.

The concern may be sharper when the client is seriously ill, because a customer facing a terminal diagnosis may be less able to track small, repeated transfers or to press for repayment. The complaint describes 20 payments over roughly two years, most of them between $1,000 and $1,500, each one, according to the complaint, described as a loan Polemis would repay, often by a specific date and with interest. A pattern of that kind may be hard for a family to spot until someone reviews the account holder’s bank records.

Trading after an account holder’s death raises a separate problem. The complaint describes unauthorized trading as effecting trades in a customer’s non-discretionary account without first obtaining the customer’s authorization or consent, and alleges that neither Customer A nor any representative of Customer A or his estate authorized the June and August 2024 purchases.

The rules that apply

FINRA Rule 2010 requires associated persons to observe high standards of commercial honor and just and equitable principles of trade; the complaint relies on it for the alleged misrepresentations, the loans, the trades, and the alleged failure to respond to FINRA’s requests. FINRA Rule 3240 governs borrowing from and lending to customers. FINRA Rule 8210 allows FINRA staff to require members, associated persons, and other persons subject to FINRA’s jurisdiction to provide information and documents in an investigation. FINRA Rule 3110 requires each member firm to establish and maintain a system to supervise the activities of each associated person that is reasonably designed to achieve compliance with applicable securities laws and regulations and FINRA rules. The complaint does not charge either firm with a supervisory violation. Under FINRA Rule 12206, “No claim shall be eligible for submission to arbitration under the Code where six years have elapsed from the occurrence or event giving rise to the claim.”

California law adds protections that may matter here. Welfare and Institutions Code section 15610.30 defines financial abuse of an elder or dependent adult to include taking property by undue influence or with intent to defraud. Section 15610.27 defines an elder as a California resident 65 or older, and section 15610.23 defines a dependent adult as a resident between 18 and 64 whose physical or mental limitations restrict the ability to protect that person’s rights. Section 15657.5 provides enhanced remedies where financial abuse is proven. The complaint states the customer’s age only as of April 2022 and does not state where the customer lived, so whether these statutes apply depends on facts beyond the complaint. Under Code of Civil Procedure sections 377.20 and 377.30, a cause of action for or against a person generally is not lost by reason of the person’s death, and an action may be commenced by the decedent’s personal representative or, if none, by the decedent’s successor in interest.

What a customer’s family or estate can do

The FINRA complaint asks for restitution, but no hearing panel has ruled, and a disciplinary order of restitution, if one issues, is not the same as a customer’s own claim. An estate or successor trustee can pursue recovery directly. Depending on the facts, an estate may seek unrepaid loan principal, commissions charged on trades it did not authorize and any losses on those positions, and, where California’s elder and dependent adult statutes apply, the additional remedies those statutes provide. Customer claims of this kind may be brought in FINRA arbitration and may name both the representative and the member firms that employed the representative at the time of the conduct. The outcome in any case depends on the facts and the documents.

Steps to Take Right Now

1. Gather your account statements, trade confirmations, and any correspondence with your broker or firm, including emails, texts, and written materials about the investments.
2. Look up your broker on FINRA BrokerCheck at brokercheck.finra.org to review their full disclosure record.
3. Contact a securities arbitration attorney for a consultation to evaluate your options.

Rosenberger + Kawabata represents retail investors in FINRA arbitration proceedings involving broker borrowing violations and unauthorized trading. Contact Rosenberger + Kawabata online for a free and confidential consultation, or call (310) 894-6921.

The information in this post comes from FINRA’s public records and BrokerCheck database. You can view the full detailed report (CRD# 4270012) here.

You can view the full September 2026 FINRA disciplinary actions report here.