According to FINRA, David Brian Test was fined $5,000 and suspended from association with any FINRA member in all capacities for two months for forging customer initials and falsifying customer documents.

Test met with certain customers to transfer their assets to a mutual fund sold through his member firm and provided the customers with new account documents to complete and sign. After the customers had signed the new account documents, Test realized that some customers had not checked certain boxes on their new account documents related to the rationale for the transactions.

Without the customers' prior permission, Test checked the applicable boxes on new documents that had previously been signed by the customers and signed the customers' initials next to the boxes he had checked. Test then submitted all the documents to the firm. Subsequently, Test admitted to the firm that he had signed the customers' initials on the documents without the customers' prior permission.

After the firm identified Test's forgeries, the firm requested that the customers re-execute the new account documents, and all of the customers re-executed the documents with the same information Test had previously submitted. By forging and falsifying documents, Test caused the firm to maintain inaccurate books and records.

The suspension was in effect from February 21, 2023, through April 20, 2023.

Even though the customers ultimately re-executed the documents with the same information and no customer was harmed, Test's conduct was still a serious violation. Forging customer initials, even for what may seem like a minor omission, is never acceptable. Customers have the right to review and initial or sign every part of their account documents.

Test's conduct shows poor judgment and a willingness to take shortcuts rather than following proper procedures. The proper course of action would have been to contact the customers and ask them to check the boxes and initial the documents themselves. Instead, Test took it upon himself to forge their initials, which violated their trust and the firm's procedures.