This loan gave rise to a conflict or potential conflict of interest, which Puzara failed to disclose to the Dealer Member or address with responsible business judgement in the client’s best interest.
At the time, the Dealer Member’s policies prohibited borrowing from clients.
Puzara used the funds to address personal debts and repaid portions periodically until January 2022. By July 2022, DG’s family raised concerns with the Dealer Member, leading to a formal investigation.
During the inquiry, it was revealed that Puzara had not reported the loan in compliance forms and had misled the Dealer Member in an annual review questionnaire by denying any personal financial dealings with clients.
A subsequent directive led Puzara to repay the remaining balance of $11,000 to the client in April 2023.
