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1110 Brickell Avenue 

Suite 430k-200 

Miami, FL 33131 

www.ledgerx.com

June 23, 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: CFTC Regulation 40.6 Certification – Liquidity Provider Program

LedgerX LLC Submission No. 21-16

Dear Mr. Kirkpatrick:

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

(the “Commission”), pursuant to Commission Regulation 40.6, that it is certifying its Bitcoin 

(“BTC”) and Ether (“ETH”) swaps and options liquidity provider program (the “Program”) for 

trading on LedgerX’s designated contract market (“DCM”) and swap execution facility (“SEF”). 

The Program will incentivize liquidity and volume in the LedgerX’s swaps and options contracts. 

The terms and conditions of the Program are set forth in Appendix A, which has redacted certain 

information pursuant to CFTC Regulations 40.8 and 145.9, and Appendix B, which has been filed 

pursuant to CFTC Regulations 40.8 and 145.9. The Program will become effective on or after 

July 8, 2021. 

Compliance with Core Principles

LedgerX has reviewed the core principles (“Core Principles”) set forth in the Commodity 

Exchange Act and has identified that the Program may most directly implicate the following Core 

Principles:

DCM Core Principle 2 -- Compliance with Rules; SEF Core Principle 2 – Compliance with Rules; 

DCM Core Principle 4 -- Prevention of Market Disruption; SEF Core Principle 4 – Prevention of 

Market Disruption

All trading on LedgerX, including any trading and related activity by participants under 

the Program, is subject to the LedgerX rules (the “Rulebook”) including Chapter 8 (Business 

Conduct and Trading Practices), which prohibits fraud, non-competitive trading, market 

manipulation and abusive and disruptive trade practices. Terms not defined in this submission 

have the meanings set forth in the Rulebook. Additionally, as with all trading on LedgerX, trading 

in the Program’s products will be subject to monitoring and surveillance by the Compliance 

Department, which has the authority to investigate and enforce LedgerX rules, as described in 

Chapter 9 (Discipline and Enforcement).
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DCM Core Principle 9 -- Execution of Transactions

The Program’s products are listed for trading on the LedgerX’s trading system, which 

provides for efficient, competitive, and open execution of transactions.

DCM Core Principle 12 -- Protection of Markets and Market Participants

Chapters 3 (Participants), 4 (Liquidity Providers) and 8 (Business Conduct and Trading 

Practices) of the Rulebook require all market participants, including those participating in the 

Program, to observe high standards of integrity, market conduct, commercial honor, fair dealing, 

and just and equitable principles of trade and prohibits, among other things, fraud, non-competitive 

trading, market manipulation, and abusive and disruptive trade practices. As with all contracts 

traded on LedgerX, trading in the Program’s products will be subject to monitoring and 

surveillance by the Compliance Department.

Certification

LedgerX certifies that the Program complies with the CEA and Commission Regulations 

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

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

is not aware of any or substantive opposing views to the Program.

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