FOIA CONFIDENTIAL TREATMENT REQUESTED BY LEDGERX LLC

Appendix A

Below is a description of revisions to the LedgerX Participant Agreement. This chart is intended to ease Participants’ review of 

the changes made to the Participant Agreement. Since the changes may impact LedgerX’s operations as a DCM, SEF and DCO, we are

explaining how the changes are consistent with the Core Principles. When appropriate, a concise summary of how the changes may 

impact LedgerX’s business operations has also been included in the chart. 

Unless otherwise indicated herein, all section references in the chart refer to the revised Participant Agreement. To further 

enhance the Participants’ review, the chart is organized into sub-categories to group together similar updates. In addition, references are 

made to existing provisions in LedgerX’s Rulebook. 

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DICTION / FORMATTING CHANGES

1. The title of the Agreement has been 

changed from “Participant Agreement” to 

“LedgerX Participant Agreement.”

This change does not directly implicate the Core Principles. The change is not expected to 

materially impact LedgerX’s business operations and is intended to enhance readability for 

the Participants.

2. A reference to LedgerX’s operation as a 

DCM has been added to Section I, Services.

This change does not directly implicate the Core Principles. The change is not expected to 

materially impact LedgerX’s business operations and is intended to highlight LedgerX’s 

role as a DCM for Participants.

3. Various diction and consistency changes 

improve clarity, such as: (a) references to

“the Participant” changed to “Participant”; 

(b) references to “applicant” changed to 

“Participant”; (c) references to “Authorized 

Users” changed to Authorized Participants, 

as defined in the LedgerX Rulebook, 

including Authorized Users; (d) certain 

instances of “it” have been replaced with 

“Participant”; (e) reference to “state” 

changed to “place” in Section V, Item B; 

(f) added “bank” to the list of entities in 

Section VI, Item K to match the list of 

entities in Section VI, Item L; (g) reference 

to “Paragraphs” changed to “Sections” in 

Section XV, Termination.

These changes do not directly implicate the Core Principles. The changes are not expected 

to materially impact LedgerX’s business operations and are intended to enhance readability 

for Participants.
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4. Various formatting changes throughout the 

Participant Agreement to improve clarity:

a. Changed bullet points to an 

alphabetical list.

b. Added “and” to the end of the 

penultimate list items.

c. Moved the explanation of 

capitalized terms under the previous 

Services section to its own section, 

Section II, Definitions.

d. Moved Participant’s warranty that 

Participant meets the eligibility 

requirements set forth in Rule 3.2 of 

the LedgerX Rulebook under the 

previous Governing Law section to 

its own section, Section III, 

Participant Eligibility.

e. Moved (and rephrased) the bulleted 

provision regarding Participant’s 

obligation to update information 

under the previous Governing Law 

section to Section VI, Item X.

These changes do not directly implicate the Core Principles. The changes are not expected 

to materially impact LedgerX’s business operations and are intended to enhance readability 

for Participants.

5. Certain redundant provisions were removed:

a. The provision regarding 

Participant’s representation that the 

information and statements 

contained in the Participant 

Agreement are true, complete and 

accurate under the previous 

Governing Law section was 

removed because a similar provision 

existed under the previous Section V, 

Participant Acknowledgments (now 

Section VI, Item S).

b. The bulleted provision regarding 

These changes do not directly implicate the Core Principles. The changes are not expected 

to materially impact LedgerX’s business operations and are intended to enhance readability 

for Participants.
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Participant’s agreement to abide by 

the Rulebook under the previous 

Governing Law section was 

removed because a similar provision 

existed under the previous Section 

II, Participant Obligations and 

Consent to Jurisdiction of LedgerX

(now Section IV).

c. The bulleted provision regarding 

Participant’s authorization to allow 

certain organizations to furnish 

information to LedgerX under the 

previous Governing Law section 

was removed because a similar 

provision existed under the previous 

Section V, Participant 

Acknowledgments (now Section VI, 

Item K).

d. The bulleted provision regarding 

Participant’s authorization to allow 

certain organizations to receive 

information from LedgerX under the 

previous Governing Law section 

was removed because a similar 

provision existed under the previous 

Section V, Participant 

Acknowledgments (now Section VI, 

Item L).

CLARIFYING EXISTING PROVISIONS

6. Clarified that fees and charges can be 

revised in Section IV, Participant 

Obligations and Consent to Jurisdiction of 

LedgerX.

This is consistent with DCM Core Principle 7 requiring LedgerX to make available to 

market participants accurate information concerning the execution of transactions. See CEA 

§ 5(d)(7); see also 17 C.F.R. §§ 38.400-401.
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This is also consistent with SEF Core Principle 2 requiring LedgerX to establish, monitor, 

and enforce compliance with its rules. See CEA §5h(f)(2); see also 17 C.F.R. § 37.202. 

This is also consistent with DCO Core Principle L requiring LedgerX to provide market 

participants sufficient information for them to identify and evaluate accurately the costs 

associated with using the services of the DCO. See CEA § 5b(c)(2)(L)(i), (iii)(II); see also 

17 CFR § 39.21(a), (c)(2).

Furthermore, this change is consistent with existing Rule 3.6 - Dues, Fees and Expenses 

Payable by Participants in LedgerX’s Rulebook. Accordingly, the change is not expected to 

materially impact LedgerX’s business operations and is intended to enhance potential 

Participants understanding of LedgerX’s business and fee structure.

7. Defined “www.ledgerx.com” as the 

LedgerX website in Section IV, Participant 

Obligations and Consent to Jurisdiction of 

LedgerX.

This change does not directly implicate the Core Principles. The change is not expected to 

materially impact LedgerX’s business operations and is intended to enhance readability for 

the Participants.

8. Clarified that Participants must also provide 

to LedgerX information about itself, in 

addition to its Authorized Representatives, 

if requested in Section IV, Participant 

Obligations and Consent to Jurisdiction of 

LedgerX.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

Furthermore, this change is consistent with existing Rule 2.15 - Information Sharing 

Arrangements in LedgerX’s Rulebook. Accordingly, the change is not expected to 

materially impact LedgerX’s business operations and is intended to enhance potential 

Participants understanding of LedgerX’s business and requirement to share certain 

information with LedgerX.

9. Clarified that fees and charges owed by a 

Participant, including legal fees and costs,

can be deducted from a Participant’s 

Accounts in Section VI, Item N.

This is consistent with DCM Core Principle 14 requiring LedgerX to establish and enforce 

rules regarding dispute resolution. See CEA § 5(d)(14); see also 17 C.F.R. § 38.750.

This is also consistent with SEF Core Principle 2 requiring LedgerX to establish, monitor, 

and enforce compliance with its rules. See CEA §5h(f)(2).
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Furthermore, this change is consistent with existing Rule 3.6(D) - Dues, Fees and Expenses 

Payable by Participants in LedgerX’s Rulebook. Accordingly, the change is not expected to 

materially impact LedgerX’s business operations and is intended to enhance potential 

Participants understanding of LedgerX’s business.

10. Replaced the reference to a “Participant 

Security Policy” with the general term “any 

security policies” in Section VI, Item T as 

LedgerX currently does not, and may not, 

have a specific Participant Security Policy.

This change does not directly implicate the Core Principles. The change is not expected to 

materially impact LedgerX’s business operations and is intended to enhance readability for 

the Participants.

11. Clarified that the Participant Agreement 

will also be construed in accordance with 

the laws of New York in Section XXI, 

Governing Law.

This is consistent with DCM Core Principle 14 requiring LedgerX to establish and enforce 

rules regarding dispute resolution. See CEA § 5(d)(14); see also 17 C.F.R. § 38.750.

This is also consistent with SEF Core Principle 2 requiring LedgerX to establish, monitor, 

and enforce compliance with its rules. See CEA §5h(f)(2). 

Furthermore, this change is consistent with existing Rule 11.5 -Governing Law in 

LedgerX’s Rulebook. Accordingly, the change is not expected to materially impact 

LedgerX’s business operations and is intended to enhance potential Participants 

understanding of LedgerX’s business.

12. Clarified that dispute resolution processes in 

the Participant Agreement and the LedgerX 

Rulebook are binding on Authorized 

Representatives in Section XXI, Governing 

Law.

This is consistent with DCM Core Principle 14 requiring LedgerX to establish and enforce 

rules regarding dispute resolution. See CEA § 5(d)(14); see also 17 C.F.R. § 38.750.

This is also consistent with SEF Core Principle 2 requiring LedgerX to establish, monitor, 

and enforce compliance with its rules. See CEA §5h(f)(2). 

Furthermore, this change is consistent with existing Rule 11.6 - Legal Proceeding in 

LedgerX’s Rulebook. Accordingly, the change is not expected to materially impact 

LedgerX’s business operations and is intended to enhance potential Participants 

understanding of LedgerX’s business.

13. Clarified that the dispute resolution 

procedures in the LedgerX Rulebook stated 

that disputes will be settled through 

arbitration or courts located in the city of 

New York in Section XXI, Governing Law.

This is consistent with DCM Core Principle 14 requiring LedgerX to establish and enforce 

rules regarding dispute resolutions. See CEA § 5(d)(14); see also 17 C.F.R. § 38.750.

This is also consistent with SEF Core Principle 2 requiring LedgerX to establish, monitor, 

and enforce compliance with its rules. See CEA §5h(f)(2). 
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Furthermore, this change is consistent with existing Rule 11.5 -Governing Law in 

LedgerX’s Rulebook. Accordingly, the change is not expected to materially impact 

LedgerX’s business operations and is intended to enhance potential Participants 

understanding of LedgerX’s business.

REFINED PROVISIONS TO ACCOUNT FOR DCM TRADING

14. Refined references to the requirement that a

Participants be an eligible contract 

participants (“ECPs”) to reference trading 

through the Swap Execution Facility 

(“SEF”), since DCM participants are not so 

required.

a. The ECP representation is included 

in Section III, Participant Eligibility, 

with respect to SEF trading.

b. The previous Section IV, Eligible 

Contract Participant Status was 

removed in its entirety.

c. The representation of ECP statin in 

Previous Section XV, Governing 

Law was removed.

This is consistent with SEF Core Principle 2 requiring LedgerX to establish, monitor, and 

enforce compliance with its rules. See CEA §5h(f)(2); see also 17 C.F.R. § 37.202.

This is consistent with DCM Core Principle 7 requiring LedgerX to make available to 

market participants accurate information concerning the execution of transactions. See CEA 

§ 5(d)(7), 7 U.S.C. § 7(d)(7); see also 17 C.F.R. §§ 38.400-401.

This is also consistent with DCO Core Principle C requiring LedgerX to establish 

appropriate admission and continuing eligibility standards for participants. See CEA § 

5b(c)(2)(C)(i)(I); see also 17 CFR § 39.12.

Furthermore, this change is consistent with the definition of “Participant” in existing Rule 

1.1 - Definitions in LedgerX’s Rulebook. Accordingly, the change is not expected to 

materially impact LedgerX’s business operations and is intended to enhance potential 

Participants understanding of LedgerX’s business.

ADDING REDUNDANT PROVISIONS FOR EMPHASIS

15. Added multiple provisions throughout the 

Participant Agreement to emphasize that 

Participant agrees to be bound by the 

Agreement:

a. Provision added in Section I, 

Services.

b. Provision added in Section VI, Item 

E.

c. Provision added in Section VI, Item 

G, with language emphasizing that 

LedgerX can enforce the Participant 

Agreement directly.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).
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16. Added multiple provisions throughout the 

Participant Agreement to emphasize that 

Participant agrees to be bound by the 

LedgerX Rulebook:

a. Provision added to Section I, 

Services.

b. Provision added to Section VI, Item 

C, with language emphasizing the 

Digital Currency Fork policy in the 

LedgerX Rulebook.

c. Provision added to Section VI, Item 

D, with language emphasizing the 

conflict resolution provisions of the 

LedgerX Rulebook.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is consistent with DCM Core Principle 14 requiring LedgerX to establish and enforce 

rules regarding dispute resolution. See CEA § 5(d)(14); see also 17 C.F.R. § 38.750.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

ADDING PROVISIONS REGARDING USE OF SERVICES

17. Added multiple provisions throughout the 

Participant Agreement where Participant 

agrees to be bound by the Participant 

Agreement by accessing and using the 

services provided by LedgerX:

a. Provision added to Section VI, Item 

E.

T This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

18. Added multiple provisions throughout the 

Participant Agreement where Participant 

agrees to be bound by any amendments to 

the Participant Agreement by continuing to 

access and use the services provided by 

LedgerX:

a. Provision added to Section IV, 

Participant Obligations and Consent 

to Jurisdiction of LedgerX, with 

language regarding amended fees 

and charges.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).
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b. Provision added to Section VI, Item 

E.

19. Added provisions in Section III, Participant 

Eligibility where Participant represents that 

Participant meets the eligibility 

requirements in Rule 3.2 of the LedgerX 

Rulebook whenever Participant or one of its 

Authorized Representatives use of the 

services provided by LedgerX.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

ADDING PROVISIONS REGARDING FINANCIAL OBLIGATIONS

20. Added a provision to Section IV, 

Participant Obligations and Consent to 

Jurisdiction of LedgerX regarding 

Participant’s financial responsibility for 

transactions entered as a result of a failure 

in security or credit controls or entered by 

an unauthorized user.

This is consistent with DCM Core Principle 11 requiring LedgerX to establish and enforce 

rules and procedures for ensuring the financial integrity of transactions. See CEA § 

5(d)(11); see also 17 C.F.R. § 38.600.

This is also consistent with SEF Core Principle 7 requiring LedgerX to establish and 

enforce rules and procedures for ensuring the financial integrity of swaps. See CEA § 

5h(f)(7); see also 17 CFR § 37.700.

This is also consistent with DCO Core Principle D requiring LedgerX to limit its exposure 

to potential losses from defaults by members and participants. See CEA §5b(c)(2)(D)(iii); 

see also 17 CFR § 39.13(f).

21. Added a provision to Section VI, Item B 

regarding Participant’s responsibilities 

when transferring digital currency.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is consistent with DCM Core Principle 12 requiring LedgerX to establish and enforce 

rules to protect markets and market participants from abusive practices, including 

fraudulent actions. See CEA § 5(d)(12); see also 17 C.F.R. §§ 38.650-51.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with its

rules. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).
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22. Provision added to Section VI, Item M

regarding Participant’s acknowledge that it 

will not fraudulently deposit funds.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is consistent with DCM Core Principle 12 requiring LedgerX to establish and enforce 

rules to protect markets and market participants from abusive practices, including 

fraudulent actions. See CEA § 5(d)(12); see also 17 C.F.R. §§ 38.650-51.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with its

rules. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

Furthermore, this change is consistent with existing Rule 8.3 - Prohibited Trading Activity; 

Prohibitions on Fictitious Transactions, Fraudulent Activity and Manipulation in 

LedgerX’s Rulebook. Accordingly, the change is not expected to materially impact 

LedgerX’s business operations and is intended to enhance Participants understanding of 

their obligations.

23. Added a provision to Section VI, Item O

regarding LedgerX’s ability to close out or 

transfer positions or terminate accounts 

when a position is not sufficiently 

collateralized.

This is consistent with DCM Core Principle 6 requiring LedgerX to adopt rules to provide 

for the exercise of emergency authority to liquidate or transfer open positions. See CEA § 

5(d)(6)(A); see also 17 C.F.R. § 38.350.

This is consistent with DCM Core Principle 11 requiring LedgerX to establish and enforce 

rules and procedures for ensuring the financial integrity of transactions, including 

appropriate minimum financial standards. See CEA § 5(d)(11); see also 17 C.F.R. §§ 

38.600, 602, 604.

This is also consistent with SEF Core Principle 7 requiring LedgerX to establish and 

enforce rules and procedures for ensuring the financial integrity of swaps. See CEA § 

5h(f)(7); see also 17 CFR § 37.700.

This is also consistent with SEF Core Principle 8 requiring LedgerX to adopt rules to 

provide for the exercise of emergency authority to liquidate or transfer open positions in a 

swap. See CEA § 5h(f)(8); see also 17 CFR § 37.800.
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This is also consistent with DCO Core Principle D requiring LedgerX to limit the 

exposure of the DCO to potential losses from defaults by its members and participants. See 

CEA § 5b(c)(2)(D)(iii); see also 17 CFR § 39.13(f).

Furthermore, this change is consistent with existing Rule 7.1 - Full Collateralization of 

Company Contracts Required in LedgerX’s Rulebook. Accordingly, the change is not 

expected to materially impact LedgerX’s business operations and is intended to enhance 

Participants understanding of their obligations.

24. Added a provision to Section VI, Item P

regarding Participant’s responsibility to pay 

any deficiencies in Participant’s accounts.

This is consistent with DCM Core Principle 11 requiring LedgerX to establish and enforce 

rules and procedures for ensuring the financial integrity of transactions, including 

appropriate minimum financial standards. See CEA § 5(d)(11); see also 17 C.F.R. §§ 

38.600, 602, 604.

This is also consistent with SEF Core Principle 7 requiring LedgerX to establish and 

enforce rules and procedures for ensuring the financial integrity of swaps. See CEA § 

5h(f)(7); see also 17 CFR § 37.700.

This is also consistent with DCO Core Principle D requiring LedgerX to limit the 

exposure of the DCO to potential losses from defaults by its members and participants. See 

CEA § 5b(c)(2)(D)(iii); see also 17 CFR § 39.13(f).

ADDING PROVISIONS REGARDING CHANGES TO THE PARTICIPANT AGREEMENT

25. Added a provision to Section VI, Item F, 

with language regarding how a Participant 

can avoid being bound by an amendment to 

the Participant Agreement.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with its

rules. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

26. Section XIV, Amendments to the Agreement

has been added, which explains the notice 

process and how a Participant can avoid 

being bound by an amendment to the 

Participant Agreement.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with its

rules. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).
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27. Added a provision to Section XV, 

Termination that includes additional 

sections of the Participant Agreement that 

will survive the termination of the 

Participant Agreement.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with its

rules. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

28. Added a provision to Section XV, 

Termination explaining the process through 

which a Participant can terminate the 

Participant Agreement.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with its

rules. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

ADDING PROVISIONS REGARDING THIRD-PARTY EXCHANGE PARTICIPANTS

29. Added a provision to Section VII, ThirdParty Exchange Participants: 

Representations, Warranties and 

Acknowledgments regarding the agreement 

to be bound by the Participant Agreement.

a. Added provisions emphasizing that 

the dispute resolution procedures in 

the Participant Agreement are 

binding.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with its

rules. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

This is consistent with DCM Core Principle 14 requiring LedgerX to establish and enforce 

rules regarding dispute resolutions. See CEA § 5(d)(14); see also 17 C.F.R. § 38.750.

Furthermore, this change is consistent with existing Rule 11.6 - Legal Proceeding in 

LedgerX’s Rulebook. Accordingly, the change is not expected to materially impact 

LedgerX’s business operations and is intended to enhance potential Participants 

understanding of LedgerX’s business.

30. Added a provision to Section VII, ThirdParty Exchange Participants: 

Representations, Warranties and 

Acknowledgments regarding the agreement 

to be bound by the LedgerX Rulebook.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.
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a. Added provisions emphasizing that 

the dispute resolution procedures in 

the LedgerX Rulebook are binding.

This is consistent with DCM Core Principle 14 requiring LedgerX to establish and enforce 

rules regarding dispute resolutions. See CEA § 5(d)(14); see also 17 C.F.R. § 38.750.

This is also consistent with SEF Core Principle 2 requiring LedgerX to establish, monitor, 

and enforce compliance with its rules. See CEA §5h(f)(2). 

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

Furthermore, this change is consistent with existing Rule 11.6 - Legal Proceeding in 

LedgerX’s Rulebook. Accordingly, the change is not expected to materially impact 

LedgerX’s business operations and is intended to enhance potential Participants 

understanding of LedgerX’s business.

ADDING PROVISIONS REGARDING DISCLAIMERS

31. Section IX, Limited Warranty and 

Limitation of Liability has been added, 

which incorporates by reference the rules 

concerning liability and warranties in the 

LedgerX Rulebook to the Participant 

Agreement.

This is consistent with DCM Core Principle 1 and SEF Core Principle 1, which gives 

LedgerX reasonable discretion in establishing its rules. See CEA §§ 5(d)(1)(B), 5h(f)(1)(B); 

see also 17 C.F.R. §§ 38.100(b), 37.100(b).

32. Section XI, Market Information; No 

Warranty has been added, where certain 

disclaimers regarding financial information 

obtained by third-party service providers are 

listed.

This is consistent with DCM Core Principle 1 and SEF Core Principle 1, which gives 

LedgerX reasonable discretion in establishing its rules. See CEA §§ 5(d)(1)(B), 5h(f)(1)(B); 

see also 17 C.F.R. §§ 38.100(b), 37.100(b).

33. Section XII, No Investment Advice or 

Recommendations has been added, where 

Participant agrees that LedgerX is not liable 

for any decision Participant makes based on 

services provided by LedgerX.

This is consistent with DCM Core Principle 1 and SEF Core Principle 1, which gives 

LedgerX reasonable discretion in establishing its rules. See CEA §§ 5(d)(1)(B), 5h(f)(1)(B); 

see also 17 C.F.R. §§ 38.100(b), 37.100(b).

ADDING PROVISIONS REGARDING ELECTRONIC SIGNATURES
FOIA CONFIDENTIAL TREATMENT REQUESTED BY LEDGERX LLC

PARTICIPANT AGREEMENT CHANGE

COMPLIANCE WITH CORE PRINCIPLES & REGULATIONS AND

IMPACT ON LEDGERX’S BUSINESS OPERATIONS

34. Added provisions in Section XVIII, 

Counterparts regarding the use of electronic 

signatures.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

35. Section XXII, Click “I agree” for Your 

Signature has been added, which explains 

that the Participant Agreement will be 

signed with a binding electronic signature if 

the Participant clicks “I agree.”

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

MISCELLANEOUS ADDITIONS

36. Added a provision in Section V, Item D

regarding Participant’s obligation to 

maintain all necessary regulatory approvals 

and licenses.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

37. Added a provision in Section VI, Item A

regarding Participant’s awareness of the 

high risk associated with LedgerX’s 

services and derivative trading in general.

This is consistent with DCM Core Principle 2 and SEF Core Principle 2 requiring 

LedgerX to establish, monitor, and enforce compliance with its rules. See CEA §§ 5(d)(2), 

5h(f)(2); see also 17 C.F.R. §§ 38.150, 37.200.

This is also consistent with DCO Core Principle H requiring LedgerX to maintain 

adequate arrangements for the effective monitoring and enforcement of compliance with the 

rules of the DCO. See CEA § 5b(c)(2)(H)(i)(I); see also 17 CFR § 39.17(a)(1).

38. Added a provision to Section VI, Item U 

regarding liability when Participant’s 

internet service is down or disconnected.

This is consistent with DCM Core Principle 1 and SEF Core Principle 1, which gives 

LedgerX reasonable discretion in establishing its rules. See CEA §§ 5(d)(1)(B), 5h(f)(1)(B); 

see also 17 C.F.R. §§ 38.100(b), 37.100(b).

39. Added a provision in Section VI, Item W 

regarding Participant’s consent to the 

electronic delivery of tax forms.

This is consistent with DCM Core Principle 1 and SEF Core Principle 1, which gives 

LedgerX reasonable discretion in establishing its rules. See CEA §§ 5(d)(1)(B), 5h(f)(1)(B); 

see also 17 C.F.R. §§ 38.100(b), 37.100(b).
FOIA CONFIDENTIAL TREATMENT REQUESTED BY LEDGERX LLC