QCEX

10055 Yamato Road, Suite 111

Delray Beach, FL 33498

Via E-mail 

June 16, 2022

Mr. Christopher J. Kirkpatrick, Esq. 

Secretary 

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Application for Designation as a Contract Market by QCX LLC 

Dear Mr. Kirkpatrick:

On behalf of QCX LLC (the “Exchange”), enclosed please find an application for the 

Exchange to be designated as a contract market pursuant to Section 5 of the Commodity 

Exchange Act, as amended (the “CEA”) and Part 38 of the regulations promulgated by the 

Commodity Futures Trading Commission (the “Commission”). In addition to this transmission 

letter and the petition for confidential treatment discussed further below, the application includes 

the following items (collectively with the letter and petition, the “Submission”): 

1. Form DCM Cover Sheet;

2. Exhibit A (ownership information);

3. Exhibit B (officer and director information); 

4. Exhibit C (governance fitness standards);

5. Exhibit D (organizational structure);

6. Exhibit E (personnel qualifications);

7. Exhibit F (staffing requirements);

8. Exhibit G (organizational documents); 

9. Exhibit H (legal proceedings);

10. Exhibit I (financial information);

11. Exhibit J (affiliates’ financials);

12. Exhibit K (dues and fees);

13. Exhibit L (core principles compliance);

14. Exhibit M (the rulebook);
15. Exhibit N (executed and executable agreements);

16. Exhibit O (compliance manual);

17. Exhibit P (disciplinary procedures);

18. Exhibit Q (matching algorithm and examples);

19. Exhibit R (rules prohibiting trade practice violations);

20. Exhibit S (maintenance of trading data);

21. Exhibit T (clearing arrangements);

22. Exhibit U (information subject to confidentiality request);

23. Exhibit V (technology questionnaire);

The Exchange is submitting simultaneously a petition for confidential treatment of the 

Submission (except for this transmission letter, the petition for confidential treatment, the Form 

DCM cover sheet, Exhibit G and Exhibit M thereof) pursuant to Section 8(a) of the CEA and 

145.9(d) of the Commission’s regulations, a copy of which is enclosed with this letter. Pursuant 

to Section 8(a) of the CEA and 145.9(d) of the Commission’s regulations, the Exchange requests 

confidential treatment of this Submission as well as all other enclosures, files, data and material 

submitted herewith on the grounds that disclosure of the Submission would reveal trade secrets 

or confidential commercial information of the Exchange. In addition to violating the Exchange’s 

proprietary rights, the disclosure of the Submission would grant competitors an unfair advantage 

or compromise the competitive advantages possessed by the Exchange. 

Please contact me or David J. Gilberg using the information below if you have any 

questions regarding this Submission. 

Matt Childers

QCX LLC

10055 Yamato Road, Suite 111

Delray Beach, FL 33498

Phone: 517-775-9538

Email: matt.childers@qcex.com

David J. Gilberg

Sullivan & Cromwell LLP

125 Broad Street 

New York, NY 10004

Phone: (212) 558-4680

Email: gilbergd@sullcrom.com

 
Sincerely,

 

 Matt Childers 

 Chief Compliance Officer

 QCX LLC 

(Enclosures)

cc: Nancy Markowitz

(Commodity Futures Trading Commission)

Aleko Stamoulis

(Commodity Futures Trading Commission)

Justin D. Hertzberg

(QCX LLC)

David J. Gilberg

Elianne Neuman Schiff

(Sullivan & Cromwell LLP)