NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.
Polychronis engaged in outside business activities without giving prompt written notice of those activities to his member firm. Polychronis wrote annuity business away from his firm, including sales of fixed annuities and an equity-indexed annuity. When his firm questioned Polychronis on various occasions, he initially failed to disclose his outside activities and then later under-reported its scope by falsely claiming that it had been limited to a single transaction.
John Andrew Polychronis : Fined $5,000; Suspended 6 months