ASSOCIATED INVESTMENT SERVICES, INC.

Discharged

Employee was responsible for properly documenting the opening of an annuity for a couple. The Principal Review Desk reviewed the paperwork the employee submitted, noted multiple deficiencies, and placed the transaction in Not-In-Good-Order (NIGO) status. Employee attempted to address the deficiencies, but those efforts resulted in the Principal Review Desk raising additional questions. As a result, an internal investigation was initiated. It was determined there was no customer harm, but the employee admitted to violating Firm policies including, among other things, improperly adding clients' initials to a document and, in connection with an internal investigation, providing statements that were contradictory to the facts.

FINRA

FINRA RULE 2010, NASD RULE 2370: GOLEMBIESKY BORROWED $30,000 FROM A CUSTOMER, WITHOUT THE KNOWLEDGE OR APPROVAL OF HIS MEMBER FIRM. THE FIRM PROHIBITED REGISTERED REPRESENTATIVES FROM BORROWING MONEY FROM CUSTOMERS, UNLESS THAT CUSTOMER WAS A MEMBER OF THE REGISTERED REPRESENTATIVE'S IMMEDIATE FAMILY, AND THE REGISTERED REPRESENTATIVE HAD REQUESTED AND RECEIVED PRIOR WRITTEN PERMISSION FROM THE FIRM. THE CUSTOMER WAS NOT A MEMBER OF GOLEMBIESKY'S IMMEDIATE FAMILY. THE LOAN WAS THUS PROHIBITED UNDER THE FIRM'S WRITTEN PROCEDURES. WHEN THE FIRM BECAME AWARE THAT GOLEMBIESKY HAD BORROWED MONEY FROM THE CUSTOMER, GOLEMBIESKY HAD REPAID THE CUSTOMER $10,000 ON THE LOAN. THE FIRM'S BANK AFFILIATE REPAID THE BALANCE OF THE LOAN TO THE ESTATE OF THE CUSTOMER. BY PROMISSORY NOTE, THE BANK AND GOLEMBIESKY ENTERED INTO AN AGREEMENT, WHEREBY GOLEMBIESKY PROMISED TO PAY THE BANK $22,275 PLUS ANY APPLICABLE INTEREST. GOLEMBIESKY HAS REDUCED THE OUTSTANDING AMOUNT TO $10,000.

Acceptance, Waiver & Consent(AWC)

Civil and Administrative Penalty(ies)/Fine(s)

$5,000.00

Suspension

ALL CAPACITIES

30 DAYS

8/1/2011

8/30/2011

WITHOUT ADMITTING OR DENYING THE FINDINGS, GOLEMBIESKY CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR 30 DAYS. THE FINE SHALL BE DUE AND PAYABLE EITHER IMMEDIATELY UPON REASSOCIATION WITH A MEMBER FIRM FOLLOWING THE 30 DAY SUSPENSION, OR PRIOR TO ANY APPLICATION OR REQUEST FOR RELIEF FROM ANY STATUTORY DISQUALIFICATION RESULTING FROM THIS OR ANY OTHER EVENT OR PROCEEDINGS, WHICHEVER IS EARLIER. THE SUSPENSION IS IN EFFECT FROM AUGUST 1, 2011 THROUGH AUGUST 30, 2011.

WITHOUT ADMITTING OR DENYING THE FINDINGS, GOLEMBIESKY CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE HE IS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR 30 DAYS. THE FINE SHALL BE DUE AND PAYABLE EITHER IMMEDIATELY UPON REASSOCIATION OR REQUEST FOR RELIEF FROM ANY STATUTORY DISQUALIFICATION RESULTING FROM THIS OR ANY OTHER EVENT OR PROCEEDINGS, WHICHEVER IS EARLIER. THE SUSPENSION IS IN EFFECT FROM AUGUST 1, 2011 THROUGH AUGUST 30, 2011.

PRIMEVEST FINANCIAL

Discharged

TAKING A LOAN FROM A CLIENT