135519018

Ledger Holdings Inc

152 Madison Avenue, 21st Fl.

New York, NY 10016

https://ledgerx.com

July 10, 2019

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. 19-20

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 Compliance 

Manual. The attached changes and amendments will become effective on July 23, 2019. 

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, is attached hereto as Appendix A. A marked copy of the changes and amendments to 

the Compliance Manual is designated as Appendix B. LedgerX is requesting confidential treatment 

for Appendix B. A request for confidential treatment and detailed written justification is being 

simultaneously submitted to the Commission. 

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 non-confidential 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.

* * * *
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Ledger Holdings Inc

Please contact the undersigned at 917-935-6727 or gchaleff@ledgerx.com if you have any 

questions or you would otherwise like to discuss this further.

Sincerely,

Glenn Chaleff

Chief Compliance Officer

LedgerX LLC
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Ledger Holdings Inc

Appendix A

Manual Explanation Core Principle or other CEA 

Provision, Commission 

Regulation and/or 

Commission Staff Letter

Compliance Manual Section 7.1 Section 7.1 covers LedgerX’s 

Compliance and Risk 

Management Program. The 

procedures added further detail 

on LedgerX providing 

information to the Commission 

upon request.

Core Principle 10. The 

revisions provide clarity on 

LedgerX’s requirement with 

respect to CFTC reporting, 

including supporting data and 

information.

Compliance Manual Section 9.2 Section 9.2 discusses employee 

fitness and this change 

enhanced the procedures 

surrounding employee pre-hire 

screening.

Core Principle 2. This change 

was to provide further detail 

surrounding LedgerXs’ ability 

to enforce fitness standards for 

LedgerX employees.

Compliance Manual Section 10.3.2 Section 10.3 covers conflicts of 

Interest and LedgerX updated 

sub-section10.3.2 to state that 

investigations will be conducted 

by an independent 3rd party.

Core Principle 12. The 

revisions improve clarity with 

respect potential conflicts of 

interest; specifically, to any

investigations dealing with

LedgerPrime.

Compliance Manual Section 11.4.3 Section 11.4.3 covers LedgerX 

employee trading and this 

change refined the procedures 

surrounding employee trading.

This change was in order to 

comply with CFTC regulation 

1.59.

Compliance Manual Section 12.3 Section 12 of the Manual covers 

Market Participants and this 

change Enhanced the procedures 

around participant eligibility and 

screening. 

Core Principle 3. The revisions 

will improve LedgerX’s ability 

to periodically review 

exchange participants.

Compliance Manual Section 15 Section 15 pertains to SDR 

reporting and LedgerX 

procedures were updated to 

ensure that the Platform clearly 

identifies whether a swap is 

being traded on the DCM or 

SEF.

Part 43 and Part 45. LedgerX 

procedures ensure proper 

reporting should the DCM and 

SEF share certain automated 

systems.
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Ledger Holdings Inc

Compliance Manual Section 21.8 Additional language was added 

requiring LedgerX to certify and 

copy all notices of disciplinary 

or access denial action.

Core Principle 3 and 

Commission regulation 9.11. 

These changes enhance 

compliance with rule 

enforcement through additional 

disciplinary procedures.

Compliance Manual Section 22.4.2 Section 22.4.2 was revised to 

provide guidance regarding the 

reporting of any changes in 

equity ownership of more than 

10%.

General Provisions. This 

ensures LedgerX will properly 

report all transfers or decreases 

in firm equity.
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Ledger Holdings Inc

Appendix B

[SEE COMPLIANCE MANUAL REDLINE]