The allegations read: In june 2020, jonmark richardson recommended an investment in a private placement that later failed. Mr. Richardson is presently an investment advisor representative and sole owner of financial partners of america ("fpa"), which is a licensed insurance producer. Plaintiff claims the investment was unsuitable and asserts causes of action against fpa and mr. Richardson for breach of fiduciary duty, securities fraud, professional negligence, constructive fraud, negligent misrepresentation, and punitive damages and a claim of control person liability against mr. Richardson.