1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://ledgerx.com

October 23, 2021

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. 21-22

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 amendments to the LedgerX

Operations Manual. The attached amendments will become effective on November 6, 2021. 

The following is 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. Broadly speaking, LedgerX has revised its operations manual to 

(1) update the review and approval process for changes to the Operations Manual, and (2) update 

the settlement process for contracts cleared by LedgerX for Kalshi Exchange.

The changes to the review and approval process for changes to the Operations Manual are 

consistent with core principals as follows. They are consistent with DCM Core Principle 16 in 

that they minimize potential conflicts of interest between the self-regulatory responsibilities and 

the commercial interests of the contract market. They are also consistent with SEF Core 

Principle 1 in that it establishes the manner in which the swap execution facility complies with 

core principles, within its reasonable discretion, and SEF Core Principle 12, in that it establishes 

rules to minimize conflicts of interest in its decision-making process. They are also consistent 

with DCO Core Principle P, in that it establishes rules to minimize conflicts of interest in the

decision making process of the derivatives clearing organization.

The changes to the settlement process for contracts cleared by LedgerX for Kalshi 

exchange are consistent with DCO Core Principle E, in that ensures settlements will be completed 

on a timely basis by reducing the settlement time by reducing the settlement time from 25 hours, 

and instead settling those contracts promptly after expiry, or promptly after Kalshi’s market 

outcome determination process is completed.

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

designated as Appendix A. The final version of the revised Operations Manual is attached at 

Appendix B.
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://ledgerx.com

2

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 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 gc@ledgerx.com if you have any questions or you would 

otherwise like to discuss this further.

Sincerely,

Brian G. Mulherin

General Counsel, LedgerX LL