1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

www.ledgerx.com

June 15, 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. 21-15

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 Operations 

Manual. The attached amendments will become effective on June 29, 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) reflect the replacement of the Director of Finance with the Chief Financial Officer, (2) update 

its operational procedures pertaining to deposits through the Automated Clearing House (“ACH”) 

system, (3) address the processes and procedures for managing reversals of ACH deposits and 

their impact on ACH reserves, and (4) revise the description of the month end accounting process.

These changes are consistent with DCO Core Principle B to ensure LedgerX has adequate 

financial, operational, and managerial resources, DCO Core Principle F and CFTC Regulation 

39.15(c) to protect and ensure the safety of member and participant assets, and DCO Core 

Principle I to reduce operational risk through the development of appropriate controls and 

procedures.

The changes are also consistent with DCM Core Principle 21 and SEF Core Principle 

13 to ensure LedgerX has adequate financial, operational, and managerial resources. It is also 

consistent with DCM Core Principle 11 and CFTC Regulation 38.603 requiring the protection of 

customer funds. Additionally, they are consistent with SEF Core Principle 7 and CFTC 

Regulation 37.702, requiring an exchange to provide for the financial integrity of transactions. 

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

consistent with DCM Core Principle 20 and SEF Core Principle 14.

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

Principles is attached hereto as 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.
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

www.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 LLC