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Exhibit O – ABC, LLC

Attach as a description of any specifications, qualifications, or other criteria which limit, are interpreted to limit, or have the effect of limiting access to, or use of, any clearing agency service furnished by the registrant and state the reasons for imposing such specifications, qualifications, or other criteria.

ABC, LLC (ABC) limits membership to entities that fulfill certain criteria. First, the entity must be able to fulfill anticipated commitments to ABC, and must meet the operational requirements of ABC with promptness and accuracy. Second, the entity must have sufficient financial ability to make all anticipated fee payments required to be made to ABC. Third, if the entity is a regulated entity, the entity must represent to ABC that it is in compliance with the capital requirements imposed by its examining authority or regulator. Finally, the entity must not have been convicted within the past ten years of any criminal offense, and must not have been responsible for making material misstatements or fraudulent acts in violation of the securities laws. 

ABC imposes these criteria to ensure that every member is sufficiently able and situated to fulfill its obligations to ABC and its membership base.