According to FINRA, Derek John Rehill was suspended from association with any FINRA member in all capacities for two months for preparing inaccurate customer contact notes reflecting telephone calls with customers. No monetary sanction was imposed in light of Rehill's financial status.

Rehill was responsible for periodically calling customers whose accounts his member firm had identified as actively traded to confirm, among other things, the investment objective and risk tolerance reflected on the customer's new account form. For each call, Rehill was required to complete a customer contact form including fields to record whether the customer had confirmed his or her investment objective and risk tolerance.

Rehill completed customer contact forms that inaccurately stated that customers had confirmed their investment objectives and risk tolerances when they had not. He also completed customer contact forms reflecting that customers had confirmed they had a speculative investment objective when, in fact, the customers had not made such confirmations. In one instance, Rehill completed a customer contact form reflecting that a customer had confirmed he had a speculative risk tolerance when Rehill had not asked the customer any questions about his risk tolerance.

Investors should understand that customer contact notes and investment profile confirmations are important safeguards to ensure that trading activity in accounts remains suitable for customers' actual objectives and risk tolerance. When representatives falsify these records, it undermines the firm's ability to supervise trading activity and protect customers from unsuitable recommendations. This case demonstrates that creating false documentation about customer conversations is a serious violation even when there is no evidence of customer harm. Accurate recordkeeping is fundamental to investor protection and regulatory oversight.