operation; risk management; selection and monitoring of its personnel assuring that they have and maintain such qualifications that correspond to the nature of their duties and internal control measures to

management; selection and monitoring of its personnel assuring that they have and maintain such qualifications that correspond to the nature of their duties; measures to prevent improper access to inside

securities company at the time of selling order but the securities company is confident that the customer owns such securities, regardless of whether the securities are in the customer’s possession or