The allegations read: Felix a. Bartolomei was a subject of a customer's complaint against his member firm that asserted the following causes of action:
breach of fiduciary duty; breach of contract; contractual negligence; fraud and constructive fraud; failure to supervise and control; violation of section 10b of the exchange act and rule 10b-5, and violation of nasd and finra rules; and violations of the puerto rico uniform securities act 10 l.p.r.a. 890.