Former BofA Securities rep penalized for violating policy on expensing meals

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Former BofA Securities rep penalized for violating policy on expensing meals
On Behalf of Hyman Cotter PC
  |   Mar 05, 2026  |  Broker Misconduct

A former investment banking representative for BofA Securities was penalized by regulators over violations of the firm’s policy on meal expenses, ThinkAdvisor reports.

The Financial Industry Regulatory Authority suspended Carly C. Zelner for nine months for her actions.

“Between January 2023 and January 2024, Zelner improperly charged to the firm approximately $6,000 in overtime meal expenses for more than 175 meals,” FINRA stated in its settlement letter. “Zelner had some of the meals delivered to a non-BofA address by circumventing controls in the firm’s meal-ordering application. Zelner 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.”

FINRA noted that the expense policy of BofA Securities allowed employees to order overtime meals to BofA locations and charge them to the firm when they: (1) worked in their assigned firm office for four hours beyond the normal workday on weekdays, or worked on weekends or firm holidays; and (2) consumed the meal on site at their assigned firm office.

In April 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.” Her dismissal involved an “internal review into conduct involving using corporate expenses while working from home. The Form U5 filing led to FINRA’s review of the matter.

Zelner was found to be in violation of FINRA Rule 2010, which requires that members, in the conduct of their business, “observe high standards of commercial honor and just and equitable principles of trade.” When a person uses or causes firm funds to be applied in a manner not intended by the firm, the improper use of those funds constitutes a violation of this rule.

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

Financial advisor misconduct takes many forms. The attorneys at Hyman Cotter PC are uniquely qualified to represent individual investors in investment-related claims against financial professionals and their firms. We understand how financial professionals and their firms are supposed to operate through decades of experience working for the SEC and firms like Morgan Stanley and UBS Financial Services. While in private practice, we have represented individual clients and firms in investment loss matters. If you think your financial professional or firm engaged in misconduct that caused you investment losses, contact Hyman Cotter at (844) 316 8277 or through our online contact form for a no-cost evaluation of your matter.

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