The other, was failure to supervise a broker /adviser when in 2000, a customer alleged Kevin Palmer, while employed at Merrill Lynch and running Supervision and Trading modules recommend unsuitable investments. The complaint settled for $31,500 without fault, arbitration or FINRA claims; National Association of Securities Dealers (NASD) Arbitration No. 00001529 (March 28,2001). Because the customer had not lost money investing with Kevin Palmer directly and since it was a smaller part of a larger well diversified portfolio overall that the customer had approved first, the Broker-Dealer decided to save on legal fees and risks of an attorney advertising to accept customer complaints case on a contingency basis who only get paid when and if customers collect money.