The Department of Enforcement alleges: SUMMARY 1. Respondent John Polemis induced a customer he knew to be terminally-ill to lend him $28,000 by pretending he would repay the loans. Not only did he not repay the loans, Polemis additionally traded in the customer’s account in the weeks and months after his death, generating more than $3,000 in commissions. 2. In particular, between May 2022 and April 2024, while registered with FINRA through Park Avenue Securities LLC (CRD No. 46173) and later Stirlingshire Investments (CRD No.