FINRA Suspends Broker Christopher Polinaire

Christopher Polinaire (Christopher Edward Polinaire CRD# 4330879) is a previously-registered broker whose last employer was Network 1 Financial Securities Inc. (CRD#:13577) of Hauppage, NY. His prior employers include Arive Capital Markets (CRD#:8060) of Ronkonkoma, NY, First Standard Financial Company, LLC (CRD#:168340) of Garden City, NY, and Rockwell Global Capital LLC (CRD#:142485) of Melville, NY. He has been in the industry since 2004.

Following a 2020 cause exam by FINRA of Arive Capital Markets, it was found that Polinaire “excessively and unsuitably” traded in three customer accounts. These customers were senior investors, all over the age of 65.

• The first customer is an 82-year-old California man who worked in the jewelry business when he opened his account with Arive. From February of 2019 through January of 2020, Polinaire recommended that he make 58 trades in his account, most of which were on margin. The purchases had a total principal value of $2,221,255 and required the account to grow by over 65% just to break even. The customer accepted his recommendations, and paid approximately $44,243 in commissions and fees, plus an additional $4,981 in margin interest for a total of approximately $49,224.
• The second customer is a 83-year-old retired farmer from South Dakota, and was 77 years old when he opened his first Arive account in 2017. Between August 2017 and April 2018, Polinaire recommended 31 trades, and the customer followed those recommendations and made purchases with a total principal value of $539,919 and a “break even” point of just over 35%. The customer later opened a second Arive account. For the first six months of 2019 in this second account, Polinaire recommended 53 trades, all on margin, with a total principal value of $1,100,581, and a “break even” point of nearly 75%. This customer paid approximately $38,936 in commissions and fees and another $1,320 in margin interest for a total of approximately $40,256.
• The third customer is a retired attorney from Virginia and was 69 years old when he opened his first Arive account, and regularly accepted Polinaire’s recommendations. From April 2019 and March 2020, Polinaire recommended that Customer C place 78 trades in his account. Polinaire recommended purchases with a total principal value of $1,142,115, and the “break even” point for this account was 152.56%. This customer paid pay approximately $37,213 in commissions and fees and another $1,307 in margin interest for a total of approximately $38,520.

These three customers paid a combined total of $128,000 in fees and commissions for trades based on Polinaire’s recommendations. FINRA found that these recommendations were “excessive and unsuitable.”

FINRA imposed three sanctions, which Polinaire agreed to when signing the Acceptance, Waiver & Consent (AWC) letter:

• A suspension of eight months from all FINRA members in all capacities, effective 11/7/2022, ending 7/6/2023
• A fine of $7,500
• Restitution to the three clients totaling $128,000, plus interest

Polinaire’s four prior disclosures are all civil judgments with liens. Three of these entries include comments from Polinaire that they are being handled and paid.

Did You Invest With Christopher Edward Polinaire?

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