1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://derivs.ftx.us/

1

August 4, 2022

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. 22-11

Dear Mr. Kirkpatrick:

LedgerX LLC (d/b/a FTX US Derivatives) (the “Company”) 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 current, integrated Rulebook for the purpose of 

creating a standalone Rulebook for the Company’s Swap Execution Facility (“SEF”). The 

attached amendments will become effective on August 18, 2022. 

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, are as follows.

Primarily, the Company has prepared a standalone Rulebook for its SEF by removing 

all definitions and provisions exclusively applicable to the Company’s other registration 

categories, removing definitions not used elsewhere in the Rulebook, removing rules that are 

currently inapplicable to the SEF (including provisions and definitions with respect to futures 

commission merchants (“FCMs”), in light of the absence of FCMs among the SEF’s current 

membership) and providing minor clarifications of the applicability of provisions to exchange 

functions. The removal of provisions not applicable to the SEF is consistent with SEF Core 

Principles 2, 4, 5, and 7 in that it makes clear to Participants the Rules applicable to the SEF 

and to Participants trading on the SEF. For the same reason, these changes are consistent with 

CFTC Regulations 37.9, 37.200, 37.201, 37.202, 37.205, 37.400, 37.404, 37.500, 37.502, and 

37.700.

Other minor corrections were made to the revised SEF Rulebook, including correcting 

various typographical errors, including in the descriptions of previously certified contract terms 

and to the definitions of terms used elsewhere. Contracts not currently eligible for trading 

through the SEF were also removed, consistent with SEF Core Principle 2 requiring the 

Company to establish and enforce rules pertaining to the terms and conditions of swaps traded 

through the facility, and CFTC Regulation 37.10.

The above-referenced chages are identical to the July 27, 2022 revisions which have 

been withdrawn, except that the definition of Chief Compliance Officer (“CCO”) has been 
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://derivs.ftx.us/

2

revised to reflect the proper titles applicable to the SEF, the Designated Contract Market, and 

the Derivatives Clearing Organization. This certification is being re-filed to coordinate with 

the other related Rulebook filings.

The changes and amendments to the Rulebook are reflected in a redlined copy 

designated as Appendix A. The final version of the revised SEF Rulebook is attached at 

Appendix B. 

The Company certifies that the above changes and amendments comply with the CEA 

and Commission Regulations thereunder. The Company additionally certifies that it has 

concurrently posted a copy of this submission letter and the attachments hereto on the Company 

website at https://derivs.ftx.us. The Company is not aware of any or substantive opposing 

views to the changes and amendments.

Please contact the undersigned at brian@ftx.us if you have any questions or you would 

otherwise like to discuss this further.

Sincerely,

Brian G. Mulherin

General Counsel, FTX US Derivatives