The allegations read: 10-03-00, sec news digest, issue no. 2000-186, dated september 27, 2000, enforcement proceedings and administrative proceeding release #34-43356, discloses: respondent failed to reasonably supervise members of the firm who had a prior disciplinary history or a history of customer complaints and who engaged in unsuitable and unauthorized trading and churning in customer accounts, including the accounts of elderly clients; and failed to implement adequate procedures; and failed to devote sufficient resources to the firm's supervisory system that could have alerted the firm to such misconduct.