The allegations read: Todd was named in a customer complaint that asserted the following causes of action: outside business activities, selling away and private securities transactions; unsuitable investments and negligent account management; negligence and negligent supervision; bogus statement summaries; conversion; violations of the florida securities act; sale of unregistered and non-exempt securities; breach of fiduciary duty and constructive fraud; violations of finra conduct rules and nyse board rules; violations of statutes and industry rules related to senior investors, elderly persons, and disabled adults; and respondeat superior.