Exhibit K – ABC, LLC

Attach as Exhibit K a description of the measures or procedures employed by registrant to provide for the security of any system which performs the functions of a clearing agency. Include a general description of any operational safeguards designed to prevent unauthorized access to the system (including unauthorized input or retrieval of information for which the primary record source is not hard copy). Identify any instances within the past year in which the described security measures or safeguards failed to prevent unauthorized access to the system and describe any measures taken to prevent a recurrence of any such incident. Describe also any measures used to verify the accuracy of information received or disseminated by the system.

ABC, LLC (ABC) employs numerous measures to provide for the security of its systems. ABC’s policies and procedures prevent unauthorized access to information at physical datacenters and in the virtual private cloud. This includes contracting with a third-party specialist to provide information security services to ABC, providing information security through multiple layers of security controls. ABC’s security measures, as well as the services provided by the third-party specialist, include safeguards to protect from the unauthorized information or retrieval of information through which the primary record source is not hard copy.  

During the past year, ABC experienced one incident in which its safeguards failed to prevent unauthorized access to its systems. In March 20XX, a group of hackers circumvented ABC’s safeguards and obtained confidential information relating to several dozen trades cleared by ABC.  

In the aftermath of this incident, ABC worked with newly hired security experts, as well as a newly contracted security consultant, to identify necessary updates to system security protocols. ABC has since successfully implemented those updates. 

ABC also works with a third-party information verification service provider to verify the accuracy of information received and disseminated by its systems.