The allegations read: Hirata was named in a customer complaint that asserted the following causes of action: breach of fiduciary duty; violation of california corporations code sections 25401 et seq. (with damages/rescission per section 25501) and sections 25110 and 25130 (with section 25503 relating to damagers and rescission) and sections 25403 and 25504; constructive fraud and fraud; breach of third party beneficiary contract, based on the agreements that respondent has with finra, for which claimant is an intended third party beneficiary; and elder abuse under california welfare & institutions code sections 1500 et seq.