Commodity Futures Trading Commission

March 27, 2018

SR-NFX-2018-15

Page 2

March 27, 2018	Nasdaq Futures, Inc.

	FMC Tower, Level 8, 

Christopher J. Kirkpatrick						 2929 Walnut Street

Office of the Secretariat						 Philadelphia, PA 19104 / USA

Commodity Futures Trading Commission				 

Three Lafayette Center						 business.nasdaq.com/futures

1155 21st Street, NW

Washington, DC  20581

**Rule Self-Certification: 	Rule Certification to**

**Launch a New Designated Market Maker Program**

**Reference File: SR-NFX-2018-15**

Dear Mr. Kirkpatrick:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (“Act”), and Section 40.6 of the Commission’s regulations thereunder, NASDAQ Futures, Inc. (“NFX” or “Exchange”) submits this self-certification to launch a new Designated Market Maker Program (the “DMM Program”) for contracts that the Exchange has listed pursuant to Appendix A of the Exchange Rulebook (the “Contracts”).[footnoteRef:1]  Effective trade date April 16, 2018, the DMM Program will operate for a period of one year.  The DMM Program will replace the former DMM program and MQ program terminated by SR-NFX-2018-14.  A description of the program is attached as Exhibit A.  A description of the cost of the programs is attached as confidential Exhibit B. [1:  See NFX Rulebook Appendix A – Listed Contracts ] 

The DMM Program is being revised and relaunched to reward program participants that exhibit the highest degrees of participation and provide for the most competitive markets on NFX.  The Exchange believes that the new DMM Program complies with Core Principle 4 (Monitoring of Trading), Core Principle 9 (Execution of Transactions) and Core Principle 12 (Protection of Market Participants).  The DMM Program will not impact order execution priority or otherwise give participants any execution preference or advantage.  The DMM Program will not impact the Exchange’s ability to perform its trade practice and market surveillance obligations under the Act and Exchange staff will monitor trading in the DMM Program’s products to prevent manipulative trading and market abuse.  Additionally, the Exchange has systems to track program participants’ volume to ensure proper distribution of earned incentives.  Finally, NFX rules include prohibitions against fraudulent, non-competitive, unfair or abusive practices.  

The Exchange has reviewed the designated contract market core principles as set forth in the Act in connection with the amendments presented herein.  Consistent with Core Principle 7 - Availability of General Information, the Exchange will post general information, including the NFX Rulebook as amended herein, on its website: business.nasdaq.com/futures. 

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**Certifications**

There were no opposing views among NFX’s Board of Directors, members or market participants.  The Exchange hereby certifies that the rule amendments set forth herein comply with the Act and the Commission’s regulations thereunder.  The Exchange also certifies that notice of pending certification and a copy of this submission have been concurrently posted on the Exchange’s website: business.nasdaq.com/futures.  

If you require any additional information regarding this submission, please contact Stephen Matthews at (301) 978-8458 or steve.matthews@nasdaq.com.  Please refer to SR-NFX-2018-15 in any related correspondence. 

Regards,

Daniel R. Carrigan

President

Exhibit A 

DMM Program Tender

Confidential Exhibit B

Description and cost estimate for the DMM Program through March 31, 2019 (under separate cover)

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