The allegations read: Nasd rules 2110, 2860(b), 2860(b)(20), 3010 - birkelbach, acting on behalf of his member firm, failed to establish and maintain adequate written supervisory procedures to ensure an employee's activities related to options trading were in compliance with securities laws and regulations and failed to have written supervisory procedures which provided the circumstances under which a registered representative would be subject to special supervision, among other things, the presence of a disciplinary history or regulatory action. The complaint alleges that birkelbach failed to reasonably supervise a representative's handling of customers' accounts and failed to adequately review documents to prevent misleading documents from being sent to customers.
