The allegations read: Alex gierbolini was a subject of the customers' complaint against his member firm that asserted the following causes of action: breach of fiduciary duty; gross negligence and breach of the duty of due care; breach of contract and the covenant of good faith and fair dealing; violations of puerto rico and state securities laws; common law fraud and deceit; failure to supervise; control person liability; respondeat superior; and violation of finra and securities industry rules and standards of conduct.