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      Eligibility Controls - Operations

      This page outlines client duties to ensure Eligibility checks can be properly run as well as operational procedures to monitor and remediate errors.


      Internal Processes (Set Up)

      1. Client Onboarding Procedures:

      • Verification of Internal Systems: Clients should verify that their internal systems are configured to capture and store all required reporting attributes accurately. This may require customization or configuration changes to align with regulatory reporting requirements.

      • Robust Counterparty Onboarding: KOR recommends implementing robust counterparty onboarding procedures to capture and submit all fields necessary for determining trade eligibility. This involves assessing reporting requirements mandated by regulatory authorities and identifying essential identification fields such as Legal Entity Identifiers (LEIs). Where a counterparty's answer can be verified with an online source (e.g., NFA for Swap Dealer list) cross-checks should be performed. 

      • Review of Missing Fields: If a client does not currently capture all submittable details for eligibility checks, it is recommended to review Droit workflows to determine the impact of missing fields. Work with compliance to assess the acceptability of reduced eligibility checks and establish processes to capture missing information for new and existing counterparties.

      2. Product Onboarding Procedures:

      • Implementation of Robust Procedures: Implement robust product onboarding procedures to streamline internal systems for trade reporting and ensure compliance with regulatory mandates. This proactive approach helps mitigate reporting errors and facilitates integration with external reporting platforms.

      • Review of Reporting Requirements: Conduct a thorough review of reporting requirements for each product or instrument traded. Identify specific data attributes required for trade reporting, such as product type, asset class, maturity date, currency, and regulatory-specific fields.

      3. Procedures for New Product Trading:

      • Preparation Before Trading: Put procedures in place before trading new products to ensure required attributes are recorded in the system for reporting purposes. Consider downstream impacts such as obtaining a Unique Product Identifier (UPI) before initiating trades.

      4. Single Stream Reporting:

      • Recommendation for Single Trade Message: KOR recommends submitting a single trade message to cover all applicable jurisdictions for trade reporting, rather than sending separate messages by jurisdiction. Utilize the power and controls built into the Droit engine to identify reportability and minimize points of failure.

      5. Determining Eligibility Checks:

      • Considerations for Eligibility Checks: Determine which eligibility checks to enroll for based on trading partners and reporting requirements. Consider whether you are concerned with where you need to report or if you want to know which regulators your counterparty may be reporting your data to.

      By following these procedures, clients can enhance their compliance efforts, minimize reporting errors, and ensure alignment with regulatory requirements. For further assistance or clarification on any of these procedures, please consult with your compliance or operations team.

      Automated ("API") checks to KOR when using Droit

      In order to review Eligibility checks over the API, you will first need to retrieve the list of eligibility checks. (Get a list of eligibility checks) Each eligibility check will return a status. 

      • REPORTABLE
      • NOT_REPORTABLE
      • REPORTABLE_WITH_ERRORS
      • NOT_REPORTABLE_WITH_ERRORS
      • GLOBAL_ERROR

      For those checks that return an error, you can use the ID to return the details including the specific error. (Get the details of an eligibility check) 

      The API response will provide the details of the error that will need to be remediated. Please see the API page for details of the response contents. 

      Manual checks to KOR when using Droit

      Eligibility Reports: You can leverage our reporting functionality to set up custom reports that can be generated on an ad hoc basis. 

      In the KOR RS UI, you can view Eligibility determinations at a record level. In the cases where there is an unexpected outcome, you can dive into the Logic Viewer to get a better understanding of what logic resulted in that outcome. In the case of errors, you will need to investigate the particular error and what led to it.