Ex-Merrill rep suspended, fined $10,000 over expense reports

Finra says Sandy Galuppo submitted improper reimbursement requests.

The Financial Industry Regulatory Authority has fined former Merrill Lynch representative Sandy Galuppo $10,000 and suspended him for one year for submitting dozens of business expense reimbursement requests that were not compliant with the firm’s policies.

Finra said Mr. Galuppo “knew or was reckless in not knowing” that the requests were non-compliant.

From 2012 to 2015, Finra said, Mr. Galuppo submitted over 600 expense reimbursement requests. In them, Mr. Galuppo sometimes described meals with his team members as meals with clients, or personal meals as business meals. In other instances, he provided inaccurate information about the reported attendees at meals, Finra said.

It cited one example in which Mr. Galuppo submitted an expense for $430 that was identified as a client meal with a client representative in attendance, when in fact only Mr. Galuppo and another Merrill Lynch employee were present. In total, Finra found that approximately 82 expenses, primarily business-related meals, contained inaccurate information.

Mr. Galuppo joined Merrill Lynch in September 1995 and was discharged in October 2016. According to Finra’s BrokerCheck website, he was then employed for less than a month at Boston-based WFS LLC before being terminated in April 2017. He is not currently associated with a Finra-member firm.