The allegations read: Christopher thomas tolmacs was named in a customer complaint that asserted the following causes of action: breach of fiduciary duty; breach of loan agreements; breach of the implied covenant of good faith and fair dealing; failure to recommend suitable investments; and conversion. The causes of action relate to respondent tolmacs' recommendation of allegedly unsuitable alternative investment products to claimants and respondent tolmacs' alleged solicitation of claimants to enter into improper lending agreements.