From at least March 2023 to July 2023, a TIS registered representative (Representative A) engaged in improper cancel and rebill activity when he canceled trades he placed in his personal TIS brokerage account and later rebilled them to certain of his customers’ brokerage accounts, without the customers’ knowledge or authorization, causing those customers to incur significant losses. TIS failed to reasonably identify and investigate red flags of Representative A’s improper cancel and rebill activity.