1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://derivs.ftx.us/

1

March 10, 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. 22-02

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 update to its Privacy Policy, which is incorporated by reference into 

Company Participant Agreement. The Participant Agreement and Company User Agreement 

have also been slightly amended. The attached amendments will become effective on 

March 24, 2022. 

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 Participant Agreement has been amended to replace references to the Company’s 

legal name with references to the “Company.” It has also been amended to incorporate by 

reference the Company User Agreement and the Company Privacy Policy. Similarly, the User 

Agreement, which is incorporated by reference into the Participant Agreement, has been 

amended to replace references to the Company’s legal name with references to the “Company.” 

The Privacy Policy, which is incorporated by reference into the Participant Agreement, 

has been completely updated to inform the Company’s customers about how the Company

uses, stores, processes, and sharees customers’ personal information. 

These changes are consistent with SEF Core Principle 5 in that they clarify the rules 

allowing the Company to obtain any necessary information. They are also consistent with SEF 

Core Principle 9 and DCM Core Principle 10 in that they clarify our procedures for the 

recording and safe storage of all identifying trade information. They are also consistent with 

DCM Core Principles 18 and 23, SEF Core Principle 10, and DCO Core Principal K in 

that they set forth the Company’s policies on required recordkeeping. They are also consistent 

with DCO Core Principal J in that they clarify the Company’s policies on reporting necessary 

information to the Commission. Finally, they are also consistent with DCM Core Principles 

3 and 4, SEF Core Principle 3, as well as DCO Core Principal M, in that they set forth the 

Company’s policies relating to information sharing.
1110 Brickell Avenue

Suite 430k-200

Miami, FL 33131

https://derivs.ftx.us/

2

The changes and amendments to the Participant Agreement are reflected in a redlined 

copy designated as Appendix A. The final version of the revised Participant Agreement is 

attached at Appendix B. The changes and amendments to the User Agreement are reflected 

in a redlined copy designated as Appendix C. The final version of the revised User Agreement 

is attached at Appendix D. The changes to the Privacy Policy are reflected in a redlined copy 

designated as Appendix E. The final version of the revised Privacy Policy is attached at 

Appendix F. 

The Company certifies that the 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://derivs.ftx.us. 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, FTX US Derivatives