Bank of America joined other firms in asking junior bankers to disclose future job offers.
This follows similar policies by JPMorgan, Goldman Sachs, Citi, and Morgan Stanley.
BofA's approach seeks to balance conflict-of-interest concerns with young bankers' ambitions.
Bank of America's junior bankers are the latest young cohort on Wall Street to receive new guidance on accepting hush-hush private equity jobs while employed by the bank.
The Brian Moynihan-led bank will ask its analysts to disclose whether they have offers for future-dated jobs, according to a person with direct knowledge of the matter. The policy was first reported by Bloomberg.
It follows similar rules rolled out by JPMorgan, Goldman Sachs, Citi, and Morgan Stanley in recent weeks, with one big exception: BofA juniors who accept these future-dated job offers will not be terminated but rather reassigned to another area within the bank.
A Bank of America spokesperson declined to comment.
By contrast, JPMorgan has told juniors that their "employment with the firm will end" if they take offers. Other banks weren't as specific about what would happen if the bankers attest that they indeed have future jobs lined up, which the banks have criticized as a potential conflict of interest. Citi's memo said that anyone with a future-dated job would be assessed on "a case-by-case basis," and Morgan Stanely juniors were told they could face disciplinary action.
BofA's approach comes as banks struggle to balance their staffing needs with the career ambitions of young bankers who want to jump to the buy side after their investment banking analyst stints end, usually after two years.
The PE industry's habit of filling future analyst classes with junior investment bankers two years in advance has become a major thorn in the side of many investment banks. In the last few years, the recruiting timeline has been pushed up to the point that college grads were secretly interviewing for future-dated PE jobs before they had even officially started their current banking jobs.
Many banks have buyout firms as clients, which could lead to conflicts of interest for the bankers working on deals with future employers.
"I think that's unethical. I don't like it, and I may eliminate it regardless of what the private-equity guys say," Dimon told college students at Georgetown University last year, adding: "You are already working for somewhere else, and you are dealing with highly confidential information for JPMorgan."
This year, JPMorgan's stance seemed to cause a fall of the dominoes. In June, CEO Jamie Dimon blasted the practice. Days later, buyout shops Apollo Global Management, General Atlantic, and later TPG announced they'd hold off on recruiting for 2027 analysts until next year β an unprecedented step.
Zombie funds are on the rise as private equity dealmaking and distributions slow.
We asked recruiters about the reputational impact of working at a zombie fund.
They suggested looking for an exit, especially if you're an investor or fundraiser.
Have you heard the news? A new contagion is turning formerly healthy private equity firms into the walking dead. It's not fungal, like in "The Last of Us," a virus, like in "28 Days Later," nor a magical reanimation like the original Haitian Vodou Zombis.
Instead, it's the result of a dealmaking slump, pickier investors, and macroeconomic conditions that have turned some private-equity firms into glorified estate sales, auctioning off their dusty holdings before closing up shop.
There are many definitions of a zombie fund β but no matter how you slice it, it can be bad for your career.
To some, a zombie fund is one that's passed its investment deadline, but is still holding onto capital to invest. Others say it's a firm that can't raise new money and is stuck managing and selling off its current portfolio. Zombie fund can also refer to a fund that has invested capital but is delaying the process of returning money to investors while it continues to collect management fees.
The phrase has picked up steam amid a multiyear lag in M&A and IPOs that has slowed private equity dealmaking and distributions to investors.
Private markets data firm PitchBook said the number of US funds that haven't made an investment in a year, despite raising money in the last six years, is up 50% from 2021 to June 2025, to 651. Internationally, they're up 40% in the same period to 1203.
We spoke to recruiters about the rise of the zombie funds and what that means for people working for them. Here is what they said.
When to run
Recruiters said employees, especially in certain roles, should start job-hunting at the first sign of zombification, though they warned that not every slowdown signals trouble.
"If they are working at a firm that has no plans to fundraise for the foreseeable future, that is usually their sign to go straight to exploring the market," Jessica Xu, head of investor relations recruiting at Selby Jennings, told Business Insider.
This is especially true for people in fundraising roles, where success means growing the firm's assets under management and building strong and deep relationships with investors.
Bill Matthews, partner at BraddockMatthewsBarrett, said it's also true for people in investment roles because a zombie fund will drag down your investment track record.
"Folks have to pick their head up and move," he said, adding, "On the investment side, you want to have a track record of doing deals and exiting deals, and if there's a zombie fund, that's not going to be the case."
Of course, fundraising has slowed across the board and isn't necessarily a death knell. It's important to differentiate between a slowdown due to market conditions and one caused by dissatisfied investors. Just make sure you're keeping busy during the slowdown, said Lisa Steele, a partner at BraddockMatthewsBarrett.
"You're maintaining relationships and keeping current LPs up to date, which is also critically important to these long-term partnerships," she said, referring to limited partners, the industry's catchphrase for fund investors.
You should also be developing new relationships, which Steele said will prove "hugely valuable when you go back to market."
How to interview
A candidate running from a zombie fund may feel tempted to hide their current situation in a bid to make the candidacy more enticing. That would be a mistake, recruiters said.
Matthews said hiring firms tend to know which of their peers are zombie funds from conversations with investors and other intermediaries.
"It's important for candidates to be as transparent as possible with potential employers about their reasons for wanting to leave their current firm, and working at a zombie fund is an understandable reason," Xu said.
The trick is to do it smartly. Recruiters warned against badmouthing the current employer or divulging confidential performance information. Focusing on personal gain is key, they said.
"Many candidates in these situations feel constrained in their ability to drive growth and create meaningful value for their investors," said Xu, adding that they are "seeking environments where they can contribute more strategically."
By focusing on how you'd benefit from moving to a better-performing fund, you come across as a good player on a bad team. And it's worth remembering that there are worse situations to be in.
"A hiring firm's biggest fear is unknowingly hiring another firm's castoff," Matthews said. "A zombie fund situation is obviously a good and valid reason why someone would want to leave."
Lucia Soares, Carlyle's chief innovation officer and head of tech transformation.
Carlyle
Lucia Soares is helming Carlyle's AI transformation after years of bringing tech to big companies.
She spoke to BI about the firm's AI rollout and how it's already resulting in cost savings.
She also spoke about life as a bicoastal executive and what she learned from her immigrant parents.
Lucia Soares had been working for Carlyle for four years when the private equity giant's CEO called to ask if she would take on a new role.
"I originally focused on using tech to create portfolio value," she told Business Insider, referring to the companies Carlyle controls. "Then, two years ago, our new CEO called me and said, 'Can you please do what you're doing for our portfolio companies but for our own company internally?'
Now, Soares β as Carlyle's chief information officer and head of technology transformation β is taking on a new challenge: Bringing artificial intelligence to the investment giant's 2,300 global employees.
She spoke with Business Insider about the rollout, including the successes, the pitfalls, and how the company is implementing checks and balances. She explained where the company is already seeing cost savings, for example.
She also walked us through her life as a bicoastal tech executive β and how she learned to hustle from a young age, helping her immigrant parents sell plants at the flea market on weekends. The interview has been edited for length and clarity.
What are your tech goals for Carlyle?
In my 27 years in technology, I've learned that you can't start with technology itself as the goal. People said that e-commerce is the goal, or that digital is the goal. Now, they say AI is the goal. And actually it's not.
Instead, we start with our business goals: we want to grow, create efficiencies, and build a strong tech foundation. AI and other technologies are levers to achieve these goals.
Tell us about Carlyle's AI rollout.
Increasing our employees' AI fluency is a strategic priority. They get AI training from the day they start at Carlyle, and are introduced to a wide range of tools they can use.
Now, 90% of our employees use tools like ChatGPT, Perplexity, and Copilot. We also have an AI champions' council where early adopters can play around with tools and eventually share best practices.
We're using AI to transform our workflows through Project Catalyst, which automates processes. We're also developing custom tools that leverage proprietary data to deliver insights instantlyβsaving investors from sifting through endless materials. Today, Carlyle's credit investors can assess a company in hours using generative AI, instead of spending weeks on research.
How is AI impacting the average worker at Carlyle? Are they required to use the technology?
It depends. Some business leaders have made it a requirement to put all investment committee memos in an AI tool for them to review. Others are not so direct about it, but everybody is seeing how it can make their jobs easier and challenging their teams in meetings to talk about the value they are deriving from AI tools.
As a firm, we have a return-on-investment strategy, and my team aims to deliver a certain amount of ROI every year.
We're not eliminating people's jobs, but we believe that it can help reduce dependency on outside services costs. For example, we can use AI to review legal invoices and catch errors that will reduce our costs. We've seen real savings as a result.
How do you balance autonomy with the risks of adoption?
I think a lot about that. I worry about kids in school using a tool to write an essay and not being able to think. But you have to wonder how people felt when the calculator came out, and if they thought no one would ever be able to do math on their own again.
We never allow AI to make a final decision. There's always a human in the loop, and someone needs to be accountable for the final results.
For example, when employees use AI to write a report, we have employees write a final paragraph summarizing the output to ensure they're thinking critically about it.
Can you give examples of success and failure in Carlyle's tech transformation?
Let's start with success.
When investors invest with us, we can at times receive up to 80-page documents with questions about everything from our employees to cybersecurity training. It's very manual.
We had one team decide they'd try to use AI to make investor diligence easier. Despite having just one technologist, this team found a solution to automate the process, which we're launching later this year.
We seek to empower people to solve things themselves, with embedded technologists across the organization.
We experienced more challenges dealing with regulatory restrictions on large language models globally. We learned the hard way that these regulatory hurdles require a lot of evaluation. We're launching solutions, but it's taking longer than expected to deploy.
You might think you can go fast with AI, but it doesn't always work that way, especially in today's global climate.
Has any single piece of career advice stuck with you over the years, and what is it?
Early on, I was advised to always raise my hand for the extra hard assignments. In other words, take a risk and bet on yourself.
My parents are immigrants, and I learned work ethic, courage, and audacity from them. But when I entered the workforce, I had impostor syndrome. With blue-collar parents, the office environment was completely different for me.
By taking on difficult assignments, I created relationships and visibility and was able to learn and grow more.
Tell me about your parents.
They are from the Azores Islands in Portugal. They came to the US during the dictatorship years. My dad only went to school up until the age of 10, because his family could not afford to pay for more education. He can add, subtract, and multiply, but was never taught how to divide.
He came to the US after serving in the Portuguese Army to give his family a better future. He knew no English.
He became a custodian, cleaning schools, and had a side hustle selling house plants at a flea market on the weekends. We all helped cultivate and sell the plants. I learned a lot from my parents.
What does your morning routine look like?
I am bicoastal: I spend one week a month in DC and also time in New York, but I live on the West Coast and work out of our Menlo Park office.
On the East coast, I might start my day β work permitting β listening to news podcasts, going for a run, meditating, and eating a healthy breakfast.
At home, I start really early in the morning. I don't always get that workout in, but I start with some early calls, and then take a break to drive my daughter to school before heading to the office.
When I get to my desk, I write down the day's priorities. I've done this my whole career, and try not to let constant fire drills overtake those priorities. When you're driving transformation, you have to keep strategy at the forefront.
What are the most important meetings of your week?
The most important meetings are the unplanned ones. For example, I run into a coworker, and we start talking about our kids. Then they bring up a company we should partner with. Or I run into an administrative assistant, and they show me new ways they're using Copilot. I get inspired by solving problems with people in real time.
The second most important meetings are the ones where we drive strategy and brainstorm. As technologists, you can fall into the Dilbert category of employees, where you just work through problem resolutions. So I force strategy onto the calendar to ensure we think big and ambitiously about tech transformation.
Jamie Dimon has criticized the private equity industry's recruiting of its junior bankers.
On Thursday, the firm warned incoming juniors not to accept future-dated jobs from buyout firms.
Those who do will be terminated, the bank said in a memo.
JPMorgan is warning junior bankers against taking future-dated jobs with buyout firms βΒ or even sneaking out of job training to take interviews.
On Wednesday, JPMorgan Chase's top investment banking brass sent a memo to incoming first-year IB analysts warning them against participating in the private equity industry's annual recruiting ritual. This whirlwind affair is known asΒ "on-cycle recruiting"Β and promises young bankers lucrative jobs at the end of their investment banking analyst programs, which often last two or three years.
In the memo, John Simmons and Filippo Gori, co-heads of global banking, admonished analysts who accept "future-dated job offer" or "a position with another company before joining us" within their first 18 months of employment, saying they will be terminated if discovered.
"You will be provided notice and your employment with the firm will end," the executives wrote. They said such offers could constitute a conflict for junior bankers working on transactions for PE sponsors who could also be their future employers.
This year's memo appears to be an escalation of a long-simmering personnel issue important to the bank's high-profile CEO, Jamie Dimon.
"I think that's unethical. I don't like it, and I may eliminate it regardless of what the private-equity guys say," Dimon told college students at Georgetown University last year.
Last year, the firm warned incoming junior bankers against the practice, but stopped short of saying it would terminate those who participated.
This year's memo even vowed to terminate junior bankers who dare sneak out of job training to interview with private equity firms, as many did in 2023.
"To succeed in the Investment Banking Analyst Program, your full attention and participation are essential," wrote Simmons and Gori. "Attendance at all training sessions, meetings and obligations is required. Missing any part of the training program may lead to removal from the program and termination," they said.
The memo was first reported by ExecSum, a newsletter offshoot of the popular Instagram account Litquidity. A JPMorgan spokesperson confirmed its authenticity to BI.
As Business Insider has previously reported, private equity's annual recruiting of junior bankers is a frenetic affair that often starts without warning. Young bankers can be asked to drop everything to interview or miss out βΒ resulting in middle-of-the-night interviews or missed vacations and proving a nagging source of disruption for bank bosses.
Dimon has railed against PE recruiting and its impact on his staff. "I think it's wrong to put you in the position," he said in the fall, adding: "You have to kind of decide the next career move before you have a chance to even decide what the company is like."
It remains to be seen how this new rule could impact the future of buyside recruiting. The industry insiders who spoke to BI expressed skepticism over the bank's ability to enforce the new rule.
"I imagine while some junior bankers will be scared off, many will continue to take the risk," Anthony Keizner, a partner at the headhunting firm Odyssey Search Partners, told BI on Thursday. "They always saw banking as a stepping stone, and won't want to be put off starting the next phase of their career."
A former junior banker who now works in private equity agreed.
"Analysts are going to recruit regardless," this person said, adding that young bankers will simply "shut their mouths about" it.
In what appears to be an acknowledge of the competitive pressures young people in the industry face, the bank said in the memo that it would shorten its analyst program from three years to two and a half, offering juniors "quicker advancement opportunities within the firm."
"All the mega funds already fill spots within the first six months," said the private equity professional, who asked to remain anonymous to protect her job. "They're not going to wait for JPM analysts."