1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://derivs.ftx.us/

1

December 3, 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 (d/b/a FTX US Derivatives) Submission No. 21-25

Dear Mr. Kirkpatrick: 

LedgerX LLC d/b/a FTX US Derivatives (“LedgerX” or “FTX US Derivatives”) 

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 December 18, 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) re-assign certain responsibilities relating to risk management from the Chief Compliance 

Officer to the Chief Risk Officer, (2) re-assign certain responsibilities relating to cash and 

collateral management from the Chief Compliance Officer to the Chief Financial Officer, 

(3) reflect the process for handling ACH transfers for participants on the Kalshi Exchange, and

(4) update the operational processes for handling deposits and withdrawals of cash and

cryptocurrency.

The changes to re-assign certain responsibilities from the Chief Compliance Officer to 

the Chief Risk Officer or Chief Financial Officer are consistent with DCO Core Principle B, 

in that they ensure the derivatives clearing organization will have adequate financial, 

operational, and managerial resources to meet its financial obligations, DCO Core Principle 

D, in that they enable the derivatives clearing organization to manage risks, and DCO Core 

Principle P, in that they establish rules to minimize conflicts of interest in the decision making 

process of the derivatives clearing organization. These changes are also consistent with DCO 

Core Principle I, DCM Core Principle 20, and SEF Core Principle 14 in that they reduce 

operational risk through the development of appropriate controls and procedures. 

The changes that reflect the process for (a) handling ACH transfers for participants on 

the Kalshi Exchange and (b) handling deposits and withdrawals of cash and cryptocurrency, 

are consistent with DCO Core Principle B, in that they ensure the derivatives clearing 

organization will have adequate financial resources to meet its financial obligations to 

participants notwithstanding a default by a participant, DCO Core Principle D, in that they 

enable the derivatives clearing organization to manage risks, and DCO Core Principal E, in 

that they enable the derivatives clearing organization to complete money settlements on a 
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

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timely basis and maintain an accurate record of the flow of funds. These changes are also 

consistent with DCO Core Principle I, DCM Core Principle 20, and SEF Core Principle 

14 in that they reduce operational risk through the development of appropriate controls and 

procedures. 

A list of the changes and amendments to the Operations Manual is set forth in 

Appendix A. The changes and amendments to the Operations Manual are reflected in a 

redlined copy designated as Appendix B. The final version of the revised Operations Manual 

is attached at Appendix C. 

FTX US Derivatives certifies that the changes and amendments comply with the CEA 

and Commission Regulations thereunder. FTX US Derivatives additionally certifies that it has 

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

Derivatives website at https://derivs.ftx.us/. FTX US Derivatives is not aware of any or 

substantive opposing views to the changes and amendments. 

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

otherwise like to discuss this further. 

Sincerely, 

Rahul Sharma 

Deputy General Counsel, FTX US Derivatives