152 Madison Avenue, 21st Fl.

New York, NY 10016

https://ledgerx.com

May 1, 2018

VIA SEF & DCO COMMISSION PORTALS

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. 18-12

Confidential Treatment Requested by LedgerX LLC as to Appendix C

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 changes and amendments to its 

Rulebook and Operations Manual. The attached changes and amendments will become effective 

no earlier than May 15, 2018. 

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, is attached hereto as Appendix A. A marked copy of the changes and amendments to 

the Rulebook is designated as Appendix B. A marked copy of the changes and amendments to the

Operations Manual is designated as Appendix C. 

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 non-confidential 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 (917) 935-6727 or alex@ledgerx.com if you have any questions 

or you would otherwise like to discuss this further.

Sincerely,

Alex C. Levine

Chief Compliance Officer & Head of Legal

LedgerX LLC
Appendix A

Rule/Section Explanations Core Principle or other CEA 

Provision, Commission Regulation 

and/or Commission Staff Letter

Various Sections 

and Rules

Throughout

Rulebook and 

Operations 

Manual:

--See Rulebook

Redline at pp. 59, 

61, 63-64, 112, 

115, 118, and 121.

--Operations 

Manual Redline at 

pp. 2, 27-30, and 

46.

LedgerX is implementing 24-

hour trading on its exchange for 

approved products. As a result, 

various rules and sections in the 

Rulebook and Operations Manual 

have been modified to reflect 

these expanded trading hours. 

Additionally, instances where 

order cancelations or other 

actions were based upon the daily 

close of the exchange have been 

modified to comport with 

operational practices that will 

exist once 24-hour trading goes 

into effect.

DCO Core Principles C, D, & I and 

SEF Core Principles 2, 4, & 14 – This 

change enhances fair and open access 

to the LedgerX exchange by allowing 

authorized participants to trade 

approved products and have such 

trades processed and cleared any time 

on a 24-hour basis, which aligns with 

the fact that bitcoin can be transferred 

or utilized at any time on the 

blockchain. LedgerX has constructed 

appropriate technological and 

operational infrastructure to ensure 

proper risk management and systems 

safeguards are in place to institute 

these expanded trading hours.
Appendix B

[SEE RULEBOOK REDLINE]
Appendix C

[SEE OPERATIONS MANUAL REDLINE – CONFIDENTIAL TREATMENT REQUESTED]