Comment Text:
To whom it may concern,
I have been a satisfied user of LedgerX since 2019. LedgerX, LLC d.b.a. FTX US Derivatives provides a valuable service in a secure and regulated environment. I would like to see the applicants application seeking to offer clearing of margined products directly to their end-users approved.
The ability for myself (and others) to use margin would be extremely capital efficient for my balance sheet.
Another benefit of approving FTX's application would be the reduction of counterparty risk for end-users. Participants would not need to post as much collateral to a third party. Posting digital collateral to a third party exposes the end-user to the third-party's security level. However, I do feel confident with the level of security offered by FTX US Derivatives.
Furthermore, I would like to see more volume derivatives volume traded within US regulated entities. I believe approving the application would further strengthen America's financial leadership and competitiveness.
I do have a few notes of concern, although none are specific to FTX US Derivatives.
I have hesitation about offering excessive margin to end-user participants.
I also have concerns that non-bitcoin assets could be subjected to market manipulation.
I believe bitcoin is the only digital asset that is definitively a commodity-based digital property asset. I believe other digital assets can be highly influenced on human actions. Without over-stepping my opinion, I think maybe the CFTC and other governmental Commissions should work together.
Nonetheless, the approval of FTX's Request for Amended DCO Registration Order would be a net positive to myself, other market participants, FTX US Derivatives, and America.
Thank you for your time.
