EFTA Document EFTA01356506

1. The client may continue to conduct trades and transactions in existing accounts without Compliance pre-approval, provided that the business has determined these transactions do not involve any unusual and/or suspicious activity or are in a size that is unusually significant or a novel structure. 2. Consistent with this, CMS may also "open" accounts to facilitate activity as a booking matter where the activity has already been approved in AWM. 3. In addition, the business will need to