The allegations read: In july, 2013, customer purchased three certificates of deposit issued by the firm's affiliate bank for $100,000.00 each. The interest payments on these cds are linked to the performance of a basket of three stocks. In order to receive an annual interest payment on the cds, the price of all three stocks must have increased or remained the same. The customer claims that representative (who was acting in his capacity as an employee of the firm's affiliate bank in offering said cds) did not adequately disclose the terms of the cds, despite being clearly disclosed on the term sheet provided to the customer, and acknowledged in writing by the customer, at the time of the sale.