1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://derivs.ftx.us/

1

August 4, 2022

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. 22-10

Dear Mr. Kirkpatrick:

LedgerX LLC (d/b/a FTX US Derivatives) (the “Company”) 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 its current, integrated Rulebook for the purpose of 

creating a standalone Rulebook for the Company’s Derivative Clearing Organization 

(“DCO”). The attached amendments will become effective on August 18, 2022. 

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, are as follows.

Primarily, the Company has prepared a standalone Rulebook for its DCO by removing 

all definitions and provisions exclusively applicable to the Company’s other registration 

categories, removing definitions not used elsewhere in the Rulebook, removing rules that are 

currently inapplicable to the DCO (including provisions and definitions with respect to futures 

commission merchants (“FCMs”), in light of the absence of FCMs among the DCO’s current 

membership), and providing minor clarifications of the applicability of provisions to clearing 

functions. The removal of provisions not applicable to the DCO are consistent with DCO Core 

Principles A and F in that they make clear to Participants the Rules applicable to the DCO, 

and to Participants clearing transactions through the DCO, by, among other things, removing 

rules applicable to other registration categories. The Company has also augmented its 

references to Kalshi Contracts eligible for clearing, consistent with DCO Core Principle C

and CFTC Regulation 39.12.

Secondarily, the above-referenced changes are in furtherance of DCO Core 

Principle L, as a standalone DCO rulebook facilitates market participants’ ability to easily 

identify and review relevant information concerning the rules and operating and default 

procedures governing the clearing and settlement systems of the DCO.

Other minor corrections were made to the revised DCO Rulebook, including correcting 

various typographical errors, including in the descriptions of previously certified contract terms 

and to the definitions of terms used elsewhere. 
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://derivs.ftx.us/

2

The above-referenced changes are substantially similar to the July 27, 2022 revisions 

which have been withdrawn, except that the current revisions do not alter the text of Rules 

6.1A or 7.1.

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

designated as Appendix A. The final version of the revised DCO Rulebook is attached at 

Appendix B. 

The Company certifies that the above changes and amendments comply with the CEA 

and Commission Regulations thereunder. The Company additionally certifies that it has 

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

website at https://derivs.ftx.us. The Company is not aware of any or substantive opposing 

views to the changes and amendments.

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

otherwise like to discuss this further.

Sincerely,

Brian G. Mulherin

General Counsel, FTX US Derivatives