The allegations read: Customer indicates he believes he was sold annuity without appropriate disclosures that hart/abeyta were incentivized to sell that particular annuity. Abeyta received higher payout (on top of standard commission payout) and other incentives such as trips and marketing dollars for previous sales of the annuity family he was sold. Thus he was incentivized to sell all his clients this one family of annuities in violation of abeyta/hart's fiduciary duties. Customer, a senior citizen, indicates he was subject to high pressure sales tactics without disclosure of the downsides of the product sold. In addition, customer stated had he known all the facts he would never have purchased. As a result, customer accuses hart/abeyta of violations of colorado insurance best interest regulations and violating sec reg. Bi. Customer also indicates at time of annuity sale he was physically, mentally and visually debilitated from a previous injury. Customer believes hart/abeyta took advantage of his debilitation by utilizing high pressure tactics while in his diminished state. Customer also alleges violation of reg. Sp and colorado privacy laws in that abeyta and hart currently have possession of his private client financial data and has shared it with their new advisory firm without his express authorization.