(a) a robust risk assessment process for determining the pre-defined approval criteria;

(b) proper documentation to record (i) the basis of the pre-defined approval criteria and (ii) the member(s) of senior management or delegate staff independent of the Trading Member’s sales and dealing who is(are) responsible for establishing the pre-defined approval criteria; and

(c) a process to review the implementation and effectiveness of the pre-defined approval criteria on a periodic basis, and enhance them if necessary.