© 2021 KOR Financial Inc.

Core Principles Chart

2021-04-01
Reporting Core Principles 1

1. Table of Contents

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Table of Contents ......................................................................................................................................... 1

History ......................................................................................................................................................... 2

Compliance with Core Principles................................................................................................................... 3

Appendix A: Exhibits................................................................................................................................... 19
Reporting Core Principles 2

History

Date Description of change Sections Updated

2021-04-01 Original Document
Reporting Core Principles 3

1. Compliance with Core Principles

KOR SDR shall comply with the core principles as described in CFTC Regulation 49.19 at all times while using reasonable discretion in establishing the manner in 

which the swap data repository complies with the core principles

The Chief Compliance Officer (“CCO”) shall review compliance with all core principles annually in the compliance report.

Core Principle(s) KOR SDR Compliance Referenced Exhibits

1: Antitrust considerations

Unless necessary or appropriate to 

achieve the purposes of the Act, a swap 

data repository shall avoid adopting any 

rule or taking any action that results in 

any unreasonable restraint of trade; or 

imposing any material anticompetitive 

burden on trading, clearing or reporting 

swaps.

Unless necessary or appropriate to achieve the purposes of the 

Act, KOR SDR shall avoid adopting any rule or taking any action that 

results in any unreasonable restraint of trade; or imposing any 

material anticompetitive burden on trading, clearing, or reporting 

swaps.

To ensure anti-trust considerations are not overlooked, the CCO is 

intimately involved in the rule making process of the SDR. The 

rulemaking process involves an analysis of any implications of 

inherent violations of the SDR core principles. 

Exhibit D-2: Compliance Manual

Section: “6.2 Anti-trust considerations”

KOR will avoid adopting any rule or taking any action that results 

in any anticompetitive burden on the reporting of derivatives.

To ensure anti-trust considerations are not overlooked, the CCO 

is intimately involved in the rule making process of the SDR as set 

forth in 4.2 Error! Reference source not found.. The rulemaking 

process involves an analysis of any implications of inherent 

violations of SDR core principles.

Exhibit J: Rulebook

Section: “Preamble”

Unless necessary or appropriate to achieve the purposes of the 

Act, KOR SDR shall avoid adopting any rule or taking any action 

that results in any unreasonable restraint of trade; or imposing 

any material anticompetitive burden on trading, clearing or 

reporting swaps.
Reporting Core Principles 4

Exhibit O-1: Fee Schedule

(document in its entirety) 

2: Governance arrangements

Swap data repositories shall establish 

governance arrangements as set forth in 

§ 49.20.

KOR SDR shall maintain governance arrangements that are 

transparent to fulfil public interest requirements and to support the 

objectives of the CFTC, Owners, and market participants. 

Such arrangements are well defined and include a clear 

organizational structure and effective internal controls. 

KOR SDR governance arrangements are transparent. They include the 

charter for the Board of Directors (“BOD”) and each committee 

thereof, the nomination process for the BOD, the names of all the 

directors, an explanation of how the directors maintain an 

independent perspective, and the lines of responsibility and 

accountability. 

The following information will be made available to the Commission 

and the public on KOR SDR’s website in a sufficiently comprehensive 

and detailed fashion as to permit the public and relevant authorities, 

including the Commission, to understand the policies or procedures 

of the swap data repository:

a. KOR SDR’s mission statement; 

b. The mission statement and/or charter of the board of direc

tors, as well as of each committee of KOR SDR that has: 

i. The authority to act on behalf of the board of directors

or

ii. The authority to amend or constrain actions of the boa

rd of directors; 

Exhibit D-2: Compliance Manual

Section: “Governance core principle”

KOR SDR will maintain governance arrangements that are 

transparent to fulfill public interest requirements and to support 

the objectives of the CFTC, owners, and market participants.

Such arrangements are well-defined and include a clear 

organizational structure and effective internal controls.

Exhibit D-1: SDR Governance Principles

(document in its entirety)
Reporting Core Principles 5

c. KOR SDR’s board of directors’ nomination process, as well a

s the process for assigning members of the board of directo

rs or other persons to any committee; 

d. For the board of directors and each committee, the names

of all members; 

e. The lines of responsibility and accountability for each opera

tional unit of KOR

SDR to any committee thereof and/or the board of director

s; and

f. Summaries of significant decisions impacting the public 

interest, the rationale for such decisions, and the process for 

reaching such decisions. Such significant decisions shall 

include decisions relating to the pricing of repository 

services, offering of ancillary services, access to SDR data, 

and the use of section 8 material, SDR information, and 

intellectual property. Such summaries of significant 

decisions shall not require KOR SDR to disclose section 8 

material or, where appropriate, information that KOR SDR 

received on a confidential basis. 

g. A description of the manner in which the BOD, as well as any 

committee considers an “independent perspective” in its 

decision making process. 

The information described in items a through g above is made availa

ble on the KOR website using commonly used language. 

KOR shall not disclose minutes from meetings of its board of directo

rs or committees to the public, although it shall disclose such minute

s to the Commission upon request.
Reporting Core Principles 6

3. Conflicts of interest

Swap data repositories shall manage and 

minimize conflicts of interest and 

establish processes for resolving such 

conflicts of interest as set forth in § 49.21.

A conflict of interest arises when the interests of KOR compete with 

the interests of the employee or director or when such individual has 

a personal or financial relationship or other interest that could 

interfere with the person’s obligation to act solely in the best interest 

of KOR SDR. As discussed in the Conflicts of Interest Policy and KOR 

Code of Conduct, actual and potential conflicts must be disclosed to 

the Compliance department for documentation and tracking of 

certain relationships/activities/affiliations that could result in a 

conflict of interest. 

While we cannot identify in advance every situation that could 

present a conflict or an appearance of a conflict, there are a few 

instances where conflicts typically arise:

1. Personal relationships

2. Outside activities

3. IP development

4. Financial interests

5. Loans

6. Business opportunities

7. Misuse of corporate assets

8. Personal interest that conflict with the interests of a 

Client 

All KOR employees and consultants are required to annually certify to 

the KOR Code of Conduct, which provides a non-exclusive definition 

of a conflict of interest and requires that employees disclose any 

potential conflicts of interest that they may have. As part of each 

Exhibit D-2: Compliance Manual

Section: “6.5 Conflicts of interest”

A conflict of interest arises when the interests of KOR compete 

with the interests of the employee or director or when such 

individual has a personal or financial relationship or other 

interest that could interfere with the person’s obligation to act 

solely in the best interests of KOR SDR. As discussed in the 

Conflicts of Interest Policy and KOR Code of Conduct, actual and 

potential conflicts must be disclosed to the Compliance 

department for documentation and tracking of certain 

compliance requirements including the certification of 

compliance policies, reporting of gifts and entertainment, and 

disclosure of certain relationships/activities/affiliations that 

could result in a conflict of interest.

The following is a non-exhaustive list of conflicts that may arise:

a. Outside business activity – non-software 

development

a. Outside business activity – software development

b. Vendor relationship
Reporting Core Principles 7

1 Commentary to the Final Rule – Part§49 states that such conflicts may originate in the control of an SDR by one reporting entity or a subset of reporting entities (a “control

group”). Such control may result from representation on SDR governing bodies, whether through (i) ownership of voting equity or the exercise of voting rights, or (ii) other direct

or indirect means. A control group may compete with other reporting entitiesin the execution or clearing ofswap transactions and may have an incentive to leverage itsinfluence

over the registered SDR to gain a competitive advantage in relation to other reporting entities. Additionally, because all swaps are required to be reported to a registered SDR,

SDR data and SDR analyses of SDR information could have great commercial value. A control group may have incentive to (i) limit or burden access to such analyses on a

discriminatory basis or (ii) disclose or use the data of other reporting entities for its own competitive purposes (e.g. front-running). The control group may also have an incentive

to cause the SDR to provide such data to an affiliate for derivative application or ancillary services (especially if such application or services are bundled).

disclosure, employees and consultants are required to identify where 

their role falls within the SDR. By virtue of this designation, the CCO 

will be notified of their requirement to review and remediate the 

potential conflict, in conjunction with a senior officer of the SDR in 

accordance with the KOR Conflict of Interest Policy. All disclosures 

where a conflict is identified will be reviewed within five (5) business 

days of being submitted. 

To the extent that conflicts of interest arise and/or are disclosed by 

any member of the BOD, the CCO will be notified to review and 

remediate any such conflict, which may require recusal from any 

decision-making with respect to the SDR to ensure impartiality in SDR 

decision making process. 

To protect the data maintained by the SDR, safeguards have been put

in place that function to protect the data regardless of the presence

of conflicts of interest. The KOR Access Policy prescribes who may

access the SDR. Access is restricted to those individuals who require

the data to perform their assigned job responsibilities. More

c. Discrimination against certain reporting entities1

i. Relationship with a reporting party of 

reporting entity

ii. Unfair or anticompetitive disclosure

All KOR employees and consultants are required to annually 

certify to the KOR Code of Conduct, which provides a nonexclusive definition of a conflict interest and requires that 

employees disclose any potential conflicts of interest that they 

may have. As part of each disclosure, employees and consultants 

are required to identify where their role falls within the SDR. By 

virtue of this designation, the CCO will be notified of their 

requirement to review and remediate the potential conflict, in 

conjunction with a senior officer of the SDR in accordance with 

the KOR Conflict of Interest Policy. All disclosures where a 

conflict is identified will be reviewed within five (5) business days 

of being submitted.
Reporting Core Principles 8

specifically, this includes individuals that are employees directly by

the SDR or are operating pursuant to a documented Service Level

Agreement, all must have a “need to know”. In addition, pursuant to

the KOR Confidentiality and Data Protection Policy, which is

applicable to all KOR employees, the data maintained by the SDR

classified as KOR Highly Sensitive. This classification represents the

highest level of sensitivity of the four data classifications. Data with

the classification cannot be provided outside of KOR unless

appropriately authorized and subjected to protective measures such

as non-disclosure agreements.

To the extent that conflicts of interest arise and/or are disclosed 

by any member of the BOD, the CCO will be notified to review 

and remediate any such conflict, which many require recusal 

from any decision-making with respect to the SDR to ensure 

impartiality in SDR decision making process.

To protect the data maintained by the SDR, safeguards have 

been put in place that function to protect the data regardless of 

the presence of conflicts of interest. The KOR Access Policy

prescribes who may access the SDR. Access is restricted to those 

individuals who require the data to perform their assigned job 

responsibilities. More specifically, this includes individuals that 

are employed directly by the SDR or are operating pursuant to a 

documented Service Level Agreement, all must have a “need to 

know”. In addition, pursuant to the KOR Confidentiality and Data 

Protection Policy which is applicable to all KOR employees, the 

data maintained by the SDR classified as KOR Highly Sensitive. 

This classification represents the highest level of sensitivity of 

the four data classifications. Data with this classification cannot 

be provided outside of KOR unless appropriately authorized and 

subjected to protective measures such as non-disclosure 

agreements.

The chief compliance officer of the SDR shall review the 

compliance of the SDR with this core principle.

Exhibit GG-1: Code of Conduct

Section: “1 Overview”
Reporting Core Principles 9

Action by members of your immediate family, significant

others or other persons who live in your household (referred 

to in the Code as “family members”) also may potentially result 

in ethical issuesto the extent that they involve KOR business. For 

example, acceptance of inappropriate gifts by a family member 

from one of our suppliers could create a conflict of interest and 

result in a Code violation attributable to you. Consequently, in 

complying with the Code, you should consider not only your own

conduct, but also that of your immediate family members, 

significant others and other persons who live in your household.

Section: “16 Speak Up and Escalation Policy”

KOR Reporting is committed to fairness, integrity and respect for 

the law throughout our business lines. It is very important that 

our employees, as valuable eyes and ears of the Company, can 

raise and discuss acts, or potential acts, of misconduct (known as 

“Speaking Up”) with confidence. By doing so, employees give our 

Company the opportunity to deal with the issue appropriately.

Employees (including temporary and casual employees, agency 

staff, consultants, work experience or other trainees and 

contractors) who reasonably believe that malpractice has 

occurred or is likely to occur can raise concerns via the Speak Up 

Policy (“Speak Up”).

16.1 What is the purpose of the Speak Up and Escalation Policy?

The purpose of this policy is to explain how you can raise 

concerns about suspected misconduct in confidence without 
Reporting Core Principles 10

fear of retaliation. It also describes what process you can expect 

if you Speak Up.

16.2 What concerns are covered

16.2.1 Types of Concerns to report 

Stakeholders must report, to their manager or Chief Compliance 

Officer (CCO) or the Speaking Up Program; any known or 

suspected misconduct relating to:

a. Breaches of law or regulation,

b. Improper conduct or unethical behavior;

c. Failure to comply with a legal obligation, regulatory 

directives or statutes;

d. All forms of financial malpractice or impropriety;

e. Insider abuses;

f. Non-compliance with KOR Policies, Procedures; or 

Codes of Conduct;

g. Other forms of corporate governance breaches;

h. Non- disclosure of conflict of interest;

i. The concealment, or deliberate failure to report, a 

known control breach or weakness;

j. any criminal offense (such as fraud, theft, bribery, 

insider trading etc.);

k. improper use of company resources;

l. inappropriate disclosure of confidential information;

m. endangering someone’s health and safety;
Reporting Core Principles 11

n. damaging the environment;

o. Any threat to the KOR’s reputation; or

p. Attempts to conceal any of these, etc.

16.2.2 Inappropriate Use

This policy is not to be used for:

a. raising any grievances you may have in relation to 

your employment;

b. settling personal disputes; or

c. any accusations of a false nature.

16.3 Procedure for raising concerns under the Speak Up and 

Escalation Policy

16.3.1 How to Speak Up 

There are several internal channels available to you should you 

need to Speak Up:

a. You can discuss any concerns with your direct manager, 

who will attempt to resolve the matter as soon as 

reasonably possible or will pass on the matter to the 

Chief Compliance Officer to investigate.

b. You can send an email to speakup@korfinancial.

c. If this is not appropriate or if you consider that the 

concern has not been dealt with sufficiently, you can 

raise the concern directly with the Chief Compliance

Officer.
Reporting Core Principles 12

d. If you reasonably consider that the concern has still not 

been dealt with sufficiently or at all, or if someone in 

your chain of communication is involved in the 

malpractice, you can raise the concern by contacting 

the General Council. 

16.3.2 Investigation

Once a disclosure has been made, the process will be as follows:

a. The person hearing your concern will arrange a 

confidential meeting with you to gather the information 

needed to understand the situation and may ask you to 

put your concern in writing, for clarity, prior to the 

meeting.

b. Following the meeting, the person hearing your 

complaint will decide if any further action needs to be 

taken and, if so, what action. This may include arranging 

another meeting for you to speak to someone at a more 

senior level of management and/or asking you to 

provide some additional evidence.

c. If your concern is valid and is not already subject to 

internal or legal proceedings, a decision will be taken by 

the Company as how to proceed, which may include 

referral to one or more of the following:

the Board of Directors or relevant subsidiary board with 

a view to an internal investigation;

an appropriate external regulatory body for 

investigation; or

the police.
Reporting Core Principles 13

d. You will be advised of timescales that may apply and 

you will be informed of any decision taken. Please treat 

the investigation and any decision taken as 

confidential.

16.4 Confidentiality

As far as possible, any concerns raised via Speak Up and 

Escalation Policy will be treated by the Company in the strictest 

confidence. All reasonable steps will be taken to maintain the 

confidentiality, where it is requested, of anyone Speaking Up. A 

possible exception to this may be if it is required (e.g. by law) to 

break that confidentiality. Should this be the case, you will be 

told in advance.

Anonymous information is just as important to the Company as 

information that is disclosed with an identity. However, if you 

feel you can reveal your identity, you are encouraged to do so as 

this would enhance the Company’s ability to pursue your 

concern and feedback will be limited if you cannot be contacted.

The Company is committed to treating all disclosures 

consistently and fairly, and victimization of any individual 

Speaking Up will not be tolerated. Any instances 

of victimization will be taken very seriously and managed 

appropriately.

16.5 Misuse of the Speak Up and Escalation Policy

If, at any time, it is found that an individual has raised a concern 

in bad faith, they may lose the protection granted under Speak 
Reporting Core Principles 14

Up and may be subject to disciplinary action under the 

Company’s disciplinary procedure.

Exhibit F-1: Conflicts of Interest Policy

(document in its entirety) 

Exhibit F-2: Board of Directors Conflicts of Interest Policy

(document in its entirety) 

Exhibit V-1: SDR Access Policy

(document in its entirety) 

Exhibit GG-2: Confidentiality and Data Protection Policy

(document in its entirety) 

4.(a) Additional duties - Financial 

resources

Swap data repositories shall maintain 

sufficient financial resources as set forth 

in § 49.25.

As an SDR, KOR is required to maintain sufficient financial resources

to comply with all CFTC Regulations. The financial resources 

maintained in the account for the SDR shall be at least equal to a total 

amount that would enable the SDR to cover its operating costs for at 

least one year, calculated on a rolling basis. 

Financial resources that satisfy these requirements include:

a. KOR’s own capital; and

b. Any other financial resource deemed acceptable by the 

Commission.

Financial resources must include unencumbered, liquid financial 

assets equal to at least 6 months’ operating costs. KOR may take into 

account a committed line of credit or similar facility for purposes of 

meeting this 6-month liquidity requirement.

Exhibit D-2: Compliance Manual

Section: “10 Financial resources”

As an SDR, KOR is required to maintain sufficient financial 

resources to comply with all CFTC Regulations. The financial 

resources maintained in the account for the SDR shall be at least 

equal to a total amount that would enable the SDR to cover its 

operating costs for at least one year, calculated on a rolling basis. 

Financial resources that satisfy these requirements include:

a. KOR’s own capital; and

b. Any other financial resource deemed acceptable by 

the Commission.
Reporting Core Principles 15

The financial resources must be independent and separately 

dedicated ensuring that assets and capital are not used for multiple 

purposes.

Financial resources must include unencumbered, liquid financial 

assets equal to at least 6 months’ operating costs. KOR may take 

into account a committed line of credit or similar facility for 

purposes of meeting this 6-month liquidity requirement.

The financial resources must be independent and separately 

dedicated ensuring that assets and capital are not used for 

multiple purposes.

Exhibit M: Financial Information

(exhibits in their entirety) 

4.(b) Additional duties - Disclosure 

requirements

Swap data repositories shall furnish an 

appropriate disclosure document setting 

forth the risks and costs of swap data 

repository services as detailed in § 49.26.

Prior to accepting SDR data from any Client, KOR shall provide the 

KOR SDR Disclosure Document that contains the required information 

which will allow the reporting entity to identify and evaluate 

accurately the risks and costs associated with using the services of the 

SDR.

The following information will be included in the Disclosure 

Document:

a. The criteria for providing access to services offered and 

SDR data maintained by KOR SDR;

b. The criteria for those seeking to connect to or link with 

KOR SDR;

c. A description of the policies and procedures regarding 

the safeguarding of SDR data and operational reliability 

to protect the confidentiality and security of such data 

(see Section above);

Exhibit D-2: Compliance Manual

Section: “11 Disclosure requirements”

Prior to accepting SDR data from any Client, KOR shall provide 

the KOR SDR Disclosure Document that contains the required 

information which will allow the reporting entity to identify and 

evaluate accurately the risks and costs associated with using the 

services of the SDR.

The following information will be included in the Disclosure 

Document:

a. The criteria for providing access to services offered 

and SDR data maintained by KOR SDR;

b. The criteria for those seeking to connect to or link 

with KOR SDR;

c. A description of the policies and procedures 

regarding the safeguarding of SDR data and 
Reporting Core Principles 16

d. The policies and procedures reasonably designed to 

protect the privacy of any and all SDR data that KOR SDR 

receives from a SEF, DCM, or Reporting Counterparty;

e. The policies and procedures regarding the noncommercial and/or commercial use of the SDR data that 

it receives from a SEF, DCM, or Reporting Counterparty;

f. The dispute resolution procedures;

g. A description of all of the SDR Services, including any 

ancillary services;

h. The updated schedule of any fees, rates, dues, 

unbundled prices, or other charges for all of SDR 

Services, including any ancillary services; any discounts 

or rebates offered; and the criteria to benefit from such 

discounts or rebates; 

i. A description of the governance arrangements; and

j. The policies and procedures regarding the reporting of 

SDR data to KOR SDR, including KOR’s SDR data 

validation procedures, swap data verification 

procedures, and procedures for correcting SDR data 

errors and omissions.

operational reliability to protect the confidentiality 

and security of such data (see Section above);

d. The policies and procedures reasonably designed 

to protect the privacy of any and all SDR data that 

KOR SDR receives from a SEF, DCM, or Reporting 

Counterparty;

e. The policies and procedures regarding the noncommercial and/or commercial use of the SDR data 

that it receives from a SEF, DCM, or Reporting 

Counterparty;

f. The dispute resolution procedures;

g. A description of all of the SDR Services, including 

any ancillary services;

h. The updated schedule of any fees, rates, dues, 

unbundled prices, or other charges for all of SDR 

Services, including any ancillary services; any 

discounts or rebates offered; and the criteria to 

benefit from such discounts or rebates; 

i. A description of the governance arrangements; and

The policies and procedures regarding the reporting of SDR data 

to KOR SDR, including KOR’s SDR data validation procedures, 

swap data verification procedures, and procedures for correcting 

SDR data errors and omissions.

Exhibit FF-2: Disclosure document

(document in its entirety)
Reporting Core Principles 17

4.(c) Additional duties - Access and Fees

Swap data repositories shall adhere to 

Commission requirements regarding fair 

and open access and the charging of any 

fees, dues or other similar type charges 

as detailed in § 49.27.

Access to the SDR shall be fair, open and equal; this includes access 

to data required to be publicly disseminated. SDR Services will be 

provided on a non-discriminatory basis. Additionally, KOR SDR does 

not obligate a Client to use a second KOR or third-party service to 

utilize or gain access to SDR. KOR SDR will not as a condition of use, 

require that a Client consent to the external commercial or business 

use of any reported data, including that which is required to be 

publicly disseminated. Likewise, KOR SDR will not, as a condition of 

accepting SDR data from any market participant, require the waiver 

of any privacy rights by such reporting entity.

Fees are assessed in a consistent, non-preferential manner and are 

not permitted to be used as a barrier to entry. KOR SDR will not offer 

preferential pricing arrangements to any Client on any basis, including 

volume discounts or reductions unless such discounts or reductions 

apply to all Clients uniformly and are not otherwise established in a 

manner that would effectively limit the application of such discount 

or reduction to a select number of Clients.

Any fee or charge assessed by KOR SDR for the collection of real-time 

Swap Transaction and Pricing Data shall be equitable and nondiscriminatory. If KOR SDR allows a fee discount based on the volume 

of data reported to it for Public Dissemination, then such discount 

shall be made available to all Reporting Counterparties, SEFs and 

DCMs that are Clients in an equitable and non-discriminatory 

manner.

All fees are fully disclosed and available on the KOR SDR Website.

Exhibit D-2: Compliance Manual

Section: “11.1 Access to SDR services”

Access to the SDR shall be fair, open and equal; this includes 

access to data required to be publicly disseminated. SDR 

Services will be provided on a non-discriminatory basis. 

Additionally, KOR SDR does not obligate a Client to use a second 

KOR or third-party service to utilize or gain access to SDR. KOR 

SDR will not as a condition of use, require that a Client consent 

to the external commercial or business use of any reported data, 

including that which is required to be publicly disseminated.

Likewise, KOR SDR will not, as a condition of accepting SDR data 

from any market participant, require the waiver of any privacy 

rights by such reporting entity.

Exhibit J: Rulebook

Section: “14.4 Fees”

Fees are assessed in a consistent, non-preferential manner and 

are not permitted to be used as a barrier to entry. KOR SDR will 

not offer preferential pricing arrangements to any Client on any 

basis, including volume discounts or reductions unless such 

discounts or reductions apply to all Clients uniformly and are not 

otherwise established in a manner that would effectively limit 

the application of such discount or reduction to a select number 

of Clients.

Any fee or charge assessed by KOR SDR for the collection of realtime Swap Transaction and Pricing Data shall be equitable and 

non-discriminatory. If KOR SDR allows a fee discount based on 
Reporting Core Principles 18

Changes to the SDR fee schedule will be consistent with the principles 

set forth in this section and must be processed through the rule 

amendment process.

the volume of data reported to it for Public Dissemination, then 

such discount shall be made available to all Reporting 

Counterparties, SEFs and DCMs that are Clients in an equitable 

and non-discriminatory manner.

All fees are fully disclosed and available on the KOR SDR Website.

Changes to the SDR fee schedule will be consistent with the 

principles set forth in this section and must be processed through 

the rule amendment process.

Exhibit O-1: Fee Schedule

(document in its entirety)

Exhibit O-2: Fee Schedule Methodology and Differentiation 

(document in its entirety)
Reporting Core Principles 19

2. Appendix A: Exhibits

Regulator  Exhibit  Exhibit Description

CFTC  FF-1 Attach as Exhibit FF, a narrative and supporting documents that may be provided under other Exhibits herein, that describes 

the manner in which the Applicant is able to comply with each core principle and other requirements pursuant to Commission 

Regulation § 49.19.