1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

www.ledgerx.com

June 13, 2021

VIA COMMISSION PORTAL

Christopher J. Kirkpatrick

Secretary, Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581 

Re: Commission Regulation 40.6(a) – Rule Certification

LedgerX LLC Submission No. 21-13

Dear Mr. Kirkpatrick:

LedgerX LLC (“LedgerX”) hereby notifies the Commodity Futures Trading Commission 

(the “Commission”), pursuant to Section 5c(c) of the Commodity Exchange Act (the “CEA”) and 

Commission Regulation 40.6(a), that it is certifying the attached amendments to its Business 

Continuity and Reconstitution Plan with attached appendices, including the Business Impact 

Analysis. The attached amendments will become effective on June 25, 2021. 

The following is a concise explanation and analysis of the changes and amendments, and 

their compliance with applicable provisions of the CEA, including the Core Principles and the 

Commission’s Regulations LedgerX has made the following revisions to its Business Continuity

and Reconstitution plan. These revisions are all consistent with SEF Core Principle 14, DCM 

Core Principle 20, and DCO Core Principle I, as well as CFTC Regulations 37.1401, 38.1051, 

and 39.18 requiring LedgerX to establish and maintain emergency procedures and a plan for 

disaster recovery. See CEA §§ 5h(f)(14), 5(d)(20), and 5b(c)(2)(I); see also 17 C.F.R. §§ 37.1401, 

38.1051, and 39.18.

1. Emergency Contact Information Updated (Exhibit A, p. ii). 

2. An erroneous reference to “Addendum” has been replaced with “Appendix.” (Exhibit A, 

p. ii).

3. The Document Control Version has been updated to reflect these changes, the effective 

date. (Exhibit A, p. iii).

4. The Document Control Storage Location has been updated to reflect its location as of the 

effective date of these changes. (Exhibit A, p. iii).

5. The overview has been edited to reflect that the plan applies to LedgerX in its capacity as 

a Designated Contract Market, as well as its other capacities. (Exhibit A, p. 1).

6. Appendix B to the manual has been eliminated since LedgerX has eliminated its physical 

office in New York. (Exhibit A, p. 1).

7. An updated diagram of the LedgerX Management Structure has been inserted. (Exhibit A, 

p. 7).
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

www.ledgerx.com

2

8. Reference to LedgerX’s former physical office in New York has been removed. 

(Exhibit A, p. 11, 14, 20)

9. Reference to Equinix was removed, since they ceased to be a service provider after 

LedgerX moved cryptocurrency custody to BitGo. (Exhibit A, p. 11, 20).

10. References to the proprietary HSM Wallet have been removed since LedgerX no longer 

uses an internal cryptocurrency custody solution, and instead has outsourced that process 

to BitGo. (Exhibit A, p. 13).

11. LedgerX updated the BitGo procedures for cryptocurrency key management, referring to 

a third-party vendor as holding the backup key, instead of having it held in a secured 

storage facility. (Exhibit A, p. 13).

12. The determination on who is to be consulted when determining how to reconstitute 

operations has been changed from the Chief Operations Officer to the Chief Technology 

Officer. (Exhibit A, p. 14).

13. In “Appendix A,” added new bank as a Key Contact since they currently hold a custodial 

account for LedgerX. (Exhibit A, p. 20).

14. In “Appendix A,” third-party cryptocurrency key manager has been added as a Key 

Contact, since it will hold one of the backup cryptocurrency keys for enhanced security. 

(Exhibit A, p. 20).

15. In “Appendix B,” Building Emergency Procedures intentionally omitted, since LedgerX 

has eliminated its physical office in New York. (Exhibit A, pp. 22-24).

16. Added “Appendix C,” referenced in the Plan, and cross-referenced BCDR Testing Plan 

separately stored in Box. (See Exhibit A, p. 25).

17. Added “Appendix D” to Plan document, and inserted Business Impact Analysis previously 

stored separately, indicating when last revised. (See Exhibit A, p. 26).

18. Added a title of “Third-Party Services” to a list of critical services and their operational 

impact if they were down for more or less than 4 hours. (See Exhibit A, p. 26).

19. Eliminated references to Equinix in “Third Party Services” since they ceased to be a service 

provider after LedgerX moved custody of all cryptocurrency to BitGo. (See Exhibit A, 

p. 26).

20. Eliminated reference to physical office network, since LedgerX employees now operate 

remotely without a physical New York location. (See Exhibit A, pp. 26-27).

21. Added third-party cryptocurrency key manager to Third-party services with description of 

operational impact if they were down for more or less than 4 hours. (See Exhibit A, p. 27).

The changes and amendments to the Business Continuity and Reconstitution Plan, 

including the Business Impact analysis, are reflected in a redlined copy designated as Exhibit A. 

The final version of the revised Business Continuity and Reconstitution Plan, including the 

Business Impact Analysis, is attached at Exhibit B.
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

www.ledgerx.com

3

LedgerX certifies that the changes and amendments comply with the CEA and Commission 

Regulations thereunder. LedgerX additionally certifies that it has concurrently posted a copy of 

this submission letter and the attachments hereto on LedgerX’s website at https://ledgerx.com/. 

LedgerX is not aware of any or substantive opposing views to the changes and amendments.

Please contact the undersigned at gc@ledgerx.com if you have any questions or you would 

otherwise like to discuss this further.

Sincerely,

Brian G. Mulherin

General Counsel, LedgerX LLC