DCM Exhibit L

Attached as Exhibit L, a narrative and any other form of documentation that may be provided under other Exhibits herein, that describes 

the manner in which the Applicant is able to comply with each core principle. Such documentation must include a regulatory compliance 

chart setting forth each core principle and providing citations to the Applicant’s relevant rules, policies, and procedures that address each 

core principle. To the extent that the application raises issues that are novel or for which compliance with a core principle is not self- evident, 

include an explanation of how that item and the application satisfy the core principles.

Unless otherwise stated, defined terms used herein shall have the meaning assigned to them in the Railbird Rulebook (Exhibit M).

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

Core Principle 1 – Designation as a Contract Market

(a) In general. To be designated, 

and maintain a designation, as 

a contract market, a board of 

trade shall comply with: 

(1) Any core principle 

described in section 5(d) 

of the Act, and 

(2) Any requirement that the 

Commission may impose 

by rule or regulation 

pursuant to section 8a(5) 

of the Act. 

(b) Reasonable discretion of the 

contract market. Unless 

otherwise determined by the 

Commission by rule or 

regulation, a board of trade 

described in paragraph (a) of 

this section shall have 

reasonable discretion in 

establishing the manner in 

which the board of trade 

Railbird Exchange LLC (“Railbird” or the “Exchange”) is 

applying for registration as a designated contract market 

(“DCM”) by submitting Form DCM (the “Railbird 

Application”). Once registered, Railbird will comply with the 

DCM Core Principles. As demonstrated in this Application, 

Railbird has drafted its Rules, Compliance Manual, Business 

Continuity Plan, Enterprise Risk Management Plan and 

Operations Manual, and has designed Railbird’s operations 

to be compliant with the DCM Core Principles and the 

Commodity Exchange Act, as amended (“CEA”) and other 

applicable Commodity Futures Trading Commission 

(“CFTC” or “Commission”) regulations promulgated 

thereunder.

Railbird Application, including all 

attachments and Exhibits.
2

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

complies with the core 

principles described in this 

subsection.

Core Principle 2 – Compliance with Rules

(a) In general. The board of 

trade shall establish, monitor, 

and enforce compliance with 

the rules of the contract 

market, including: 

(1) Access requirements; 

(2) The terms and conditions 

of any contracts to be 

traded on the contract 

market; and 

(3) Rules prohibiting abusive 

trade practices on the 

contract market.

(b) Capacity of contract market. 

The board of trade shall have 

the capacity to detect, 

investigate, and apply 

appropriate sanctions to any 

person that violates any rule 

of the contract market.

(c) Requirement of rules. The 

rules of the contract market 

shall provide the board of 

trade with the ability and 

authority to obtain any 

necessary information to 

perform any function 

described in this section, 

Railbird has established rules and procedures reasonably 

designed to ensure compliance with section 5h of the CEA 

and the CFTC regulations. Railbird fulfills its compliance 

with the CEA, CFTC regulations, and Railbird Rules through 

oversight by its Regulatory Oversight Committee ("ROC") 

and its Chief Regulatory Officer ("CRO"). 

The Railbird Rules include rules for access requirements and 

impartial access, and rules prohibiting fraudulent and abusive 

trading practices. Rules 3.1 and 3.2 set forth Member 

eligibility requirements and requires Members to meet any 

other criteria upon request by the Exchange and provide the 

Exchange with any other information the Exchange may 

request regarding the Member. Rule 5.13 prohibits abusive 

trading practices.

The Compliance Department conducts real-time surveillance, 

trade practice surveillance, and market surveillance, as 

described in the Railbird Compliance Manual. The 

Compliance Department also oversees investigations. 

The Compliance Department's investigations and disciplinary 

procedures are governed by Chapter 9 of the Rulebook. 

Pursuant to Rule 3.2, Members agree to assist Railbird in 

complying with Railbird’s legal and regulatory obligations, 

cooperate with the Exchange, the CFTC and a regulatory 

agency with jurisdiction over Railbird in any inquiry, 

investigation, audit, examination or proceeding.

Exhibit M – Railbird Rulebook

Exhibit O – Railbird Compliance Manual

Exhibit R – Trade Practice Violations
3

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

including the capacity to 

carry out such international 

information-sharing 

agreements, as the 

Commission may require.

Railbird has not entered into international informationsharing agreements but Railbird’s Rules foresee that doing so 

may be necessary in the future. Rule 2.14 contemplates 

Railbird entering into any information-sharing agreements if 

Railbird considers such arrangement to be in furtherance of 

the Company’s purpose or duties under its Rules or 

Applicable Law. 

Additionally, Rule 3.2 requires Members to allow Railbird to 

provide all information that Railbird has about a Member, 

including the Member’s trading activity, to the CFTC or any 

other regulatory agency, law enforcement authority, or 

judicial tribunal, including (as may be required by 

information sharing agreements or other arrangements or 

procedures or other contractual, regulatory, or legal 

provisions) foreign regulatory or self-regulatory bodies, law 

enforcement authorities, or judicial tribunals. 

The Compliance Manual sets forth internal procedures 

regarding asking Members for additional information and 

periodic monitoring of Members where additional 

information could be necessary.

Core Principle 3 – Contracts Not Readily Susceptible to Manipulation

The board of trade shall list on the 

contract market only contracts that 

are not readily susceptible to 

manipulation.

Railbird shall only permit trading in contracts that are not 

readily susceptible to manipulation. All Railbird contracts 

shall be cleared through LedgerX.

Exhibit M – Railbird Rulebook 

Exhibit O – Railbird Compliance Manual
4

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

Core Principle 4 – Prevention of Market Disruption

The board of trade shall have the 

capacity and responsibility to prevent 

manipulation, price distortion, and 

disruptions of the delivery or cashsettlement process through market 

surveillance, compliance, and 

enforcement practices and 

procedures, including:

(a) Methods for conducting realtime monitoring of trading; 

and

(b) Comprehensive and accurate 

trade reconstructions.

The Railbird Compliance Department is responsible for 

conducting trade practice surveillance. Trade practice 

surveillance includes reviewing bids, offers, trades and any 

other information submitted via the trading platform on an 

ongoing basis to determine if there are any potential 

violations of the Railbird Rules.

Railbird has licensed Validus, an automated market 

surveillance software, that enables the Compliance 

Department to perform trade practice and market surveillance 

functions and to monitor settlement and physical delivery. 

The Compliance Department uses Validus to effectively and 

efficiently surveil the Railbird platform and its Members and 

generate automated exception alerts. A comprehensive 

description of Validus’ tools and functions is included in the 

Compliance Manual.

Validus captures all of the data elements to recreate the audit 

trail of every actionable message on Railbird.

Exhibit M – Railbird Rulebook

Exhibit O – Railbird Compliance Manual
5

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

Core Principle 5 – Position Limits or Accountability

To reduce the potential threat of 

market manipulation or congestion 

(especially during trading in the 

delivery month), the board of trade 

shall adopt for each contract of the 

board of trade, as is necessary and 

appropriate, position limitations or 

position accountability for 

speculators. For any contract that is 

subject to a position limitation 

established by the Commission, 

pursuant to section 4a(a), the board 

of trade shall set the position 

limitation of the board of trade at a 

level not higher than the position 

limitation established by the 

Commission.

Chapter 5 of the Rulebook sets forth rules regarding position 

limits, position accountability levels, and aggregation 

requirements. Railbird imposes position limits or position 

accountability levels, as is necessary and appropriate, for the 

contracts that Railbird offers. The Compliance Manual also 

references internal controls that Railbird utilizes to monitor 

for a potential breach of position limits. 

Exhibit M – Railbird Rulebook

Exhibit O – Railbird Compliance Manual

Core Principle 6 — Emergency Authority

The board of trade, in consultation or 

cooperation with the Commission, 

shall adopt rules to provide for the 

exercise of emergency authority, as is 

necessary and appropriate, including 

the authority:

(a) To liquidate or transfer open 

positions in any contract; 

(b) To suspend or curtail trading 

in any contract; and 

(c) To require market participants 

in any contract to meet 

special margin requirements

Rule 1 of the Exchange Rulebook defines the term 

“Emergency,” and Rule 2.8 sets forth the procedures Railbird 

will follow in the event of an Emergency to adopt emergency 

Rules or take emergency action. 

Railbird’s Compliance Manual sets forth examples of actions

that Railbird may take in the event of an emergency or in 

response to disruptive activity.

Exhibit M – Railbird Rulebook

Exhibit O – Railbird Compliance Manual
6

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

Core Principle 7 —Availability of General Information

The board of trade shall make 

available to market authorities, 

market participants, and the public 

accurate information concerning:

(a) The terms and conditions of 

the contracts of the contract 

market; and

(b)

(1) The rules, regulations 

and mechanisms for 

executing transactions 

on or through the 

facilities of the 

contract market, and

(2) The rules and 

specifications 

describing the 

operation of the 

contract market's:

(i) Electronic 

matching 

platform, or

(ii) Trade 

execution 

facility.

Rule 2.16 sets forth the information that Railbird shall make 

public. Chapter 5 of Railbird’s Rulebook sets forth the 

procedures for executing transactions on the Platform. 

Chapter 13 of Railbird’s Rulebook sets forth the terms of 

Contracts traded on Railbird, and additional information with 

respect to each Contract will be available on Railbird’s 

Website. 

Exhibit M –Railbird Rulebook

Exhibit O – Railbird Compliance Manual

Railbird Website
7

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

Core Principle 8 — Daily Publication of Trading Information

The board of trade shall make public 

daily information on settlement 

prices, volume, open interest, and 

opening and closing ranges for 

actively traded contracts on the 

contract market.

Rule 2.16(b) sets forth that Railbird shall make public on a 

daily basis information on settlement prices, volume, open 

interest and opening and closing ranges for actively traded 

contracts.

Railbird Website

Exhibit M – Railbird Rulebook

Exhibit O – Railbird Compliance Manual

Core Principle 9 — Execution of Transactions

The board of trade shall provide a 

competitive, open, and efficient 

market and mechanism for executing 

transactions that protects the price 

discovery process of trading in the 

centralized market of the board of 

trade. The rules of the board of trade 

may authorize, for bona fide business 

purposes:

(a) Transfer trades or office 

trades;

(b) An exchange of:

(1) Futures in connection 

with a cash commodity 

transaction;

(2) Futures for cash 

commodities; or

(3) Futures for swaps; or

(c) A futures commission 

merchant, acting as principal 

or agent, to enter into or 

Chapter 5 of the Rulebook and Chapter 6 of the Compliance 

Manual sets forth the method for trading Exchange Contracts 

and the mechanism by which transactions are executed on the 

Platform. At this time, Railbird’s rules do not permit the 

execution of bilaterally negotiated exchange of futures for 

related position (EFRP) transactions or block trades. 

Rule 5.13(f) of the Rulebook provides that the transfers of 

open contracts on the books of the Clearinghouse to another 

account on the books of the Clearinghouse need not be made 

competitively where no change in beneficial ownership is 

involved in the transfer.

Exhibit M – Railbird Rulebook

Exhibit O – Railbird Compliance Manual
8

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

confirm the execution of a 

contract for the purchase or 

sale of a commodity for 

future delivery if the contract 

is reported, recorded, or 

cleared in accordance with 

the rules of the contract 

market or a derivatives 

clearing organization.

Core Principle 10 — Trade Information

The board of trade shall maintain 

rules and procedures to provide for 

the recording and safe storage of all 

identifying trade information in a 

manner that enables the contract 

market to use the information:

(a) To assist in the prevention of 

customer and market abuses; 

and

(b) To provide evidence of any 

violations of the rules of the 

contract market.

Railbird Rule 2.13 sets forth its recordkeeping policy, which 

requires Railbird to retain all books and records required by 

the CEA and CFTC Regulations in a form and manner 

acceptable to the CFTC and in compliance with CFTC 

Regulation 1.31. 

Further, all Transactions executed on the Platform by a 

Member will be associated with a user identification unique 

to that Member. 

Railbird’s Compliance Manual contains additional discussion 

of the Exchange’s recordkeeping requirements, including 

Railbird’s internal policies for collecting trade information 

for the purposes of identifying market abuses or violations of 

Rules. 

Railbird will utilize Validus to conduct trade and market 

surveillance. Validus provides the Compliance Department 

with the necessary context to analyze trade practice 

behaviors and trends. 

Exhibit M – Railbird Rulebook

Exhibit V (Supporting Documents) -

Railbird Logging and Monitoring Policy

Exhibit O – Railbird Compliance Manual

Exhibit O (Supporting Documents) –

Railbird Record Retention Policy

In addition, because the Platform is entirely electronic, 

Railbird’s electronic history database includes a history of all 
9

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

indications of interests, requests for quotes, orders and trades 

entered into the trading system or Platform, including all 

order modifications and cancellations. The audit trail 

captured by Railbird is sufficient to reconstruct all 

indications of interest, requests for quotes, orders, and trades 

within a reasonable period of time and to provide evidence of 

any violations of Railbird’s rules.

Railbird’s internal policies for recording and safe storage of 

trade information are in the in the Railbird Record Retention 

Policy. Railbird’s Logging and Monitoring Policy sets forth 

a baseline of specific requirements that the Exchange’s 

information systems must meet in order to generate 

appropriate audit logs and integrate with an enterprise’s log 

management function.

Core Principle 11 — Financial Integrity of Transactions

The board of trade shall establish and 

enforce:

(a) Rules and procedures for 

ensuring the financial 

integrity of transactions 

entered into on or through the 

facilities of the contract 

market (including the 

clearance and settlement of 

the transactions with a 

derivatives clearing 

organization); and

(b) Rules to ensure:

The Exchange has signed a Clearing Services Agreement 

with LedgerX to provide third-party clearing services, and all 

Contracts offered by Railbird will be cleared through 

LedgerX. LedgerX is a fully-collateralized DCO. All 

Member positions are fully cash collateralized, and no 

Member can take positions that would lead to an exposure 

that exceeds the funds deposited in the Member Account.

Each Member must be in good standing and in compliance 

with the Member eligibility standards set forth in Chapter 3. 

In addition the Exchange will perform AML/KYC screening 

of its Members.

The Exchange has contracted with third party service 

provider Eventus to perform surveillance of its Members.

Exhibit M – Railbird Rulebook

Exhibit O – Railbird Compliance Manual 

Exhibit T (Supporting Documents) –

LedgerX Clearing Services Agreement; 

Exhibit V – Section ERM
10

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

(1) The financial integrity of 

any:

(i) Futures 

commission 

merchant, and

(i) Introducing 

broker; and

(2) The protection of 

customer funds.

Core Principle 12: Protection of Markets and Market Participants

The board of trade shall establish and 

enforce rules:

(a) To protect markets and 

market participants from 

abusive practices committed 

by any party, including 

abusive practices committed 

by a party acting as an agent 

for a participant; and

(b) To promote fair and equitable 

trading on the contract 

market.

Chapter 5 of Railbird’s Rulebook sets forth the method for 

trading on the Platform. Chapter 9 of the Rulebook details 

the disciplinary process for enforcing Railbird’s Rules. 

Railbird’s Compliance Manual sets forth the real-time market 

supervision and surveillance mechanisms to identify 

potential market abuses, and describes the actions Railbird 

may take in response to disruptive activity. 

Exhibit M – Railbird Rulebook 

Exhibit O – Railbird Compliance Manual

Core Principle 13: Disciplinary Procedures

The board of trade shall establish and 

enforce disciplinary procedures that 

authorize the board of trade to 

discipline, suspend, or expel 

members or market participants that 

violate the rules of the board of trade, 

or similar methods for performing the 

Chapter 9 of Railbird’s Rulebook describes Railbird’s

disciplinary procedures and the composition of the 

Disciplinary Panel. Additional internal policies are located 

in the Railbird Compliance Manual. 

Exhibit M – Railbird Rulebook 

Exhibit O – Railbird Compliance Manual 
11

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

same functions, including delegation 

of the functions to third parties.

Core Principle 14: Dispute Resolution

The board of trade shall establish and 

enforce rules regarding, and provide 

facilities for alternative dispute 

resolution as appropriate for market

participants and any market 

intermediaries.

Chapter 10 of the Rulebook sets forth rules related to 

alternative dispute resolution. 

Exhibit M – Railbird Rulebook 

Core Principle 15: Governance Fitness Standards

The board of trade shall establish and 

enforce appropriate fitness standards 

for directors, members of any 

disciplinary committee, members of 

the contract market, and any other 

person with direct access to the 

facility (including any party affiliated 

with any person described in this 

paragraph).

Rules 2.2 and 2.4 set forth eligibility and fitness standards for 

directors. Rule 2.6 sets forth the eligibility and fitness 

standards for the ROC. Rule 9.2 set forth eligibility and 

fitness standards for members of the Disciplinary Panel. 

Rule 3.1 sets forth the eligibility and fitness standards for 

Members of the Exchange. 

Exhibit M – Railbird Rulebook 

Core Principle 16 – Conflicts of Interest

The board of trade shall establish and 

enforce rules:

(a) To minimize conflicts of 

interest in the decisionmaking process of the 

contract market; and

(b) To establish a process for 

resolving conflicts of interest 

Rule 2.9 addresses preventing conflicts of interest with 

respect to Board members or members of any disciplinary or 

oversight committee or subcommittee, and adopts 

Commission Regulation 1.69 as Rule 12.3 of the Railbird 

Rulebook. 

In addition, Rule 9.3 prohibits members of the Disciplinary 

Panel from operating under the direction or control of any 

person or persons with trading privileges on the Platform and 

may not include persons whose interests conflict with their 

Exhibit M – Railbird Rulebook

Exhibit O – Railbird Compliance Manual

Exhibit O (Supporting Documents) –

Railbird Conflicts of Interest, Employee 

Trading and Outside Business Interests 

Policy and Railbird Travel and 

Entertainment Policy
12

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

described in paragraph (a) of 

this section.

enforcement duties. Rule 10.4 prohibits arbitrators that make 

up the Board of Arbitration in the dispute resolution process 

from serving if the arbitrator has a financial, personal, or 

prejudicial interest or concern in the dispute before such 

Board of Arbitration.

Furthermore, the Railbird Compliance Manual contains 

additional internal policies and procedures for minimizing 

and conflicts of interest. The Railbird Conflicts of Interest, 

Employee Trading and Outside Business Interests Policy and 

the Railbird Travel and Entertainment Policy contain 

additional detailed conflict of interest requirements for 

Railbird employees.

Core Principle 17 – Composition of Governing Boards of Contract Markets

The governance arrangements of the 

board of trade shall be designed to 

permit consideration of the views of 

market participants.

Chapter 2 of Railbird’s Rulebook sets forth the Exchange’s 

governance arrangements. Railbird’s Board Committee 

Charters also set forth the Exchange’s governance 

arrangements with respect to Board and committee 

membership requirements.

Exhibit M – Railbird Rulebook 

Exhibit C – Board Fitness Standards, 

Board Committee Charters

Core Principle 18 – Recordkeeping

The board of trade shall maintain 

records of all activities relating to the 

business of the contract market:

(a) In a form and manner that is 

acceptable to the 

Commission; and

(b) For a period of at least 5 

years.

Railbird Rule 2.13 sets forth its recordkeeping policy, which 

requires Railbird to retain all books and records required by 

the CEA and CFTC Regulations in a form and manner 

acceptable to the CFTC and in compliance with CFTC 

Regulation 1.31. 

Railbird’s Compliance Manual contains additional discussion 

of the Exchange’s recordkeeping requirements, including 

Railbird’s internal policies for collecting trade information 

for the purposes of identifying market abuses or violations of 

Rules. 

Exhibit M – Railbird Rulebook 

Exhibit O – Railbird Compliance Manual 

Exhibit O (Supporting Documents) –

Railbird Record Retention Policy and 

Railbird Source Code Repository Policy
13

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

Core Principle 19 — Antitrust Considerations

Unless necessary or appropriate to 

achieve the purposes of this Act, the 

board of trade shall not:

(a) Adopt any rule or taking any 

action that results in any 

unreasonable restraint of 

trade; or

(b) Impose any material 

anticompetitive burden on 

trading on the contract 

market.

Railbird Rule 3.1 establishes Member eligibility criteria. 

Pursuant to Rule 3.1(h), Railbird will apply Member access 

criteria in a fair and nondiscriminatory manner that is not 

anti-competitive. 

Rule 5.13(u) states that if a Member has access to material 

non-public information that is the subject of an Underlying of 

any Contract or that has the ability to exert any influence on 

the subject of an Underlying of any Contract, that Member is 

prohibited from attempting to enter into any trade or entering 

into any trade. Further, Rule 5.13(v) states that if a Member 

is a decision maker or has any influence on the outcome of 

the Underlying of any Contract, that Member is prohibited 

from attempting to enter into any trade or entering into any 

trade.

Railbird imposes fees that are equal across classes, and such 

fees are designed to be nondiscriminatory. 

Pursuant to Rule 2.16, Railbird makes public certain 

information, including its Rules, Contract specifications, and 

information on settlement prices, volume, open interest, and 

opening and closing ranges for actively traded Contracts.

Furthermore, the Exchange Rulebook provides for a ROC

(Rule 2.6), sets forth prohibited transactions (Rule 5.13), and 

describes the investigative and disciplinary process of the 

Exchange (Ch. 9). The Compliance Manual (Ex. O) sets forth 

additional antitrust policies, describes disciplinary 

procedures, and additional trade practice review and 

investigation procedures.

Exhibit M – Exchange Rulebook

Exhibit O – Railbird Compliance Manual

Exhibit Q – Exchange Matching Engine
14

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

The Exchange matching engine (Ex. Q) provides equal, 

nondiscriminatory access to trading on the Exchange.

Core Principle 20 —System Safeguards

Each designated contract market 

shall:

(a) Establish and maintain a 

program of risk analysis and 

oversight to identify and 

minimize sources of 

operational risk, through the 

development of appropriate 

controls and procedures, and 

the development of automated 

systems, that are reliable, 

secure, and have adequate 

scalable capacity;

(b) Establish and maintain 

emergency procedures, 

backup facilities, and a plan 

for disaster recovery that 

allow for the timely recovery 

and resumption of operations 

and the fulfillment of the 

responsibilities and 

obligations of the board of 

trade; and

(c) Periodically conduct tests to 

verify that backup resources 

are sufficient to ensure 

Railbird has developed a program of risk oversight designed 

to identify a wide range of risks, including preventing system 

outages and cyber-attacks. As part of this program, Railbird

maintains an Enterprise Risk Management Plan. Railbird also 

maintains a Business Continuity Plan that would be activated 

in the event of an Emergency or other circumstances 

warranting activation of such plan. Railbird conducts 

periodic audits, internal testing, and external testing to verify 

the integrity of its technology systems.

Exhibit V – Technology Questionnaire

and Supporting Documents

Exhibit O – Railbird Compliance Manual
15

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

continued order processing 

and trade matching, 

transmission of matched 

orders to a designated 

clearing organization for 

clearing, price reporting, 

market surveillance, and 

maintenance of a 

comprehensive and accurate 

audit trail.

Core Principle 21 — Financial Resources

(a) In General. The board of 

trade shall have adequate 

financial, operational, and 

managerial resources to 

discharge each responsibility 

of the board of trade.

(b) Determination of adequacy. 

The financial resources of the 

board of trade shall be 

considered to be adequate if 

the value of the financial 

resources exceeds the total 

amount that would enable the 

contract market to cover the 

operating costs of the contract 

market for a 1-year period, as 

calculated on a rolling basis.

Railbird’s Board and management team will monitor the 

Exchange’s financial, operational, and managerial resources 

to ensure they are adequate to discharge the responsibility of 

Railbird as a DCM. Additionally, Railbird will engage with 

a public accounting firm to audit Railbird’s financial 

statements.

Exhibit I – Financial Resources

Exhibit O – Compliance Manual
16

Core Principle or Other Requirement Railbird Exchange LLC Rule, Policy or Procedure Relevant Exhibit(s)

Core Principle 22 — Diversity of Board of Directors

The board of trade, if a publicly 

traded company, shall endeavor to 

recruit individuals to serve on the 

board of directors and the other 

decision-making bodies (as 

determined by the Commission) of 

the board of trade from among, and 

to have the composition of the bodies 

reflect, a broad and culturally diverse 

pool of qualified candidates.

N/A N/A

Core Principle 23 — Securities and Exchange Commission

The board of trade shall keep any 

such records relating to swaps 

defined in section 1a(47)(A)(v) of the 

Act open to inspection and 

examination by the Securities and 

Exchange Commission.

N/A N/A