In an ongoing effort to prevent money laundering at Penson and Track Data Securities, as one of Penson's correspondents, the following policies shall apply to all foreign accounts.

1. Identifying documentation will be required in order to establish all international accounts, including international futures accounts. This requirement will necessitate a copy of a picture ID (verified by a governmental agency or authority, i.e., valid passport, driver's license, etc.) in addition to the standard account opening documentation. An account will not be opened or will not be permitted to remain open if all information on the new account documents (New Account Form, Acknowledgement Page, etc.) is not provided. International accounts will not be permitted to have a 30 day grace period in which to get in account paperwork. The account will not be opened/will be closed immediately if all required documentation is not provided. The customer will not be permitted to decline providing financial or other personal information requested in connection with account opening documentation. In the event the customer fails to provide such information, the account will may not be opened.
2. Any incoming funds will not be accepted unless all necessary paperwork has been received and processed.
3. All incoming funds in connection with international accounts (including check or wires drawn on a foreign bank account OR checks or wires for foreign accounts) will be required to go through JP Morgan Chase Bank (formerly Chase Bank).
4. All incoming funds in connection with international accounts will be required to be in U.S. currency.
5. No third party transfers will be effected for international accounts.
6. No checkwriting will be available for international accounts.
7. Track Data Securities and Penson will not accept cashiers checks, money orders, bank drafts, credit card checks, travellers checks or electronic checks for international accounts.
8. Penson approval will be required for all outgoing funds for international accounts.
9. Incoming funds into international accounts will be required to be held at least 30 days before being dispersed.
10. International accounts will be run against the OFAC database on a quarterly basis. Accounts found to match with this database will be frozen/closed immediately.

* Please note that accounts will not be accepted from the following countries/entities: Libya, Iraq, the Balkans, the Federal Republic of Yugoslavia (Serbia and Montenegro), Cuba, the National Union for the Total Independence of Angola (UNITA), North Korea, Iran, Burma (Myanmar), Sudan, the Taliban in Afghanistan, Sierra Leone, and Liberia. Track Data Securities reserves that right to not accept accounts from other countries not listed above.