1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

www.ledgerx.com

1

November 15, 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. 23-04

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 the Company’s Derivatives Clearing Organization

(“DCO”). The attached amendments will become effective within 10 business days hereof. 

The current estimated effective date is November 30, 2023. 

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.

The Company has removed references to LedgerPrime, since LedgerPrime is no longer 

an affiliate following the sale of the Company. These changes include the deletion of the 

definition of LedgerPrime in Rule 1.1, and the removal of LedgerPrime specific provisions at 

Rule 2.5. These revisions are consistent with DCO Core Principle P and CFTC Regulation 

39.25 in that they properly address potential conflicts of interest in the decision making process 

of the Company.

The Company has also revised provisions pertaining to the constitution and 

composition of Disciplinary Panels, to provide for the formation of multiple different 

Disciplinary Panels, and to clarify that they may be composed of persons who are not Directors

of the Company. Applicable changes may be found at Rules 2.6, 2.7E, 2.11, and 9.3. These 

revisions are consistent with DCO Core Principle P and CFTC Regulation 39.25 in that they 

properly address potential conflicts of interest, and also consistent with DCO Core Principle H

and CFTC Regulation 39.17 in that they establish one or more disciplinary panels that are 

authorized to fulfill their obligations.

Disciplinary Process changes has also been incorporated into these DCM Rulebook 

changes, including the following. Changes to Rule 9.1G expressly allow for all parties to be 

represented by counsel. Allowance of service by electronic mail under specified conditions is 

also described in revisions to Rules 9.4A, 9.5C, 9.5G, 9.5I, and 9.7A. The timing for examining 

evidence has been clarified at Rule 9.5B, and the process for reaching a settlement has been 
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

www.ledgerx.com

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clarified at Rules 9.6A, B and C. These revisions are consistent with DCO Core Principle H 

and CFTC Regulation 39.17 in that they establish appropriate Disciplinary procedures.

The composition of various Committees of the Board of Directors has been clarified at 

Rules 2.8A and 2.11C.1 to expressly state that those Committees must be composed of at least 

35% Public Directors. Additional Rule 2.11.A.1 clarifies that Disciplinary Panels must be at 

least 35% composed of persons who would be qualified to be Public Directors, even if they are 

not appointed as Public Directors of the Company, and describes other composition limitations 

to such Disciplinary Panels. These revisions are consistent with DCO Core Principle P and Q, 

and CFTC Regulations 39.25 and 39.26 in that they properly address potential conflicts of 

interest in the decision making process of the Company.

Rule 7.2 has been revised to add a new paragraph G, allowing for the Clearinghouse to 

invest cash deposited as collateral in interest bearing U.S. bank accounts only, as further 

specified therein. This revision is consistent with DCO Core Principle F and CFTC Regulation 

39.15 in that it is designed to protect and ensure the safety of member and participant funds 

and assets, and presents minmal credit, market, and liquidity risks to deposited funds.

Rules 12.7. and 12.8 have been revised to cross-reference the trading hours in Company 

Rule 5.6 (found in the Company’s DCM and SEF Rulebooks), consistent with other Contracts. 

Also, the last trading time in Rule 12.7 has been revised, as has the final payment day and time 

in Rule 12.8. These revisions are consistent with DCO Core Principle E and CFTC Regulation 

39.14 in that they establish the procedures, terms and conditions for the settlement of trades.

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

the numbering in of Rule 3.2 to be consistent with that of the Company’s DCM and SEF 

Rulebooks, as well as various typographical errors. 

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://ledgerx.com/reg-notices. The Company 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
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

www.ledgerx.com

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