The Financial Industry Regulatory Authority has suspended a former BofA Securities representative for nine months for expensing $6,000 in meals that did not comply with the firm's expense policy.

According to FINRA's order, from October 2022 through April 2024, Carly C. Zelner was registered with FINRA as an investment banking rep with BofA Securities Inc.

On April 18, 2024, BofA Securities filed a Form U5 disclosing that it had discharged Zelner for "[f]ailure to adhere to firm standards related to corporate expenses."

Zelner's BrokerCheck profile states that her dismissal involved an "internal review into conduct involving using corporate expenses while working from home."

Between January 2023 and January 2024, the order states, Zelner "improperly used firm funds by charging the firm approximately $6,000 in meal expenses that did not comply with the firm's expense policy."

During Zelner's employment with BofA Securities, the firm's expense policy, according to FINRA, allowed employees to order overtime meals to BofA locations and charge them to the firm when they:

  • worked in their assigned firm office for four hours beyond the normal workday on weekdays, or worked on weekends or firm holidays; and
  • consumed the meal onsite at their assigned firm office.

During the time period, "Zelner improperly charged to the firm approximately $6,000 in overtime meal expenses for more than 175 meals," the order states.

She had some of the meals "delivered to a non-BofA address by circumventing controls in the firm's meal-ordering application," the order states, and "also had other meals delivered to a BofA location on days when she did not work at any BofA location to create the appearance that she was complying with firm policy."

Zelner accepted and consented to FINRA's findings without admitting or denying them.

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