UNITED STATES OF AMERICA 

Before the 

COMMODITY FUTURES TRADING COMMISSION 

In the Matter of the Application of 

LedgerX, LLC 

For Registration as a Derivatives Clearing Organization 

ORDER OF REGISTRATION 

LedgerX, LLC ("LedgerX") has submitted to the Commodity Futures Trading 

Commission (the "Commission"), pursuant to Section Sb of the Commodity Exchange Act (the 

"Act"), 7 U.S.C. § 7a-1, an application for registration as a derivatives clearing organization 

("DCO"). 

The Commission has reviewed the application and finds that LedgerX has demonstrated 

compliance with the requirements of the Act and applicable Commission regulations thereunder. 

In light of the foregoing, IT IS ORDERED, pursuant to Section Sb of the Act, 

7 U.S.C. § 7a-1, that LedgerX is granted registration as a DCO, subject to the terms and 

conditions specified herein: 

(1) Cleared Products. LedgerX is permitted to clear, in its capacity as a DCO, fully 

collateralized digital currency swaps, subject to the requirements of Commission Regulation 

39.S(a). A contract cleared by LedgerX will be considered fully collateralized if LedgerX holds, 

at all times, funds sufficient to cover the maximum possible loss a counterparty could incur upon 

liquidation or expiration of the contract, in the form of the required payment. 

(2) Treatment of Funds. Funds held in the Cleared Swap Proprietary Accounts shall 

be considered member property, as that term is defined in the Bankruptcy Code. LedgerX shall 

at all times maintain funds of its clearing members separate and distinct from its own funds. 

1 
(3) Digital Currency Audit. LedgerX shall engage an independent certified public 

accountant to audit LedgerX's digital currency balances and issue an opinion on the accounting 

treatment of digital currency held by LedgerX as of three months after LedgerX begins clearing 

operations, and on an annual basis thereafter. 

(4) Compliance with the Act and Commission Regulations. LedgerX shall comply, 

and shall demonstrate compliance as requested by the Commission, with applicable provisions of 

the Act, including the core principles set forth in Section Sb of the Act ("Core Principles"}, and 

Commission regulations, as may be amended or adopted from time to time. LedgerX shall fulfill 

each of the representations it has made to the Commission relating to compliance with the Core 

Principles and Commission regulations. 

(5) Self-Regulatory Function. LedgerX shall ensure the performance of all selfregulatory functions required of it as a registered DCO under the Act and Commission 

regulations, including, without limitation: monitoring and enforcing clearing member 

compliance with LedgerX admission and continuing eligibility standards; and enforcing clearing 

member compliance with the terms of all other LedgerX rules, regulations, and procedures. 

(6) New Regulations. Should the Commission promulgate or amend a regulation 

addressing or otherwise affecting any aspect of this Order, then such regulation will apply and 

supersede the applicable term(s) in this Order. 

(7) Reservation of Rights. This Order is based upon the representations made and 

supporting material provided to the Commission by LedgerX. In the event of any changes to or 

omissions in the material facts or circumstances pursuant to which this Order is issued, or for any 

reason in its own discretion, the Commission may condition, modify, suspend, terminate, or 

2 
otherwise restri ct the terms of this Order, as appropriate and as permilled by law, on its own 

motion. 

Issued in Washington, D.C. on this 24th day of July, 20 17. 

By the Commission, 

C!l4M L. c;c£ Aa 

lJ 

Christopher J. Kirkpatrick 

Secretary of the Conunission 

3 .