Ledger Holdings Inc

152 Madison Avenue, 21st Fl.

New York, NY 10016

https://ledgerx.com

June 17, 2019

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. 19-08

Confidential Treatment Requested by LedgerX LLC as to Appendix B and 

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 

Enterprise Risk Management Plan. The attached changes and amendments will become effective 

no earlier than June 14, 2019.

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 Enterprise Risk Management Plan is designated as Appendix B. A clean copy of the Enterprise 

Risk Management Plan 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.

* * * *
Ledger Holdings Inc

Please contact the undersigned at (917) 935-6727 or glenn@ledgerx.com if you have any questions 

or you would otherwise like to discuss this further.

Sincerely,

Glenn Chaleff

Chief Compliance Officer

LedgerX LLC
Ledger Holdings Inc

Appendix A

Rule/Section Explanation Core Principle or other CEA 

Provision, Commission Regulation 

and/or Commission Staff Letter

Enterprise Risk 

Management Plan 

An overall review was conducted 

to ensure that the document is 

current.

Core Principle I. The revisions 

ensure that the enterprise technology 

risk assessment is accurate and up-todate.

Core Principle D. The revisions are 

also part of LedgerX’s written 

policies and procedures that address 

the DCO’s risks under Core Principle 

D.

Section III Section III reflects documentation 

regarding risk appetites. III.A 

provides the methodology for 

determining risk appetite scores. 

III.B contains the risk appetite 

scores as set by the LedgerX 

board.

Core Principle I. The revisions 

regarding risk appetites are part of 

the LedgerX program of risk analysis 

and oversight under Core Principle I.

Section V Section V contains mitigating 

controls for risks in the ERM, 

along with an identification of key 

and non-key controls. 

Section V has also been updated to 

reflect insurance as a mitigant for 

physical collateral custody risk.

Core Principle I. The revisions 

regarding the identification of 

mitigating controls are part of the 

program of risk analysis and 

oversight. The identification of key 

controls is additionally relevant to the 

DCO’s scope of controls testing 

under Core Principle I. 

Physical collateral insurance is 

related to risk mitigants under Core 

Principle I, and risk management 

under Core Principle D.
Ledger Holdings Inc

Appendix B

[SEE ENTERPRISE RISK MANGEMENT PLAN REDLINE]
Ledger Holdings Inc

Appendix C

[SEE ENTERPRISE RISK MANGEMENT PLAN CLEAN]