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Rule 831(i) SBSEF-CCO-RPT Compliance Report Mockup

THIS DOCUMENT IS A TECHNICAL ILLUSTRATION OF HOW CERTAIN DISCLOSURES IN SEC FILINGS ARE TO BE TAGGED. IT DOES NOT INDICATE WHICH PARTICULAR DISCLOSURES MUST BE INCLUDED AND/OR TAGGED IN COMMISSION FILINGS, AND IT DOES NOT CONSTITUTE LEGAL GUIDANCE OF ANY SORT.

Policies and Procedures

We maintain a set of core policies and procedures that are reasonably designed to achieve compliance with the Regulation SE and other applicable regulatory provisions. Our policies and procedures set out general guidelines for our partners, members, officers, employees, agents (or persons occupying a similar position or performing a similar function) to comply with the requirements of the Commission. Our policies include conflict of interest policies, a code of ethics, financial crime compliance policies, employee trading policies, and document management policies.

We believe our policies and procedures are extremely effective, as we have yet to experience any abrogations thereof.

Our code of ethics provides basic guidelines of business practice and professional and personal conduct that our employees are expected to adopt and uphold. The code is intended to guide conduct to instill public trust and confidence as it demonstrates its commitment to its values. Our employees are required to acknowledge that they have read, understand, and agree to comply with the code and that they are not aware of any circumstances involving them, any family member, or any other employee that would conflict with the code.

We believe our code of ethics is extremely effective, as we have yet to experience any ethical breaches.

Our conflict of interest policy sets forth the requirements for all employees to identify and manage potential conflicts of interest and supplements the existing policies and processes by which conflicts are addressed. Employees are prohibited from trading on the basis of material non-public information.

We believe our conflict of interest policy is extremely effective, as we have yet to experience any issues arising from conflicts of interest.

Material Changes

During the coverage period, we updated our conflicts of interest policy to update definition of family member to include niece and nephew (as aunt and uncle were previously included). We also updated our data management policy to review and update the use standards for financial regulatory reports and non-financial regulatory reports definitions.

Areas for Improvement

As part of post-implementation accuracy reviews, we identified instances where reporting of certain SBS executions in Daily Market Data Reports were inaccurate. Misreported fields included tenor and notional amount. We have initiated efforts to resolve this issue, including correction of the erroneous reports. Nonetheless, proper creation and dissemination of Daily Market Data Reports is an area for improvement.

Recommended Changes

We recommend improving our monitoring and review processes to ensure Daily Market Data Reports do not contain errors. This includes additional training and hiring of technical staff .

Resources

Considerable efforts and resources have been devoted to our registration as an SBSEF with the Commission, including the creation of a dedicated governance program to facilitate, track, and oversee implementation of the Commission’s laws, rules, and regulations for SBSEFs. In total, approximately $30,000,000 was dedicated to this effort prior to the Commission’s SBSEF rules going into effect and during the Coverage Period.

Material Non-Compliance Matters

As noted above, we identified instances where reporting of certain SBS executions in Daily Market Data Reports were inaccurate. Misreported fields included tenor and notional amount. We have initiated efforts to resolve this issue, including correction of the erroneous reports.

In addition, we identified instances where certain employees used non-approved channels for in-scope communications. We are resolving this by enhancing governance and oversight by senior management of communication channels and mediums available to staff, including the process to consider new communication channels and technology trends.

Certification

I, Jimmy Execution, do hereby certify as follows:

| 1. | I am the Chief Compliance Officer of XYZ SBSEF

| 2. | To the best of my knowledge and reasonable belief and under penalty of law, the information contained in this annual report pertaining to the period from January 1, 2033 through December 31, 20233 is accurate and complete in all material respects