The allegations read: In december 2019, an colleague of jonmark richardson recommended an investment in a private placement to the plaintiffs 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. Plaintiffs claim the investment was unsuitable and asserts causes of action against fpa and mr. Richardson for breach of fiduciary duty, securities fraud, negligence, constructive fraud, negligent misrepresentation, breach of contract and breach of implied covenant of good faith and fair dealing, and punitive damages against mr. Richardson and fpa.