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Nodal Electronic Trade Error Policy

A. Policy Overview. The policy will be applied to balance the adverse effects on market 

integrity of executing trades and publishing trade information inconsistent with prevailing 

market conditions while preserving legitimate expectations of trade certainty by 

Participants. The Nodal Exchange Rulebook authorizes Nodal Exchange (“Nodal”) to cancel 

(bust) trades when such action is necessary to mitigate market disrupting events caused by 

the improper or erroneous use of the Exchange or by system defects or malfunctions. 

Notwithstanding any other provision of Rule 4.9.1, the Exchange may cancel any trade if

the Exchange determines that allowing the trade to stand as executed may have a material, 

adverse effect on the integrity of the market. Any decision of the Exchange with respect to a 

cancellation subject to Rule 4.9.1 shall be final.

B. Determining When to Review a Trade. Nodal may review a trade based on its analysis of 

market conditions or a request for review by a user of the Exchange. Nodal phone numbers 

are available on the Nodal Exchange Website. A request for review must be made to the 

Nodal Exchange Helpdesk within eight minutes of the execution of the trade; the Exchange 

may determine in its sole discretion that a trade may be reviewed beyond that timeframe. 

Nodal shall promptly determine whether the trade will be subject to review. Upon deciding 

to review a trade, Nodal will promptly issue an alert to all Participants by posting a 

message which includes the impacted trade group id on the Nodal Trade Log, that indicates 

that the trade is under review.

In the course of its review of any trade, Nodal may contact Exchange Participants. The 

Exchange will not disclose to the parties to the alleged error trade the identity of their 

counterparty. In the absence of a timely request for review, during volatile market 

conditions, upon the release of significant news, or in any other circumstance in which 

Nodal deems it to be appropriate, Nodal may determine, in its sole discretion, that a trade 

shall not be subject to review.

C. Determining When to Cancel a Trade. Upon making a determination that a trade will be 

subject to review, Nodal will first determine whether the trade price is within the “No 

Cancellation Range” (as defined herein). In applying the No Cancellation Range, Nodal shall 

determine the fair value market price for that contract at the time the trade under review 

occurred.

In determining the fair value market price, Nodal may consider any relevant information, 

including, but not limited to: the last trade price in the Nodal contract, or a better bid or 

offer price on the Nodal Exchange system, a more recent price in a different contract 

month, the price of the same or related Nodal contract established in another venue or
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another market, the market conditions at the time of the trade, the theoretical value of an 

option based on the most recent implied volatility and responses to a request for quote. 

Nodal will then compare the trade price to the fair value market price and determine if any 

difference is inside or outside the cancellation range.

i. Trade Price Inside the No Cancellation Range. If Nodal determines that the price 

of the trade is inside the No Cancellation Range, the Exchange will issue an alert 

indicating that the trade shall stand.

ii. Trade Price Outside the No Cancellation Range. If Nodal determines that a trade 

price is outside the No Cancellation Range, the Exchange will bust the trade. Nodal 

will issue an alert regarding its decision.

Cancelled trade prices shall be recorded in Nodal Exchange’s official record of time and 

sales.
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No Cancellation Ranges

Financial Gas Products Month Spread Season & 

Calendar Spread

Henry Hub 2500 $0.04 $0.04 $0.04 $0.04

Henry Hub 10k $0.05 $0.05 $0.05 $0.05

Financial Power Products Month & 

Season Spread Quarter & Calendar Spread

PJM West Hub RT, Indiana RT, Nepool DA Futures $0.60 $0.60 $0.40 $0.40

All other futures contracts $1.00 $1.00 $1.00 $1.00

Day Ahead/Real Time Spreads $0.60 $0.40

Environmental Products Month Spread

California Carbon Allowance, California Carbon Offset, Washington Carbon 

Allowance

$0.25 $0.25

RGGI Carbon Allowance $0.10 $0.10

CSAPR NOX Ozone Season Group 2 $3.00 $3.00

CSAPR NOX Ozone Season Group 3 $30.00 $30.00

All other CSAPR SO2 /NOX Emission Allowance $0.05 $0.05

California PCC 3 REC $0.05 $0.05

PJM Compliance REC/AEC $0.25 $0.25

NEPOOL Class 1, 2 & Class 3 Compliance REC/AEC $1.00 $1.00

New York REC Tier 1 $0.25 $0.25

Texas Compliance REC $0.25 $0.25

Texas, NAR, M-RETS, WREGIS, National CRS Listed RECs $0.05 $0.05

NJ, DC, MD & OH Solar REC, PA Solar AEC $5.00 $5.00

MA Solar REC $5.00 $5.00

California LCFS, Oregon CFP, Washington CFP Credits $5.00 $5.00

Renewable Identification Numbers(RINs) $0.05 $0.05

Renewable Natural Gas Certificate $0.50 $0.50

Verified Emission Reduction (VER) CORSIA, VER Nature Based, VER Nature 

Based Vintage

$0.50 $0.50

Carbon Removal $0.50 $0.50

Certified Emission Reduction (CER) 2013+, CER 2016+, CER CP2 $0.05 $0.05

Global Emission Reduction (GER) $0.50 $0.50

Option

The greater of the following:

-Delta multiplied by the underlying futures No Cancellation Range

-20% of premium up to 1⁄4 of the underlying futures No Cancellation Range

-5 ticks
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Version Control Table

Version Effective date(s) Sections changed Summary of changes Owner(s)

2022v1 April 25, 2022 – June

16, 2022

Initial version Nodal Electronic Trade Error

Policy

Director of Compliance; Director,

Market Operations and Customer

Service

2022v2 June 17, 2022 No Cancellation Ranges AddedNo Cancellation

Ranges for new Env.

contracts

Director of Compliance; Director,

Market Operations and Customer

Service

2023v1 August 11, 2023 No Cancellation Ranges AddedNo Cancellation

Ranges for new Env.

contracts

Director of Compliance; Director,

Market Operations and Customer

Service