152 Madison Avenue

21st Floor

New York, NY 10016

e: ian@ledgerx.com 

w: ledgerx.com

128565540

December 4, 2017

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. 17-09

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 its Rules. The 

attached amendments will become effective on December 19, 2017.

A concise explanation and analysis of the 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 amendments is attached hereto as 

Appendix B.

LedgerX certifies that the 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/. 

There were no substantive opposing views to the amendments.

* * * *
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Please contact the undersigned at (917) 677-7598 or ian@ledgerx.com if you have any questions 

or you would otherwise like to discuss this further.

Sincerely,

Ian J. Darrow

General Counsel

LedgerX LLC

Enclosure
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Appendix A

Rule/Section Explanation

Core Principle or other 

CEA Provision, 

Commission Regulation 

and/or Commission 

Staff Letter

Rule 3.2B Pursuant to discussions with the Division of 

Market Oversight, add clarifying language

that LedgerX does not currently have any 

Participants that may intermediate trades.

SEF Core Principle 2, 

SEF Core Principle 4
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Appendix B

[SEE ATTACHED]
34

withdrawal requests and for providing any information the Exchange may 

request regarding such Participant; provided, that upon request the 

Exchange may permit an entity applicant to designate a single Authorized 

Representative in the Chief Compliance Officer’s sole discretion; and

10. meet any other criteria and provide the Exchange with any other 

information the Exchange may request regarding the Participant.

B. Each FCM Participant shall have the right to access electronically the Platform, 

including the right to place Orders for each of its Cleared Swaps Proprietary 

Accounts or Customer Accounts, provided that such FCM Participant is eligible 

for and has applied and received Trading Privileges and Clearing Privileges. The 

Exchange does not currently have any FCM Participants or other Participants 

that may execute intermediated trades. In order to become an FCM Participant, 

an FCM applicant must: 

1. satisfy the conditions in Rule 3.2A;

2. be validly organized and in good standing, in the United States; 

3. have sufficient operational capabilities and resources to support the 

Platform and Underlying transfer requirements, including sufficient: (a) 

policies and procedures, (b) understanding of and support for the 

Exchange Contracts and transfers of the Underlying, (c) asset security 

and cyber security procedures and (d) AML controls;

4. have sufficient ability, appropriate accounts and technical support to clear 

the Underlying, including maintenance of the requisite Collateral Accounts 

at all times; 

5. submit to the Exchange a letter confirming that the applicant will maintain 

all Customer funds deposited with it in connection with trading any 

Exchange Contract in appropriately labeled and segregated Cleared 

Swaps Customer Accounts separated from funds of both the FCM 

Participant and Customers, as required by Commission regulations; 

6. except as provided below in this Rule 3.2.B, confirm that each of its 

Customers represents that each such Customer is an ECP; and