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. 23-03

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 Swap Execution Facility (“SEF”). 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 SEF Core Principle 12 and CFTC Regulation 

37.1200 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 SEF Core Principle 4 and CFTC Regulation 37.400 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 

clarified at Rules 9.6A, B and C. These revisions are consistent with SEF Core Principle 4 and 

CFTC Regulation 37.400 in that they establish appropriate Disciplinary procedures.
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

www.ledgerx.com

2

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 SEF Core Principle 12 and 

CFTC Regulation 37.1200 in that they properly address potential conflicts of interest in the 

decision making process of the Company.

Rule 5.6, which describes the trading hours of the Company, has been revised to allow 

the Company more flexibility in its determination of trading hours. Additionally, Rules 12.7. 

and 12.8 have been revised to cross-reference the trading hours in Rule 5.6, consistent with 

other Contracts. Also, the last trading time in Rule 12.7 has been revised, as have the final 

payment day and time in both Rules 12.7 and 12.8. These revisions are consistent with SEF

Core Principle 4 and CFTC Regulation 37.400 in that they establish the procedures, terms and 

conditions for market participants to access and execute trades on the SEF.

Rule 6.5, which describes the consequence of failing to deposit or withdraw collateral 

as required, has been revised to correct a cross-referencing error. This revision is consistent 

with SEF Core Principle 7 in that it ensures the financial integrity of transactions.

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

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 SEF 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