The allegations read: Richard sullivan was a subject of the customer's complaint against his member firm that asserted the following causes of action: unsuitable recommendations; failure to perform adequate due diligence; failure to monitor; misrepresentations; omissions; failure to treat claimants in a just and equitable manner; breach of fiduciary duty; breach of contract; fraud; fraudulent misrepresentation; constructive fraud and/or negligent misrepresentation; negligence; gross negligence; and negligent supervision.