The allegations read: Tolmacs was a subject of the customer\\u2019s complaint against his member firm that asserted the following causes of action: breach of contract and warranties; promissory estoppel; violation of state securities statutes; breach of fiduciary duty; negligence and gross negligence; misrepresentation/omission and negligent misrepresentation/omission; unjust enrichment; failure to supervise; common law and statutory claims; and vicarious and control person liability.