© 2021 KOR Financial Inc.

Denial, Revocation, or Suspension 

of Client Access Policy

2021-04-01
Denial, Revocation, or Suspension of Client Access Policy 1

Table of Contents

................................................................................................................................................... 0

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

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

1. Overview................................................................................................................................. 3

2. Disciplinary procedures ........................................................................................................... 3

2.1 Violation of SDR rules...................................................................................................................3

2.2 Client Denial, Revocation, or Suspension.....................................................................................3

2.3 Restoring Client Access ................................................................................................................3

3. Appendix A: Exhibits................................................................................................................ 4
Denial, Revocation, or Suspension of Client Access Policy 2

History

Date Description of change Sections Updated

2021-04-01 Original Document
Denial, Revocation, or Suspension of Client Access Policy 3

1. Overview

The policies and procedures implemented by the Applicant to review any prohibition or limitation of any 

person with respect to access to services offered or data maintained by the Applicant and to grant such person 

access to such services or data if such person has been discriminated against unfairly are covered in the KOR 

Rulebook section “Disciplinary procedures” as copied below (edited to be across trade repositories as same 

rules apply across).

2. Disciplinary procedures

2.1 Violation of TR

1

rules

The CCO or his or her designee is responsible for investigation of any potential violation of the applicable KOR 

TR Rulebook. The CCO has the authority to request information of any Client as part of an investigation of any 

rule violation. Rule violations will be documented, and all supporting documentation will be retained. If 

deemed necessary by the CCO, a Client or User’s access may be suspended or revoked. The CCO is also

responsible for making a decision to restore a Client or User’s access by conducting a comprehensive review 

of a Client’s compliance with regulatory requirements as well as KOR SDR Rules, as applicable.

2.2 Client Denial, Revocation, or Suspension

KOR Reporting has the right to decline, revoke, or suspend a Client. Market Participants may be denied access 

pursuant to Applicable Law (e.g., OFAC or the direction of a regulator), violation of KOR TR Rules, or improper 

use of the system. KOR shall notify the applicable regulator of any Client whose access has been denied, 

revoked, or suspended due to Applicable Law. Final determination to decline, revoke, or suspend a Client shall 

be made by the Chief Compliance Officer. 

In the event a Client is denied, revoked, or suspended; KOR shall provide the Market Participant written notice 

containing the grounds for determination and the opportunity to appeal the decision to the CCO and Board of 

Directors by written request. 

2.3 Restoring Client Access

KOR may restore access to a Client after approval from the CCO and/or the Board of Directors. The CCO shall 

take under consideration Applicable Law, regulatory requirements, and the Market Participant’s response to 

the cause of denial, revocation, or suspension. All decisions shall be documented when determining whether 

to restore access.

1 Trade Repository (TR) is an all-encompassing term that includes Swap Data Repository (SDR) and Security Based Swap 

Data Repository (SBSDR) for which KOR Reporting Inc. is registered.
Denial, Revocation, or Suspension of Client Access Policy 4

Appendix A: Exhibits

Regulator  Exhibit  Exhibit  Description

CFTC  EE Attach as Exhibit EE, policies and procedures implemented by the Applicant to 

review any prohibition or limitation of any person with respect to access to 

services offered or data maintained by the Applicant and to grant such person 

access to such services or data if such person has been discriminated against 

unfairly.

SEC Y Attach as Exhibit Y policies and procedures implemented by the applicant to 

review any prohibition or limitation of any person with respect to access to 

services offered or data maintained by the applicant and to grant such person 

access to such services or data if such person has been discriminated against 

unfairly.