1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://ledgerx.com

October 27, 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. 21-23

Dear Mr. Kirkpatrick:

LedgerX LLC, d/b/a FTX US Derivatives, (“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 Compliance Manual. The attached amendments will become 

effective on November 11, 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 

minimize potential conflicts of interest by (1) updating the review and approval process for 

changes to the Operations Manual, (2) enhancing the reporting lines of the Chief Compliance 

Officer, (3) enhancing the participation of the Regulatory Oversight Committee in compliance 

oversight, (4) substituting references to the CEO with other officers who have subject matter 

expertise in certain limited compliance decisions, and (5) ensuring that, in situations where 

potential employment-related conflicts implicate both busines and compliance functions, the 

CCO’s is required to address those potential conflicts from a compliance perspective. 

Additionally, LedgerX has updated the manual (6) to reflect that it no longer shares office space 

with LedgerPrime, but will retain the same controls as before should that arise in the future. 

LedgerX has also (7) expanded on how its compliance function remains separate from 

LedgerPrime, and the CFTC stays informed about any changes in oversight.

The above changes 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 selfregulatory responsibilities and the commercial interests of the contract market. They are also 

consistent with SEF Core Principle 12, in that they establish 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.
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://ledgerx.com

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LedgerX has also (8) augmented its whistleblower program to minimize potential conflicts 

of interest in accordance with DCM Core Principle 16, SEF Core Principle 12, and DCO Core 

Principle P. This augmentation is also consistent with SEF Core Principle 1, in that it establishes 

the manner in which LedgerX complies with core principles generally.

LedgerX has also revised its monthly and quarterly financial reports filing description to 

(9) further describe requirements for reconciling custodied digital currency generally, not limited 

to bitcoin, (10) eliminate redundancies, (11) describe how they are prepared in accordance with 

Accounting and Finance Policies and Procedures, and (12) assign responsibility for preparing, 

reviewing, approving, and submitting reports. 

These changes are consistent with DCO Core Principle B, DCM Core Principle 21, and 

SEF Core Principle 13 in that they ensure LedgerX has adequate financial, operational, and 

managerial resources to discharge its responsibilities. They are also consistent with DCO Core 

Principle F, and CFTC Regulation 39.15(c), DCM Core Principle 11, and CFTC Regulation 

38.603 in that they are designed to protect and ensure the safety of member and participant assets. 

They also reduce operational risk through the development of appropriate controls and procedures, 

as required by DCO Core Principle I, DCM Core Principle 20, and SEF Core Principle 14.

LedgerX has further (13) explained how it keeps records of the review and approval process 

for its financial reports, consistent with DCO Core Principle K and DCM Core Principle 18, 

which require LedgerX to ensure that it maintains records of its activities. It is further consistent 

with SEF Core Principle 10, which requires that LedgerX maintain an audit trail of its SEF related 

activities.

Additionally, LedgerX has (14) removed references to unnecessary surveillance activities, 

consistent with DCM Core Principle 4, and SEF Core Principle 4, which require that LedgerX 

have the capacity to surveille the market for abusive trading practices.

Other non-substantive changes that do not implicate core principles have also been added, 

including adding various abbreviations, and correcting typographical errors.

A further explanation of these changes and amendments, and their compliance with Core 

Principles, is attached hereto as Appendix A. Redlines reflecting these changes and amendments 

to the Compliance Manual are attached hereto as Appendix B. The final version of the revised 

Compliance Manual is attached at 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 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.
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://ledgerx.com

3

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 LLC