NORTH AMERICAN 

DERIVATIVES EXCHANGE, INC. 

(NADEX)

RULES

d/b/a

Revised 5/23/2023
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TABLE OF CONTENTS

NORTH AMERICAN DERIVATIVES EXCHANGE, INC. (NADEX) RULES..........................1

INTRODUCTION............................................................................................................................6

CHAPTER 1 DEFINITIONS..........................................................................................................6

RULE 1.1 DEFINITIONS...................................................................................................6

RULE 1.2 INTERPRETATION.......................................................................................15

RULE 1.3 DATE AND TIME REFERENCES ...............................................................15

RULE 1.4 CONFLICTS...................................................................................................15

CHAPTER 2 MARKET GOVERNANCE ...................................................................................16

RULE 2.1 POWERS OF NADEX’S BOARD OF DIRECTORS ....................................16

RULE 2.2 RESTRICTIONS ON WHO MAY BE MEMBERS OF THE BOARD, 

MEMBERS OF DISCIPLINARY COMMITTEES, MEMBERS OF 

ARBITRATION OR OVERSIGHT PANELS, OR TEN PERCENT

OR GREATER OWNERS .............................................................................16

RULE 2.3 OFFICERS OF NADEX..................................................................................16

RULE 2.4 EMERGENCY RULES ...................................................................................17

RULE 2.5 COMMITTEES AND SUBCOMMITTEES ...................................................19

RULE 2.6 VOTING BY INTERESTED BOARD MEMBERS .......................................20

RULE 2.7 INDEMNIFICATION OF DIRECTORS, OFFICERS, AND OTHERS .........20

RULE 2.8 PROHIBITION ON USE OF MATERIAL, NON-PUBLIC

INFORMATION ............................................................................................20

RULE 2.9 LIMITATION ON TRADING BY AFFLIATES............................................21

RULE 2.10 CONSENT TO JURISDICTION...................................................................22

CHAPTER 3 MEMBERS.............................................................................................................23

RULE 3.1 TRADING MEMBERS - APPLICATIONS, CLASSIFICATIONS,

AND PRIVILEGES........................................................................................23

RULE 3.2 FCM MEMBERS - APPLICATIONS, CLASSIFICATIONS, AND 

PRIVILEGES..................................................................................................26

RULE 3.3 MEMBER OBLIGATIONS ............................................................................27

RULE 3.4 FCM MEMBER OBLIGATIONS ...................................................................29

RULE 3.5 SUPERVISION................................................................................................32

RULE 3.6 AUTHORIZED TRADERS.............................................................................33

RULE 3.7 REJECTION OF APPLICANT AND LIMITATIONS OF TRADING 

PRIVILEGES..................................................................................................34
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RULE 3.8 COMMUNICATIONS BETWEEN NADEX AND MEMBERS AND

OTHER PARTICIPANTS..............................................................................34

RULE 3.9 DUES, FEES, AND EXPENSES PAYABLE BY MEMBERS ......................35

CHAPTER 4 MARKET MAKERS ..............................................................................................36

RULE 4.1 REGISTRATION OF MARKET MAKERS ...................................................36

RULE 4.2 APPOINTMENT OF MARKET MAKERS....................................................36

RULE 4.3 BENEFITS OF BECOMING A MARKET MAKER......................................36

RULE 4.4 OBLIGATIONS OF MARKET MAKERS .....................................................37

CHAPTER 5 METHOD FOR MEMBERS TO TRADE CONTRACTS .....................................39

RULE 5.1 PRIOR REVIEW OF RISK DISCLOSURE STATEMENT AND 

THESE RULES AND ACCEPTANCE OF TERMS OF

MEMBERSHIP AGREEMENT IS REQUIRED ...........................................39

RULE 5.2 TRADING MEMBER AND AUTHORIZED TRADER ACCESS TO 

NADEX ..........................................................................................................39

RULE 5.3 TRADING CONTRACTS – TRADING MEMBERS.....................................40

RULE 5.4 TRADING CONTRACTS – CUSTOMERS OF FCM MEMBERS ...............42

RULE 5.5 ORDER ENTRY..............................................................................................44

RULE 5.6 RECORDKEEPING OF FCM CUSTOMER ORDERS..................................46

RULE 5.7 HANDLING OF CUSTOMER ORDERS.......................................................46

RULE 5.8 TRANSFER TRADES AND ADJUSTED ORDERS .....................................47

RULE 5.9 DISPUTED ORDERS .....................................................................................48

RULE 5.10 ACCEPTABLE ORDERS.............................................................................49

RULE 5.11 PRIORITY OF ORDERS ..............................................................................49

RULE 5.12 FILLING ORDERS TO TRADE CONTRACTS ..........................................49

RULE 5.13 MODIFICATION AND CANCELLATION OF ORDERS ..........................50

RULE 5.14 TRADE CANCELLATIONS ........................................................................50

RULE 5.15 INVALIDATION OF ORDERS UPON SUSPENSION OR

REVOCATION OF FCM MEMBER STATUS.............................................51

RULE 5.16 INVALIDATION OF TRADES UPON SUSPENSION OR

REVOCATION OF FCM MEMBER STATUS.............................................51

RULE 5.17 VIEWING THE MARKET AND EXECUTED ORDERS ...........................51

RULE 5.18 HOURS FOR TRADING CONTRACTS......................................................52

RULE 5.19 PROHIBITED TRANSACTIONS AND ACTIVITIES ................................52

RULE 5.20 SPECULATIVE POSITION LIMITS ...........................................................55

CHAPTER 6 CLEARING AND SETTLING CONTRACT TRADES, CONTRACTS 

AT EXPIRATION, AND MEMBER WITHDRAWAL REQUESTS AND

REGULATORY REPORTING OF SWAP DATA ...............................................57

RULE 6.1 CLEARANCE AND SUBSTITUION.............................................................57

RULE 6.2 SETTLING CONTRACT TRADES ...............................................................57
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RULE 6.3 SETTLING CONTRACTS AT EXPIRATION...............................................57

RULE 6.4 SETTLING MEMBER WITHDRAWAL REQUESTS ..................................59

RULE 6.5 REGULATORY REPORTING TO SWAP DATA REPOSITORY ...............59

CHAPTER 7 ADJUSTMENTS NECESSITATED BY MATERIAL CHANGES IN

THE UNDERLYING.............................................................................................60

RULE 7.1 ADJUSTMENTS.............................................................................................60

RULE 7.2 GOVERNMENT ACTIONS ...........................................................................60

CHAPTER 8 INVESTMENT OF MEMBER ACCOUNT FUNDS.............................................61

CHAPTER 9 RULE ENFORCEMENT........................................................................................62

RULE 9.1 MONITORING THE MARKET .....................................................................62

RULE 9.2 INVESTIGATIONS, HEARINGS, AND APPEALS......................................62

RULE 9.3 SETTLEMENT OF INVESTIGATIONS........................................................66

RULE 9.4 NOTICE AND PUBLICATION OF DISCIPLINARY ACTION ...................67

RULE 9.5 PENALTIES ....................................................................................................67

RULE 9.6 SUMMARY SUSPENSION............................................................................68

RULE 9.7 REPRESENTATION BY COUNSEL.............................................................69

CHAPTER 10 LIMITATION OF LIABILITY; TIME PERIOD IN WHICH TO BRING 

ACTIONS; GOVERNING LAW; ARBITRATION..............................................70

RULE 10.1 LIMITATION OF LIABILITY .....................................................................70

RULE 10.2 ARBITRATION OF MEMBER-MEMBER DISPUTES..............................71

RULE 10.3 ARBITRATION OF NADEX-MEMBER DISPUTES .................................71

RULE 10.4 ARBITRATION OF FCM MEMBER-CUSTOMER DISPUTES ................71

RULE 10.5 FAILURE TO ABIDE BY ARBITRATION DECISION .............................71

RULE 10.6 CHANGE IN ARBITRATION PROCEDURE.............................................71

CHAPTER 11 COMMISSION REGULATIONS THAT HAVE BEEN ADAPTED TO

BE PART OF THE RULES...................................................................................72

RULE 11.1 ACTIVITIES OF SELF-REGULATORY ORGANIZATION 

EMPLOYEES AND GOVERNING MEMBERS WHO POSSESS 

MATERIAL, NON-PUBLIC INFORMATION (ADAPTED FROM

COMMISSION REGULATION 1.59) ...........................................................72

RULE 11.2 SERVICE ON SELF-REGULATORY ORGANIZATION 

GOVERNING BOARDS OR COMMITTEES BY PERSONS WITH 

DISCIPLINARY HISTORIES (ADAPTED FROM COMMISSION

REGULATION 1.63)......................................................................................75

RULE 11.3 VOTING BY INTERESTED MEMBERS OF SELFREGULATORY ORGANIZATION GOVERNING BOARDS AND

VARIOUS COMMITTEES (ADAPTED FROM COMMISSION 
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REGULATION 1.69)......................................................................................77

CHAPTER 12 TERMS OF CONTRACTS TRADED ON NADEX............................................82

RULE 12.1 TERMS THAT ARE UNIFORM ACROSS CONTRACTS ..........................82

RULE 12.2 - 12.3 [RESERVED].......................................................................................84

RULE 12.4 GOLD VARIABLE PAYOUT CONTRACTS...............................................84

RULE 12.5 GOLD BINARY CONTRACTS.....................................................................90

RULE 12.6 SILVER VARIABLE PAYOUT CONTRACTS............................................94

RULE 12.7 SILVER BINARY CONTRACTS................................................................100

RULE 12.8 CRUDE OIL VARIABLE PAYOUT CONTRACTS...................................102

RULE 12.9 CRUDE OIL BINARY CONTRACTS ........................................................109

RULE 12.10 NATURAL GAS VARIABLE PAYOUT CONTRACTS..........................112

RULE 12.11 NATURAL GAS BINARY CONTRACTS................................................119

RULE 12.12 – 12.23 [RESERVED]................................................................................122

RULE 12.24 BITCOIN CRYPTOCURRENCY “TOUCH BRACKET”

VARIABLE PAYOUT CONTRACTS ........................................................122

RULE 12. 25 ETHER CRYPTOCURRENCY “TOUCH BRACKET”

VARIABLE PAYOUT CONTRACTS ........................................................125

RULE 12.26 CURRENCY EXCHANGE AUD/USD VARIABLE PAYOUT 

CONTRACTS...............................................................................................128

RULE 12.27 CURRENCY EXCHANGE AUD/USD BINARY CONTRACTS ............134

RULE 12.28 CURRENCY EXCHANGE EUR/USD VARIABLE PAYOUT 

CONTRACTS...............................................................................................138

RULE 12.29 CURRENCY EXCHANGE EUR/USD BINARY CONTRACTS.............144

RULE 12.30 CURRENCY EXCHANGE GBP/USD VARIABLE PAYOUT 

CONTRACTS...............................................................................................148

RULE 12.31 CURRENCY EXCHANGE GBP/USD BINARY CONTRACTS .............154

RULE 12.32 CURRENCY EXCHANGE USD/CAD VARIABLE PAYOUT 

CONTRACTS...............................................................................................158

RULE 12.33 CURRENCY EXCHANGE USD/CAD BINARY CONTRACTS.............164

RULE 12.34 CURRENCY EXCHANGE USD/CHF VARIABLE PAYOUT 

CONTRACTS...............................................................................................168

RULE 12.35 CURRENCY EXCHANGE USD/CHF BINARY CONTRACTS .............174

RULE 12.36 CURRENCY EXCHANGE USD/JPY VARIABLE PAYOUT 

CONTRACTS...............................................................................................177

RULE 12.37 CURRENCY EXCHANGE USD/JPY BINARY CONTRACTS ..............183

RULE 12.38 CURRENCY EXCHANGE EUR/JPY VARIABLE PAYOUT 

CONTRACTS...............................................................................................187

RULE 12.39 CURRENCY EXCHANGE EUR/JPY BINARY CONTRACTS ..............193

RULE 12.40 CURRENCY EXCHANGE GBP/JPY VARIABLE PAYOUT 

CONTRACTS...............................................................................................197

RULE 12.41 CURRENCY EXCHANGE GBP/JPY BINARY CONTRACTS...............203
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RULE 12.42 CURRENCY EXCHANGE EUR/GBP VARIABLE PAYOUT 

CONTRACTS...............................................................................................206

RULE 12.43 CURRENCY EXCHANGE EUR/GBP BINARY CONTRACTS ............212

RULE 12.44 CURRENCY EXCHANGE AUD/JPY VARIABLE PAYOUT 

CONTRACTS...............................................................................................215

RULE 12.45 CURRENCY EXCHANGE AUD/JPY BINARY CONTRACTS.............220

RULE 12.46 CURRENCY EXCHANGE USD/MXN BINARY CONTRACTS............223

RULES 12.47 - 12.53 [RESERVED]...............................................................................226

RULE 12.54 JAPAN 225 VARIABLE PAYOUT CONTRACTS ..................................226

RULE 12.55 JAPAN 225 BINARY CONTRACTS ........................................................229

RULES 12.56 – 12.57 [RESERVED]..............................................................................233

RULE 12.58 US 500 VARIABLE PAYOUT CONTRACTS..........................................233

RULE 12.59 US 500 BINARY CONTRACTS ...............................................................239

RULE 12.60 US SMALLCAP 2000 VARIABLE PAYOUT CONTRACTS .................243

RULE 12.61 US SMALLCAP 2000 BINARY CONTRACTS .......................................249

RULE 12.62 US TECH 100 VARIABLE PAYOUT CONTRACTS ..............................254

RULE 12.63 US TECH 100 BINARY CONTRACTS....................................................260

RULE 12.64 WALL STREET 30 VARIABLE PAYOUT CONTRACTS .....................264

RULE 12.65 WALL STREET 30 BINARY CONTRACTS ...........................................270

RULES 12.66 – 12.75 [RESERVED] ..........................................................274

RULE 12.76 CORN YIELDS EVENT CONTRACTS ......................................274

RULE 12.77 SOYBEANS YIELDS EVENT CONTRACTS ...............................276

RULE 12.78 CRUDE OIL INVENTORIES CHANGE EVENT CONTRACTS ........277

RULE 12.79 NATURAL GAS NET CHANGE (BCF) EVENT CONTRACTS .........278

RULE 12.80 CONSUMER PRICE INDEX – ALL ITEMS LESS FOOD AND ENERGY 

EVENT CONTRACTS ...........................................................................280

RULE 12.81 CONSUMER PRICE INDEX – FOOD AT HOME EVENT CONTRACTS

........................................................................................................281

RULE 12.82 CONSUMER PRICE INDEX – FOOD AWAY FROM HOME EVENT

CONTRACTS .....................................................................................282

RULE 12.83 CONSUMER PRICE INDEX EVENT CONTRACTS ......................284

RULE 12.84 FEDERAL BALANCE SHEET TOTAL ASSETS (MILLIONS) EVENT

CONTRACTS .....................................................................................285

RULE 12.85 NEW HOME SALES EVENT CONTRACTS ................................286

RULE 12.86 RETAIL SALES CHANGE EVENT CONTRACTS ........................287

RULE 12.87 BITCOIN CRYPTOCURRENCY EVENT CONTRACT ..................289

RULE 12.88 ETHER CRYPTOCURRENCY EVENT CONTRACTS ...................291
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RULES OF NORTH AMERICAN DERIVATIVES EXCHANGE, INC. 

INTRODUCTION

The Commodity Exchange Act (“CEA”) requires that North American Derivatives Exchange, Inc., d/b/a 

crypto.com | Derivatives North America, (“Nadex”) and other contract markets and derivatives clearing 

organizations adopt rules governing the way they conduct their business. Those rules generally must be 

filed with the Commodity Futures Trading Commission (“Commission”) and generally cannot be 

amended without giving notice to the Commission, which can reject proposed rules and proposed 

amendments to existing rules. The following rules are the rules of Nadex (“Rules”) that inform Members 

and others of how the Nadex market (the “Market”) operates and of each Member’s rights and obligations. 

Please remember that these Rules may be amended in the future, and if they are amended, Members will 

be required to abide by the Rules as amended. Nadex will notify all Members any time there is an 

amendment to the Rules.

CHAPTER 1 DEFINITIONS

RULE 1.1 DEFINITIONS

When used in these Rules:

“Affiliate” means any corporate affiliate of Nadex.

“Appeals Panel” means a panel comprised of individuals appointed by the Board to consider 

appeals under Rule 9.3.

“Applicable Law” means with respect to any Person, any statute, law, regulation, rule or 

ordinance of any governmental authority applicable to such Person, including the CEA, CFTC 

Regulations, and the rules or regulations of any relevant Self-Regulatory Organization.

“Authorized Trader” means an individual authorized by an Entity Trading Member and 

approved by Nadex to enter and execute transactions on the Market for that Entity Trading Member’s 

account, provided the Entity Trading Member maintains supervisory authority over such individual’s 

trading activities.

“Binary Contract” means the right to receive a fixed Settlement Value per contract, from Nadex 

on the Settlement Date dependent upon whether the market participant holds a long position or short 

position in a Binary Contract. If the market participant holds a long position in a Binary Contract, the 

participant has the right to receive a fixed Settlement Value from Nadex on the Settlement Date, if, and
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only if, the Binary Contract’s Payout Criteria encompasses the Expiration Value at Expiration. 

Conversely, if the market participant holds a short position in a Binary Contract, the participant has the 

right to receive a fixed Settlement Value if, and only if, the Binary Contract’s Payout Criteria does NOT 

encompass the Expiration Value at Expiration.

“Board of Directors” or “Board” means the Nadex board of directors consisting of eligible 

individuals as further described in Rule 2.2, with the powers enumerated in Rule 2.1.

“Business Day” shall have the same meaning as defined in 31 CFR §802.201, and excludes 

federally recognized holidays as set forth in 5 U.S.C. §6103. The Exchange may offer a limited or full 

listing of contracts on a federally recognized holiday or other non-Business Day, however, the holiday or

other non-Business Day shall still be considered a non-Business Day for purposes of determining the 

Start and End Dates for a contract’s Underlying market.

“Calculation Time” is the time the Expiration Value is calculated.

“Call Spread Contract” is a type of Variable Payout Contract, having a fixed Expiration Date, 

wherein the holder of a Long Call Spread Variable Payout Contract or a Short Call Spread Variable 

Payout Contract may have a right to receive a variable Settlement Value. Such Variable Payout Contracts 

may be classified as “Call Spread(s)” or “Narrow Call Spread(s)”.

“CEA” means the Commodity Exchange Act, as it may be amended from time to time. 

“CFTC” means the U.S. Commodity Futures Trading Commission.

“Ceiling” means the maximum rate, level, amount, measure or other value of the Underlying of a 

Variable Payout Contract that may be the Expiration Value or the Closing Trade Value. If the actual rate,

level, amount, measure, or other value of the Underlying meets or exceeds the Ceiling at Expiration, the 

Ceiling will be the Expiration Value.

“Class” means all Contracts of the same Type with the same Underlying.

“Closing Trade Value” means the rate, level, amount, measure, or other value of a Binary, Call 

Spread, or Touch Bracket at which the Contract is closed in a Member’s or Customer’s account.

“Commission Regulations” means the rules, regulations and interpretations promulgated by the 

CFTC pursuant to the CEA, as in effect from time to time.

“Committee” means a committee established by the Board.

“Commodity Futures Trading Commission” or “Commission” means the Federal regulatory 

agency established by the Commodity Futures Trading act of 1974 to administer the Commodity 

Exchange Act.
8

“Contract” means a Call Spread or Touch Bracket Variable Payout Contract, Knock-out Touch 

Bracket Contract, UpDown Touch Bracket Contract, Knock-out, UpDown Options, Event Contract or a 

Binary Contract.

“Correspondent Account” means an account as that term is defined in 31 CFR 1010.605(c).

“crypto.com | Derivatives North America” is the name under which Nadex may conduct 

business; any reference to crypto.com | Derivatives North America may be substituted with “Nadex” 

without changing the meaning of the term.

“Customer” means a Commodity Customer, a Cleared Swap Customer, a FCM Member or a 

Trading member of Nadex, as the context requires. In this regard,

(i) “Commodity Customer” has the meaning set forth in Commission Regulation 1.3(k);

(ii) “Cleared Swap Customer” has the meaning set forth in Commission regulation 22.1;

(iii) “DCO Customer” has the same meaning as the definition “customer” set forth in 

Commission Regulation 190.01(l) and section 761(9) of the Bankruptcy Code and includes FCM 

Members and Trading Members of Nadex.

“Designated Contract Market” or “DCM” has the meaning set forth in Commission Regulation

1.3.

“Derivatives Clearing Organization” or “DCO” has the meaning set forth in Commission

Regulation 1.3.

“Director” means a member of the Nadex Board of Directors.

“Dollar Multiplier” means the monetary amount by which the rate, level, amount, measure, or 

other value of an Underlying of a Variable Payout Contract is multiplied to determine the Settlement 

Value.

“Emergency” shall have the meaning set forth in Rule 2.4.

“End Date” means the last day on which a delivery month will be used as the Underlying for 

Nadex contracts.

“Entity” means a non-individual Person.

“Event Contract” means a Contracts in an excluded commodity (as defined in Section 1a(19) of 

the Commodity Exchange Act) that is based upon the occurrence, extent of an occurrence, or 

contingency.

“Exchange” means crypto.com | Derivatives North America and its respective successors, by 

merger or otherwise.
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“Expiration” means the time on the Expiration Date established by these Rules at which a 

Contract expires and the Expiration Value of that Contract is determined.

“Expiration Date” means the date established by these Rules on which the Expiration Value of 

each Contract is determined.

“Expiration Value” means the rate, level, amount, measure, or other value of the Underlying at 

Expiration as calculated and/or published by the Source Agency.

“FCM” means a Futures Commission Merchant.

“FCM Member” means any Member that is registered with the Commission as a Futures 

Commission Merchant and as a swap firm and is authorized by Nadex to intermediate orders of 

Commodity Customers or Cleared Swap Customers on the Market.

“Floor” means the minimum rate, level, amount, measure, or other value of the Underlying of a 

Variable Payout Contract that may be the Expiration Value or the Closing Trade Value. If the actual rate, 

level, amount, measure or other value of the Underlying meets or falls below the Floor on the Expiration 

Date, the Floor will be the Expiration Value.

“Foreign Bank” means a bank as that term is defined in 31 CFR 1010.100(u).

“Government Agency” means the CFTC and/or any other governmental agency or department.

“Independent Software Vendor” or “ISV” means any Person that offers services that provide 

access to the Nadex Trading System. In order to provide access to the Nadex Trading System the ISV 

must enter into an ISV Agreement with the Exchange and be approved by the Exchange to provide said 

services.

“Index Value”, also known as an “Indicative Index”, is a value calculated once per second 

throughout a Contract’s duration, which the Source Agency may release as an Expiration Value as 

provided for in the Contract specifications in Chapter 12, or to serve as an indication of the value of a 

Contract’s Underlying at a given point in time.

“Last Trading Day” means, for a particular Contract, the last date on which that Contract may be 

traded on the Market.

“Limit Order” means a request submitted to the Exchange to buy or sell a set number of contracts, 

in a particular product offered by Nadex, at a specified price or better price if a better price is available. 

The following are permissible Nadex Limit Order types, although certain order types may only be 

available on particular platforms or to particular Member types:
10

“Fill or Kill Order” or “FOK” is a Limit Order that will be cancelled if the Order cannot be 

immediately filled in its entirety.

“Immediate or Cancel Order” or “IOC” is a Limit Order that can be filled in whole or in 

part, with any remaining quantity cancelled.

“Good ‘Til Cancel Order” or “GTC” is a Limit Order which will remain on the market until 

it is filled, cancelled, or the contract expires. Any remainder of a partially filled GTC Order 

will stay on the market until it is filled, cancelled, or the contract expires.

“Long Variable Payout Contract” means (i) if the Expiration Value is greater than the Opening

Trade Value, but does not exceed the Ceiling, the right to receive any collateral posted to establish the 

position plus any positive number resulting from subtracting the Opening Trade Value from the Expiration 

Value, and then multiplying that resulting number by the Dollar Multiplier; or (ii) if the Expiration Value 

is greater than the Opening Trade Value and exceeds the Ceiling, the right to receive any collateral posted 

to establish the position plus any positive number resulting from subtracting the Opening Trade Value 

from the Ceiling, and then multiplying that resulting number by the Dollar Multiplier; or (iii) if the 

Expiration Value is less than the Opening Trade Value, but does not exceed the Floor, the right to receive 

any collateral posted to establish the position minus any positive number resulting from subtracting the 

Expiration Value from the Opening Trade Value, and then multiplying that resulting number by the Dollar 

Multiplier; or (iv) if the Expiration Value is less than the Opening Trade Value and exceeds the Floor, the 

right to receive any collateral posted to establish the position minus any positive number resulting from 

subtracting the Floor from the Opening Trade Value, and then multiplying that resulting number by the 

Dollar Multiplier.

“Market Order” means a request submitted to the Exchange to buy or sell a set number of 

contracts, in a particular product offered by Nadex, at the market price. The following are permissible 

Nadex Market Order types, although certain order types may only be available on particular platforms or 

to particular Member types:

“Market Order With Protection” or “MOP” is a Market Order that will attempt to fill, in whole 

or part, at the current displayed price or better, or within a pre-determined number of points (Tolerance 

Protection) worse than the specified display price. The remainder of any Market Order With Protection 

that cannot be immediately filled either at the current displayed price or better, or within the Tolerance 

Protection, will be cancelled.

“Market Maker” means a Member that is granted certain privileges in exchange for assuming 

certain responsibilities as set forth in Chapter 4 of these Rules for the purpose of creating liquidity for 

certain Classes of Contracts.

“Member” means a Person who is approved by Nadex to be a Trading Member or a FCM 

Member and who is bound by these Rules as they may be amended from time to time.
11

“Membership Agreement” is the Nadex Membership Agreement as set forth on the Nadex 

website, to which all Nadex Members agree to comply.

“Midpoint” is the price included in the data set used in the calculation of the Expiration Value of 

a foreign currency contract. A Midpoint is calculated by adding the bid price and the ask price of the 

relevant underlying spot currency market together and then dividing that number by two (2). For example, 

if the bid price is 1.3400 and the ask price is 1.3402, the two numbers are added together (totaling 2.6802) 

and then divided by two (2), equaling a Midpoint of 1.3401. If the spread between a particular bid price 

and ask price is deemed too wide (greater than ten (10) pips), those prices will not be used to calculate a 

Midpoint and will thus not be included within the data set used in the Expiration Value calculation.

“Modification Event” means an event as described in the Market Maker Agreement.

“Nadex” means the abbreviated form of North American Derivatives Exchange, Inc.; any 

reference to “Nadex” may be substituted with crypto.com | Derivatives North America without changing 

the meaning of the term.

“Nadex Trading System” a.k.a. “crypto.com | Derivatives North America Trading System” 

means the electronic trade execution system that is used for trading Contracts, including any licensed 

software that is a part thereof from time to time, and any successor electronic trading system thereto.

“Non Post-Only Order” is an Order that did not originate as a Post-Only Quote.

“North American Derivatives Exchange, Inc.” means the legal entity North American 

Derivatives Exchange, Inc., a Delaware corporation, registered with the Commodity Futures Trading 

Commission as a Designated Contract Market (“DCM”) and Derivatives Clearing Organization (“DCO”), 

that operates a centralized market place under the name crypto.com | Derivatives North America where 

Members can trade certain derivative instruments with each other.

“Officer” has the meaning set forth in Rule 2.3.

“Opening Trade Value” means the rate, level, amount, measure, or other value of a Binary, Call 

Spread, or Touch Bracket at which the Contract is opened in a Member’s or Customer’s account.

“Order” means a request submitted to the Exchange to buy or sell a set number of contracts, in a 

particular product offered by Nadex in accordance with the requirements established by the Exchange.

“Participant” means a Trading Member, FCM Member, an ISV, any Authorized Trader, or any 

Person initiating or executing a transaction on or subject to the Rules of the Exchange directly or through 

an intermediary, or any person who is authorized to access or utilize the Nadex Exchange pursuant to the 

applicable User ID.
12

“Payout Criterion” of a Contract means the Expiration Value or range of Expiration Values that 

will cause that Contract to pay a Settlement Value to the holder of a long position or the holder of a short 

position in such Contract. The holder of a long or short position in a Contract that receives a Settlement 

Value is considered to be “in-the-money” while the holder of either a long or short position in a Contract 

that does NOT receive a Settlement Value is considered to be “out-of-the-money”.

“Person” means an individual, sole proprietorship, corporation, limited liability company, 

partnership, trust, or any other entity, as the context may require.

“Post-Only Quote” is a quote submitted by a Market Maker, which has the potential to become a 

Limit Order if matched for trade execution, and which cannot be executed opposite another Post-Only 

Quote. Post-Only Quotes are either Post-Only (Price Adjustment) or Post-Only (Reject) Quotes.

“Post-Only (Price Adjustment) Quote” is a Post-Only Quote that will be cancelled by the 

Exchange in whole or in part to the extent that at the time it is submitted to the Exchange it would be 

immediately executable opposite another Post-Only Quote. If, some portion of such submitted Post-Only 

(Price Adjustment) Quote would be immediately executable opposite any resting Non-Post Only Order(s), 

that part of such submitted Post-Only (Price Adjustment) Quote will be matched opposite such resting 

Non-Post Only Order(s) by the Exchange. The remaining portion of the submitted Post-Only (Price 

Adjustment) Quote will be cancelled by the Exchange, leaving the opposite Post-Only Quote in the order 

book. Unlike a Post-Only (Reject) Quote, however, upon cancellation of the submitted Post-Only (Price 

Adjustment) Quote, the Exchange will automatically submit an amended quotation for the unfilled balance 

of the cancelled Post-Only (Price Adjustment) Quote at a price level that is adjusted (a) for Binary 

Contracts to four minimum tick increments, and (b) for Variable Payout Contracts to one minimum tick 

increment lower (for bids) or higher (for offers) than the price level of the existing opposite Post-Only 

Quote.

“Post-Only (Reject) Quote” is a Post-Only Quote that will be cancelled by the Exchange in 

whole or in part to the extent that, at the time it is submitted to the Exchange it would be immediately 

executable opposite another Post-Only Quote. If, however, some portion of such submitted Post-Only 

(Reject) Quote would be immediately executable opposite any resting Non-Post Only Order(s), that part 

ofsuch submitted Post-Only (Reject) Quote will be matched opposite such resting Non-Post Only Order(s) 

by the Exchange. The remaining portion of the submitted Post-Only (Reject) Quote will be cancelled by 

the Exchange, leaving the opposite Post-Only Quote in the order book.

“Privacy Policy” is the Nadex Privacy Policy as set forth on the Nadex website, to which all 

Members, FCM customers, and users of the Nadex website agree to comply.

“Regulatory Agency” means any government body, including the Commission and Securities and 

Exchange Commission, and any organization, whether domestic or foreign, granted authority under 

statutory or regulatory provisions to regulate its own activities and the activities of its members, and 

includes Nadex, any other clearing organization or contract market, any national securities exchange or
13

clearing agency, the National Futures Association (“NFA”) and the Financial Industry Regulatory

Authority (“FINRA”).

“Reportable Level(s)” means the aggregate contract level within a product Class at which the 

Exchange must report certain Member and trade information to the Commission pursuant to Commission 

Regulations.

“Risk Disclosure Statement” is the Nadex Risk Disclosure Statement as set forth on the Nadex 

website, to which all Nadex Members agree.

“Rule” means a Rule of Nadex, as applicable to each member type.

“Self-Regulatory Organization” shall mean any futures or securities exchange, derivatives 

clearing organization, securities clearing agency, registered futures association, National Futures 

Association, and the Financial Industry Regulatory Authority.

“Series” means all Contracts of the same Class having identical terms, including Payout Criterion 

and Expiration Date.

“Settlement Date” means the date on which money is paid to the account of a Member who has 

the right to receive money pursuant to a Variable Payout Contract or Binary Contract held until Expiration, 

and on which money is paid from the account of a Member who is obligated to pay money pursuant to a 

Variable Payout Contract held until Expiration. Unless otherwise specified in these Rules, the Settlement 

Date is the same day as the Expiration Date.

“Settlement Value” means the amount which the holder of a Contract may receive for a Contract 

held until Expiration. The Settlement Value of a Binary Contract is $100. The Settlement Value of a 

Variable Payout Contract is determined as described in the definitions of Long and Short Variable Payout 

Contracts.

“Short Variable Payout Contract” means (i) if the Expiration Value is less than the Opening 

Trade Value, but does not exceed the Floor, the right to receive any collateral posted to establish the 

position plus any positive number resulting from subtracting the Expiration Value from the Opening Trade 

Value, and then multiplying that resulting number by the Dollar Multiplier; or (ii) if the Expiration Value 

is less than the Opening Trade Value and exceeds the Floor, the right to receive any collateral posted to 

establish the position plus any positive number resulting from subtracting the Floor from the Opening 

Trade Value, and then multiplying that resulting number by the Dollar Multiplier; or (iii) if the Expiration 

Value is greater than the Opening Trade Value, but does not exceed the Ceiling, the right to receive any 

collateral posted to establish the position minus any positive number resulting from subtracting the 

Opening Trade Value from the Expiration Value, and then multiplying that resulting number by the Dollar 

Multiplier; or (iv) if the Expiration Value is greater than the Opening Trade Value and exceeds the Ceiling, 

the right to receive any collateral posted to establish the position minus any positive number resulting
14

from subtracting the Opening Trade Value from the Ceiling, and then multiplying that resulting number 

by the Dollar Multiplier.

“Source Agency” means the agency that publishes the Underlying economic indicator and/or 

Expiration Value for any Contract.

“Speculative Position Limits,” or “Position Limit” means the maximum position, net long and 

net short combined, in one Series or a combination of various Series of a particular Class that may be held 

or controlled by one Member as prescribed by Nadex and/or the Commission.

“Start Date” means the date on which a new delivery month will be used as the Underlying for 

Nadex contracts.

“Suspension Event” means an event as described in the Market Maker Agreement.

“Terms of Use” are the Nadex Terms of Use as set forth on the Nadex website, to which all Nadex 

Members, FCM customers, and users of the Nadex website agree to comply.

“Tolerance Protection” means the defined number of points, expressed in terms of a dollar 

amount, away from the displayed market price that will be acceptable to fill a Market Order With 

Protection in whole or part, if the displayed market price or a better price is no longer available when the 

Exchange receives the Order.

“Touch Bracket Contract”1is a type of Variable Payout Contract, having a conditional 

Expiration Date on the Last Trade Date established at the time of listing, but which Touch Bracket will 

expire prior to that stated Expiration in the event that, during the life of the Contract, the Index Value 

either (i) equals or is less than the Floor or (ii) equals or is greater than the Ceiling of the Touch Bracket.

“Trade Day” means the regular trading session on any given calendar date and the evening 

session, if any, on the immediately preceding calendar date, as specified in Rule 5.11.

“Trading Member” means a Person who has been approved by Nadex to trade directly and not 

through a FCM Member on the Market, and does not include any FCM Member.

“Type” meansthe classification of a Contract as a Variable Payout Contract or a Binary Contract.

“Underlying” means the index, rate, risk, measure, instrument, differential, indicator, value, 

contingency, occurrence, or extent of an occurrence the Expiration Value of which determines whether 

(and, in the case of a Variable Payout Contract, to what extent) a Contract is in-the-money.

1 Nadex may also refer to its Touch Bracket Contracts as “Knock-out Touch Bracket Contracts” or “UpDown Touch 

Bracket Contracts” or “Knock-outs” or “UpDown Options” from time to time.
15

“US Financial Institution” means a financial institution as that term is defined in 31 CFR 

1010.100(t), subsections (1), (2), and (8), that is required to comply with the regulations issued by the 

United States Department of Treasury under the Bank Secrecy Act including, but not limited to, the antimoney laundering program and customer identification program rules.

“Variable Payout Contract” means a category of contracts wherein the holder of a Long 

Variable Payout Contract or a Short Variable Payout Contract may have a right to a variable Settlement 

Value. Variable Payout Contracts include Call Spread Contracts and Touch Bracket Contracts.

“Volume Threshold Level” means the volume based Reportable Level as established by 

Commission Regulation 15.04.

“Wide Spread Surcharge” means an additional exchange fee imposed on a duly appointed 

Market Maker’s average per lot profit above a specified level, in a given month. Specific details pertaining 

to the Wide Spread Surcharge are set forth in the fee schedule on the Nadex website.

“12PM” or “12:00 PM” means 12:00 Noon.

RULE 1.2 INTERPRETATION

In these Rules, unless the context clearly requires otherwise, (a) words in the singular include the plural 

and words in the plural include the singular, (b) any gender includes each other gender, (c) references to 

statutory provisions include those provisions, and any rules or regulations promulgated thereunder, as 

amended, and (d) all uses of the word “including” should be construed to mean “including, but not limited 

to.” Headings included herein are for convenience purposes only and do not form a part of these Rules.

RULE 1.3 DATE AND TIME REFERENCES

Unless otherwise specified, all references to dates, times or time periods shall refer to, or be measured in 

the Eastern Time zone.

RULE 1.4 CONFLICTS

In the event of a conflict between any Rules of general application and the Rules relating to particular 

types of transactions, the transaction-specific Rules will prevail.

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CHAPTER 2 MARKET GOVERNANCE

RULE 2.1 POWERS OF NADEX’S BOARD OF DIRECTORS

The board of directors of Nadex has the power to manage and direct Nadex including but not limited to 

the power to define the standards for membership in the Exchange and who may access the secure portions 

of Nadex’s website, the power to amend, adopt, or repeal these Rules, and the power to oversee the 

business conduct of Members and impose penalties for violation of these Rules.

RULE 2.2 RESTRICTIONS ON WHO MAY BE MEMBERS OF THE BOARD, MEMBERS OF 

DISCIPLINARY COMMITTEES, MEMBERS OF ARBITRATION OR OVERSIGHT 

PANELS, OR TEN PERCENT OR GREATER OWNERS

Commission Regulation 1.63 prohibits certain individuals who have been charged with, or have been 

found to have committed, disciplinary offenses (as defined in that section) within the past three years from 

serving. No individual subject to disqualification under Commission Regulation 1.63(b) may serve on the 

Nadex Board of Directors, any of its Disciplinary Committees (including serving as compliance officer or 

hearing officer), Appeals Panel, or any other Oversight or Arbitration Panel, each as defined in 

Commission Regulation 1.63, as may be created (collectively, “Panels”). Additionally, any individual 

who may be denied registration, or whose registration may be suspended, restricted or conditioned by the 

CFTC for any reason in accordance with section 8a(2) of the CEA, to the best of Nadex’s knowledge and 

belief after reasonable inquiry, may not serve on the Nadex Board of Directors, nor any of its Disciplinary 

Committees or Panels (including serving as compliance officer or hearing officer). Nadex will not permit 

any individual subject to disqualification under Commission Regulation 1.63(b) to own 10% or more of 

Nadex or to serve as a Nadex hearing officer.

RULE 2.3 OFFICERS OF NADEX

(a) Nadex has a board of directors, consisting of no fewer than five (5) and no more than seven

(7) directors elected by a majority vote of all shareholders of Nadex. Each director serves a one year term. 

Each director, including a director elected to fill a vacancy, shall hold office until his successor is elected 

and qualified or until his earlier resignation or removal.

(b) Nadex has a chief executive officer, secretary, chief financial officer, chief regulatory officer, 

chief compliance officer, and other such officers from time to time as appointed by the board of directors 

or the shareholders (collectively, the “Management Team”). These officers are appointed and may be 

dismissed (with or without cause) by majority vote of the board of directors or the shareholders.

(c) The chief executive officer of Nadex must be a member of the board of directors. In the 

absence of the chairman, the chief executive officer will perform the chairman’s duties. In the event of a
17

disagreement between the chief executive officer and the board or the chairman of the board as to an 

exchange matter, the chairman and/or board shall control.

(d) Subject to the direction of the board of directors, the chief executive officer will manage the 

overall business of the exchange. In the absence of the chief executive officer, the executive officer in 

charge of operations will perform the chief executive officer’s duties.

(e) The chief financial officer of Nadex will be responsible for all funds and stock of Nadex and 

in general perform all duties incident to the office of chief financial officer and such other duties as from 

time to time may be assigned by the chief executive officer or the board of directors. If the function of the 

office of the chief financial officer is outsourced to a service provider, the chief executive officer shall be 

responsible for oversight of this function.

(f) The secretary of Nadex will keep the minutes of the meetings of the board and in general 

perform all duties incident to the office of secretary and such other duties as from time to time may be 

assigned by the chief executive officer or the board of directors.

(g) The chief regulatory officer of Nadex will be responsible for managing the day-to-day 

regulatory functions of the Exchange consistent with the Acceptable Practices for Designated Contract 

Markets under Core Principle 16 of Section 5(d) of the CEA.

(h) The chief compliance officer of Nadex will be responsible for fulfilling the obligations of a 

chief compliance officer of Derivatives Clearing Organizations under the CEA and Commission 

regulations, to the extent such obligations apply to Nadex. The chief compliance officer will report to the 

chief executive officer or such other person or entity as directed by the board of directors.

RULE 2.4 EMERGENCY RULES

(a) Nadex may adopt emergency Rules in response to the emergencies that are described in 

paragraph (c) of this Rule. In the event of one of those emergencies, the board of directors or at least two 

members of the Management Team may, without giving prior notice to, or securing prior approval from, 

the Commission, adopt a temporary emergency rule to address the emergency. Adoption of a temporary 

emergency rule by the board of directors requires the affirmative vote of two-thirds of the members of the 

board at a meeting of the board at which a quorum is present. Nadex may count a member of the board 

of directors who abstains from voting on a temporary emergency rule to determine whether a quorum 

exists. Adoption of a temporary emergency rule by the management team requires the written 

authorization and acknowledgement of two members of the management team, indicating the emergency 

action to be taken and the reasons for that action, before the action is taken.

(b) Any temporary emergency rule adopted under this Rule may authorize Nadex to act as the 

board of directors or management team deems necessary or appropriate to meet the emergency, and those 

actions may adversely affect the ability to trade on the Market. Therefore, the chance of an emergency is 

one of the risks that market participants should consider when deciding whether to trade on the Market.
18

(c) For the purposes of this Rule, an “emergency” is:

(i) any activity that manipulates or attempts to manipulate the Market;

(ii) any actual, attempted, or threatened corner, squeeze, or undue concentration of

positions;

(iii) any circumstance that may materially affect the performance of the Contracts

traded on Nadex, including failure of the payment system or bankruptcy or insolvency of any 

participants;

(iv) any action taken by the United States, any foreign government, any state or 

local governmental body, any other contract market or board of trade, or any other exchange, 

market, facility, or trade association (foreign or domestic) that may have a direct impact on 

trading on Nadex;

(v) any circumstances that may have a severe, adverse impact upon the physical 

functions of Nadex including, for example, natural disasters such as fire or flood, terrorist acts 

such as bomb threats, physical plant breakdowns such as plumbing, heating, or air conditioning 

problems, system breakdowns such as power, telephony, cable, trading systems, or computer 

systems failures or interruptions to communications, the network, or the Internet;

(vi) the imposition of any injunction or other restraint by any government agency, 

court, or arbitrator that may affect the ability of a Member to perform on Contracts;

(vii) any circumstance in which it appears that a Nadex Member or any other person 

is in such operational condition, or is conducting business in such a manner, that such person 

cannot be permitted to continue in business without jeopardizing the safety of Nadex Members 

or Nadex itself; and

(viii) any other unusual, unforeseeable, and adverse circumstance which, in the 

opinion of the governing board, requires immediate action and threatens or may threaten such 

things as the fair and orderly trading in, or the liquidation of or delivery pursuant to Contracts 

traded on Nadex.

(d) If deemed necessary to combat perceived market threats caused by an emergency, a Nadex 

official authorized to do so may suspend trading on the Market during the duration of the emergency or 

take any other action that the official thinks is necessary or appropriate. The official will order an end to 

the action taken in response to the emergency as soon as the official determines that the emergency has 

sufficiently abated to permit the Market to function properly.

(e) Nadex will make every effort practicable to notify the Director of the Division of Market 

Oversight, his delegates, and/or other persons designated by the Commission’s Regulations that Nadex
19

intends to implement, modify, or terminate a temporary emergency rule pursuant to Rule 2.4(a) or an 

action in response to an emergency pursuant to Rule 2.4(d) prior to the implementation, modification, or 

termination of the rule or action. If it is not possible to notify the Commission prior to the implementation, 

modification, or termination of the rule or action, Nadex will notify the Commission of the 

implementation, modification, or termination of the rule or action at the earliest possible time, and in no 

event more than 24 hours after implementation, modification, or termination.

(f) Any time that Nadex takes action in response to an emergency, either under Rule 2.4(a) or 

Rule 2.4(d), Nadex will document its decision-making process and reasons for taking emergency action.

RULE 2.5 COMMITTEES AND SUBCOMMITTEES

(a) The Nadex board of directors may create, appoint members of the board to serve on, and 

delegate powers to, committees and subcommittees.

(b) A majority of any committee or subcommittee will constitute a quorum, and a majority of a 

quorum is necessary for committee or subcommittee action. A committee or subcommittee may act by 

unanimous consent in writing, including by electronic mail, without a meeting.

(c) Nadex’s board of directors shall appoint a Regulatory Oversight Committee comprised of 

board members who are “public directors” as defined in the Acceptable Practices under Core Principle 16 

in Commission Regulation Part 38, Appendix B. The ROC shall oversee Nadex’s regulatory program on 

behalf of the board. The board shall delegate sufficient authority, dedicate sufficient resources, and allow 

sufficient time for the ROC to fulfill its mandate. The ROC shall:

(i) Monitor Nadex’s regulatory program for sufficiency, effectiveness, and 

independence;

(ii) Oversee all facets of the program, including trade practice and market 

surveillance; audits, examinations, and other regulatory responsibilities with respect to member 

firms (including ensuring compliance with financial integrity, financial reporting, sales practice, 

recordkeeping, and other requirements); and the conduct of investigations;

(iii) Review the size and allocation of the regulatory budget and resources; and the 

number, hiring and termination, and compensation of regulatory personnel;

(iv) Supervise Nadex’s chief regulatory officer, who will report directly to the

ROC;

(v) Prepare an annual report assessing Nadex’s self-regulatory program for the

board of directors and the Commission, which sets forth the regulatory program's expenses, 

describes its staffing and structure, catalogues disciplinary actions taken during the year, and 

reviews the performance of disciplinary committees and panels;
20

and

(vi) Recommend changes that would ensure fair, vigorous, and effective regulation;

(vii) Review significant regulatory proposals and advise the board as to whether

and how such changes may impact regulation.

RULE 2.6 VOTING BY INTERESTED BOARD MEMBERS

Core Principle 16 of Section 5(d) of the CEA requires that contract markets have adequate procedures to 

prevent conflicts of interest. In this regard, Nadex has adopted provisions of Commission Regulation 1.69 

as a Rule of Nadex. Commission Regulation 1.69 prohibits a member of the Nadex board of directors or 

any disciplinary or oversight committee or subcommittee from taking part in any deliberations or voting 

on any matter in which the board, committee, or subcommittee member has an interest or has a relationship 

with a named party in interest. Regulation 1.69 also requires disclosure by board, committee, or 

subcommittee members of interests and relationships in certain circumstances. Nadex board, committee,

and subcommittee members shall not deliberate or vote on any matter in which the board, committee, or 

subcommittee member has an interest or has a relationship with a named party in interest and shall disclose 

such interests in accordance with Regulation 1.69. See also Chapter 11 of these Rules.

RULE 2.7 INDEMNIFICATION OF DIRECTORS, OFFICERS, AND OTHERS

Nadex will indemnify to the full extent authorized by law any person who was or is a party or is threatened 

to be made a party to any threatened, pending, or completed action, suit, or proceeding, whether civil, 

criminal, administrative, or investigative in nature, by reason of the fact that such person is or was a 

director, officer, employee, or agent of Nadex or is or was serving at the request of Nadex as a director, 

officer, employee, or agent of Nadex against expenses, including attorneys’ fees, judgments, fines, and 

amounts paid in connection with such action, suit, or proceeding. Such indemnification shall not be 

deemed exclusive of any other rights to which a person may be entitled under any agreement or as a matter 

of law or otherwise. Nadex may purchase and maintain insurance on behalf of any person who is or was 

a director, officer, employee, or agent of Nadex against any liability asserted against such person and 

incurred by such person in any such capacity, or arising out of such person’s status as such, whether or 

not Nadex would have the power to indemnify such person against such liability under the provisions of 

this Rule. However, no person shall be indemnified from liability for fraud, bad faith, willful misconduct, 

or gross negligence. Further, no person shall be indemnified against a civil penalty imposed by the 

Commission under Section 6b of the CEA.

RULE 2.8 PROHIBITION ON USE OF MATERIAL, NON-PUBLIC INFORMATION

(a) Commission Regulation 1.59 prohibits employees and members of the board of directors of 

Nadex from using or disclosing material, nonpublic information gained through their employment or 

board service in certain circumstances. This Rule prohibits the use and disclosure forbidden by
21

Commission Regulation 1.59. In this regard, Nadex has adopted provisions of Regulation 1.59 as a Rule 

of Nadex in Chapter 11 of these Rules.

(b) No member of the board of directors or any committee established by the board of directors 

or these Rules will use or disclose material, nonpublic information obtained as a result of participation on 

the board of directors or such committee for any purpose other than the performance of official duties as 

a board or committee member.

(c) No employee, consultant, or member of the board of directors or any committee of Nadex will 

disclose to any other person material, nonpublic information obtained as a result of such person’s 

employment for purposes inconsistent with such person’s official duties.

(d) No employee, consultant, or member of the board of directors or any committee of Nadex will 

trade for such person’s account, or for or on behalf of any other account, in any commodity interest on the 

basis of any material, non-public information obtained through special access related to the performance 

of such person’s duties as an employee, consultant, or member of the board of directors or committee.

(e) No Member who inadvertently or otherwise comes into possession of any material, non-public 

information held by Nadex or any employee, consultant, or member of the board of directors or any 

committee of Nadex gained through their employment by or service to Nadex will disclose to anyone such 

material, non-public information or trade for such person’s account, or for or on behalf of any other 

account, in any commodity interest on the basis of such material, nonpublic information.

(f) For purposes of this Rule, the terms “material information,” “nonpublic information,” “linked 

exchange”, “commodity interest,” and “related commodity interest” have the same meanings as they do 

in Commission Regulation 1.59.

(g) Any director, officer, or employee of Nadex who violates any provision of this Rule will be 

required to indemnify Nadex for any losses, damages, or costs caused by that violation.

RULE 2.9 LIMITATION ON TRADING BY AFFLIATES

Except for any duly authorized Market Maker, no Affiliate of Nadex nor any employee thereof may trade 

on any Nadex Market for such Affiliate’s or employee’s own account. This rule does not prohibit an 

Affiliate of Nadex properly registered as a Futures Commission Merchant from becoming a FCM Member 

of the Exchange and acting as an intermediary for its customers on the Exchange. Exchange jurisdiction 

over the Person, as well as the Person’s agreement to be bound by the Nadex Rules and obligation of 

cooperation and participation in investigatory and disciplinary processes, shall continue beyond the 

revocation or termination of the Person’s trading privileges with respect to any transactional or Rulerelated matter involving the Person, occurring before the revocation or termination of trading privileges, 

regardless of whether the matter was discovered prior to or after the revocation or termination of the 

Person’s trading privileges.
22

RULE 2.10 CONSENT TO JURISDICTION

Any Participant, Person initiating or executing a transaction on or subject to the Rules of the Exchange 

directly or through an intermediary, and any Person for whose benefit such a transaction has been initiated 

or executed, expressly consents to the jurisdiction of the Exchange and agrees to be bound by and comply 

with the Rules of the Exchange in relation to such transactions, including, but not limited to, rules requiring 

cooperation and participation in investigatory and disciplinary processes. Any futures commission 

merchant, introducing broker, associated person, independent software vendor or foreign Person 

performing a similar role, that charges a commission or fee in connection with transactions on or subject 

to the Rules of the Exchange also expressly consent to the Exchange’s jurisdiction. The consent to 

jurisdiction under this Rule shall continue notwithstanding a termination of any Person’s membership.

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23

CHAPTER 3 MEMBERS

RULE 3.1 TRADING MEMBERS - APPLICATIONS, CLASSIFICATIONS, AND PRIVILEGES

(a) To be eligible to become a Trading Member:

(i) An applicant who is an individual, must:

1) provide Nadex with any information or documentation Nadex 

deems necessary in order to verify the applicant’s identity, perform a criminal 

background check, or otherwise review information provided on an Application for 

Membership or by a third party provider2;

2) (A) have an account(s) in the Trading Member’s name with a US 

Financial Institution that the Trading Member will use to fund its Nadex account at the 

Nadex settlement bank, and to receive funds from its Nadex account, or,

(B) have a verified account(s) at a Financial Institution or Foreign 

Bank (or other similarly authorized institution that has been vetted by Nadex and 

received pre-approved written authorization from Nadex that it is an acceptable means 

of deposit) held in the Trading Member’s name that the Trading Member will authorize 

per transaction to deposit funds to the Trading Member’s Nadex account at the Nadex

settlement bank by means of a registered money services business.; or

(C) have an account(s) as described in subsections (A) or (B) or an 

account(s) in the Trading Member’s name with a Foreign Bank capable of transacting 

with Nadex’s settlement bank either directly, through a Correspondent Account, or 

other acceptable intermediary that the Trading Member will use to fund its Nadex 

account at the Nadex settlement bank, and to receive funds from its Nadex account via 

one of the acceptable methods as stated on the Nadex website3; and

3) certify that

(A) the applicant is old enough to enter into a legally enforceable 

contract and has reached the required age as stated on the Membership Agreement;

2 Required documentation may vary depending on the applicant’s residential location. Specific residential 

locations from which Nadex may accept applications for Membership will be identified on the Nadex 

Membership application.

3 All funds deposited into the Trading Member’s Nadex account at the Nadex settlement bank shall be in U.S. 

dollars. All withdrawal payments from the Trading Member’s Nadex account will also be made in U.S. dollars.
24

(B) the applicant has read, understands and agrees to comply with 

the Nadex Rules, Risk Disclosure Statement, Terms of Use, Privacy Policy, and 

Membership Agreement;

(C) the applicant agrees to be bound by these Rules; and

(D) the applicant will trade only for itself and will not trade as an 

intermediary for any other person or entity.

(ii) An applicant that is an Entity must

(1) be organized in the United States;

(2) provide Nadex with a valid Taxpayer Identification Number;

(3) provide Nadex with a valid legal entity identifier as described in 

Commission Regulation §45.6;

(4) have an account or accounts in the Entity Trading Member’s name with 

a Financial Institution that the Entity Trading Member will use to fund its Nadex 

account at the Nadex settlement bank, and to receive funds from its Nadex account, via 

one of the acceptable methods as stated on the Nadex website; and

(5) designate Authorized Trader(s) to trade its account and agree that such 

Authorized Trader(s) will trade only for it and will not trade for him/herself or as an 

intermediary for any other entity or person;

(6) designate at least one officer who is responsible for supervising all 

activities of its employees relating to transactions effected on Nadex or subject to 

Nadex Rules and provide any information Nadex may request regarding such officer(s);

(7) agree to be bound by these Rules; and

(8) certify that

(A) the applicant is validly organized, in good standing, in the

United States;

(B) the applicant is authorized by its governing body and, if relevant,

documents of organization, to trade commodities, swaps, futures and options contracts, 

and
25

(C) the applicant has read, understands and agrees to comply with 

the Nadex Rules, Risk Disclosure Statement, Terms of Use, Privacy Policy, and 

Membership Agreement.

(b) In order to become a Trading Member, an applicant who is an individual must complete and 

submit the Nadex on-line membership application, provide Nadex with any other information Nadex may 

request, and fund its Nadex account by making a deposit of funds belonging to the individual applicant 

from the individual applicant’s account at a US Financial Institution, or as otherwise provided for in 

subsection (a)(i)(2) of this Rule, to the appropriate segregated Cleared Swap Proprietary Account at 

Nadex’s settlement bank. An applicant who is an Entity must complete an Account Certification, 

Membership Agreement, and W-9, which collectively shall constitute the membership application, 

provide Nadex with any other information Nadex may request, and fund its Nadex account by making a 

deposit of funds belonging to the entity applicant from the entity applicant’s account at a Financial 

Institution to the appropriate segregated Cleared Swap Proprietary Account at Nadex’s settlement bank. 

All funds deposited by Trading Members shall constitute “Member Property” in accordance with CFTC 

Regulations.

(c) Submission of a membership application to Nadex constitutes the applicant’s agreement to be 

bound by these Rules and other policies of Nadex.

(d) If an application is approved by Nadex and the Nadex settlement bank confirms to Nadex that 

the applicant has made a successful initial deposit in accordance with paragraph (b) of this Rule, the 

applicant will be a Trading Member of Nadex and will have the following privileges, which Nadex may 

revoke, amend, or expand in accordance with, or by amending, these Rules:

(i) to maintain a Nadex account;

(ii) to buy Contracts on the Market using the funds in its Nadex account;

(iii) to sell Contracts on the Market using the funds in its Nadex account;

(iv) to view “real-time” the same best bids to buy and offers to sell the Contracts traded on 

the Market as are available to all other Members;

(v) to view the current trading volume and open interest for the Contracts traded on the 

Market; and

(vi) to view all non-secure parts of the Nadex website, including these Rules, and 

descriptions of Contracts traded on the Market as well as all secure parts of the Nadex website 

outlined above in Rule 3.1(d)(i) – (vi).

(e) Nadex may in its sole discretion approve, deny, or condition any Member application as Nadex 

deems necessary or appropriate.
26

(f) A Trading Member that is an individual, may not maintain and/or trade more than one Nadex 

account. No Authorized Trader(s), nor any officer, director, member, manager, owner, or indirect owner, 

of an Entity Trading Member may maintain a separate Nadex account and/or trade any Nadex account 

other than that Entity’s account.

RULE 3.2 FCM MEMBERS - APPLICATIONS, CLASSIFICATIONS, AND PRIVILEGES

(a) To be eligible to become a FCM Member, an applicant must:

(i) be validly organized, in good standing, in the United States;

(ii) be registered as a Futures Commission Merchant by the National Futures Association;

(iii) have adequate financial resources and credit as determined by Nadex;

(iv) have an account or accounts with a Financial Institution designated as a settlement 

bank by Nadex;

(v) designated at least one officer who is responsible for supervising all activities of its 

employees relating to transactions effected on the Nadex or subject to Nadex Rules and 

provide any information Nadex may request regarding such FCM Member;

(vi) submit to Nadex a letter confirming that the applicant will maintain all Customer funds 

deposited with it in connection with trading any Nadex Contracts in appropriately labeled 

and segregated Cleared Swaps Customer Accounts separated from funds of both the FCM 

Member and futures customers, as required by Commission regulations;

(vii) agree to be bound by these Rules; and

(viii) meet any other criteria or complete any additional applications that Nadex may 

request.

(b) Prior to becoming a FCM Member, FCM Member applicants must submit to Nadex:

(i) a guarantee agreement on a form prescribed by Nadex defining the FCM Member’s 

obligation to guarantee the applicant’s transactions and those of the applicant’s Customers, 

signed by the FCM Member; and

(ii) an agreement authorizing Nadex to unilaterally debit any accounts identified per Rule 

3.2(a)(iv) in accordance with Nadex’s rules, policies and procedures and in amounts solely 

determined by Nadex.

(c) Nadex may in its sole discretion approve, deny, or condition any FCM Member application as 

Nadex deems necessary or appropriate.
27

(d) If an FCM Member application is approved by Nadex, the applicant will be a FCM Member 

of Nadex and will have the following privileges:

(i) to intermediate Customer transactions on Nadex;

(ii) to distribute Nadex data to its Customers pursuant to any data distribution agreement 

with Nadex; and

(iii) to access Nadex’s trading systems electronically via a FIX connection (Internet – SSL 

only).

RULE 3.3 MEMBER OBLIGATIONS

(a) Each Member and any Authorized Trader(s) thereof, must comply with these Rules, applicable 

provisions of the Commodity Exchange Act, and relevant Commission regulations. Each Member and 

any Authorized Trader(s) thereof must also cooperate promptly and fully with Nadex, its agents, and/or 

the Commission in any investigation, call for information, inquiry, audit, examination, or proceeding. 

Such cooperation shall include providing Nadex with access to information on the activities of such 

Member and/or Authorized Trader in any referenced market that provides the underlying prices for any 

Nadex market. Additionally, each Member must update its e-mail address within 24 hours after any 

change and update all other information provided in its application for membership within five days after 

that information has changed. If any Member or Authorized Trader(s) thereof fail to satisfy these 

obligations, Nadex may revoke or suspend the Member’s privileges in full or in part. Each Member may 

also be subject to civil or criminal prosecution.

(b) Each Member consents to allow Nadex to provide all information Nadex has about the 

Member, including the Member’s trading activity, to the Commission or any other Regulatory Agency, 

law enforcement authority, or judicial tribunal, including (as may be required by information sharing 

agreements or other contractual, regulatory, or legal provisions) foreign regulatory or self-regulatory 

bodies, law enforcement authorities, or judicial tribunals.

(c) Each Member and each Member’s Authorized Trader(s) are required to review the “Notices” 

section of the Nadex website to make itself aware of material changes to these Rules or other notices that 

may affect your rights and obligations as a Member of Nadex.

(d) Each Member must immediately notify Nadex in writing upon becoming aware:

(i) that the Member, any of the Member’s officers or any of the Member’s Authorized 

Traders has had access or trading privileges suspended, or membership denied, in any commodity, 

securities, or swaps exchange, brokerage, association, or Regulatory Agency;
28

(ii) that the Member, any of the Member’s officers or any of the Member’s Authorized 

Traders has been convicted of, pled guilty or no contest to, or entered a plea agreement to, any 

felony in any domestic, foreign or military court;

(iii) that the Member, any of the Member’s officers or any of the Member’s Authorized 

Traders has been convicted of, plead guilty or no contest to, or entered a plea agreement to a 

misdemeanor in any domestic, foreign or military court which involves:

(1) embezzlement, theft, extortion, fraud, fraudulent conversion, forgery, 

tax evasion, counterfeiting, false pretenses, bribery, gambling, racketeering, or 

misappropriation of funds, securities or properties; or

(2) any transaction in or advice concerning swaps, futures, options on 

futures, leveraged transactions or securities;

(iv) that the Member, any of the Member’s officers or any of the Member’s Authorized 

Traders has been subject to, or associated with a firm that was subject to regulatory proceedings 

before any governmental or Regulatory Agency;

(v) that the Member, any of the Member’s officers or any of the Member’s Authorized 

Traders is currently a party to any investigation or proceeding, the resolution of which could result 

in an event described in Rule 3.3(d)(i)-(iv);

(vi) of any other material change in any information contained in the Member’s 

membership application;

(vii) of any failure to segregate or maintain adequate Customer funds as required by the 

Commission when the Member is a FCM Member;

(viii) of becoming subject to early warning reporting under Commission Regulation 1.12;

(ix) of becoming the subject of a bankruptcy petition, receivership proceeding, or the 

equivalent, or being unable to meet any financial obligation as it becomes due; or

(x) of information that concerns any financial or business developments that may 

materially affect the Members’ ability to continue to comply with participation requirements.

(e) Each Member must diligently supervise all activities of the Member’s employees and/or 

agents, including all Authorized Traders, relating to transactions effected on Nadex. Any violation of 

these Rules by any employee of a Member may constitute a violation of the Rules by such Member.

(f) A Member is not required to engage in trading activity or maintain a minimum balance in its 

account after initial funding. If a Member does not engage in any trading activity or maintain a positive
29

balance for a period of one year, however, that Member’s account and membership may be terminated. A 

Person whose membership is terminated pursuant to this provision may re-apply for membership at any 

time following such termination.

RULE 3.4 FCM MEMBER OBLIGATIONS

In addition to the obligations applicable to all Members, FCM Members shall have the following 

obligations:

(a) Each FCM Member must at all times maintain the financial resources at or in excess of the 

amount prescribed by Nadex from time to time as a FCM Member of Nadex. FCM Members may maintain

two settlement accounts at Nadex. One settlement account will contain cleared swaps customer collateral 

and will be held separately from the members’ property and from the funds of such FCM Member held

for futures trading (“Cleared Swaps Customer Account”), while the other settlement account will hold 

Member Property of the FCM Member (“Cleared Swaps Proprietary Account”).

(i) As futures commission merchants, all FCM Members must comply with the financial 

and reporting requirements set forth by the Commission and the National Futures Association, 

including the requirements contained in Commission Regulations 1.10 and 1.17.

(ii) Cleared Swaps Customer Account

(1) The Cleared Swaps Customer Account will contain separate position 

accounts for each FCM Member Customer.

(2) Each FCM Member shall be required to make an initial deposit of at 

least $100,000 of funds constituting the FCM’s residual interest therein, into its 

FCM Member Cleared Swaps Customer Account for excess collateral with Nadex.

(3) If the available balance of the FCM Member’s residual interest in the 

Cleared Swaps Customer Account falls below $50,000, the FCM Member must 

promptly deposit additional funds into the account to increase the available balance 

of such residual interest to at least $100,000.

(4) FCM Member cannot withdraw funds from its residual interest in the 

Cleared Swaps Customer Account if, after such withdrawal, the available residual 

interest balance would be lessthan $100,000 except on termination of Membership.

(iii) Cleared Swaps Proprietary Account

(1) The Cleared Swaps Proprietary Account will contain separate position 

accounts for any error accounts and test accounts of the FCM Member and/or any 

personal trading accounts of APs/employees. For the purposes of this Rule 3.4, 

“APs/employees” includes all associated persons (“APs”) and employees of the
30

FCM Member, as well as those of the FCM Member’s guaranteed introducing 

brokers (“GIBs”).

(2) Except as set forth herein, a FCM Member shall treat an account of an 

AP/employee like an account of a FCM Member Customer. An AP/employee shall 

deposit funds with the FCM Member sufficient to fully collateralize all orders given 

by the AP/employee to the FCM Member prior to submission of such orders to the 

Exchange. Such funds, if and when transferred to Nadex, will be held by Nadex in 

the Cleared Swaps Proprietary Account. A FCM Member will be required to ensure 

that the AP/employee has on deposit with the FCM Member enough funds to fully 

collateralize the AP’s/employee’s orders before any such order is submitted to 

Nadex.

(b) Each FCM Member must submit statements of financial condition at such times and in such 

manner as shall be prescribed from time to time.

(c) Each FCM Member must maintain a separately identifiable position account for each 

Customer and provide the identifier for such account with every order submitted to Nadex.

(d) Each FCM Member must use due diligence in receiving and handling orders from Customers, 

submitting such orders onto Nadex on behalf of such Customers, responding to inquiries from Customers 

about their orders and reporting back to Customers the execution of such orders.

(e) Each FCM Member must maintain policies and procedures acceptable to Nadex that:

(i) with respect to each FCM Customer who is an individual, restricts access to any system 

through which such individual Customer submits orders to the FCM Member for transmission to 

Nadex to that individual Customer; and

(ii) with respect to each FCM Customer who is not an individual:

(1) restricts access to any system through which the Customer’s orders may 

be submitted to the FCM Member for transmission to Nadex to such individuals 

authorized to enter orders on behalf of such Customer;

(2) requires each FCM Customer who is not an individual to have and 

maintain a CFTC Interim Compliant Identifier or such other Legal Entity Identifier 

deemed acceptable under CFTC regulations, which shall be provided to Nadex with 

each order message submitted by such Person; and

(3) identifies each individual authorized to enter orders on behalf of such 

Customer by a distinct user identification code, which shall be provided to the FCM 

Member and Nadex with each order message submitted by such Person; and
31

(4) requires the customer to maintain and provide to the FCM Member or 

Nadex upon request by the FCM Member or Nadex information identifying any 

individual who has entered orders on behalf of such Customer’s account, including 

but not limited to the individual’s name, taxpayer or other identification number, 

affiliation to the Customer, address and contact information.

(f) No FCM Member may maintain a proprietary trading account for Nadex contracts. 

Notwithstanding the foregoing, a FCM Member may maintain error accounts and/or test accounts.

(g) An AP/employee may trade Nadex contracts for his or her personal account under the following 

circumstances:

(i) All such trading of Nadex contracts by an AP/employee shall occur in a trading account 

held by the FCM Member with which he or she is registered or employed (or, in the case of an AP or 

an employee of a GIB, the FCM Member who guarantees that IB). No AP/employee may be a direct 

(i.e., non-intermediated) Trading Member of Nadex or maintain an interest in or control the trading in 

the account of any direct Trading Member of Nadex.

(ii) The FCM Member must notify Nadex in writing, prior to permitting the FCM 

Member’s AP/employee to submit orders to the Exchange, of the AP’s/employee’s name and account 

identifier.

(iii) The FCM Member must notify Nadex immediately, in writing, in the event that the 

FCM Member’s AP/employee is no longer registered and/or employed by the FCM Member.

(h) Prior to a FCM Member accepting any orders from a Customer for submission to Nadex, a FCM 

Member must first have provided such Customer with the Nadex Risk Disclosure Statement.

(i) Prior to a FCM Member accepting any orders from a Customer for submission to Nadex, Nadex

will require certification by the FCM Member to Nadex that its system has the capacity to block cleared 

swaps customer collateral in accordance with the requirements of Rule 5.5(b) and demonstrate that 

capacity to Nadex. In addition, on an annual basis or as otherwise required by Nadex, each FCM Member 

must represent to Nadex that the portion of the FCM Member’s system that blocks cleared swaps customer 

collateral has not been changed in any material respect or, if the system has been changed, the FCM 

Member must identify any such changes and recertify the system’s capacity to block cleared swaps 

customer collateral in accordance with the requirements of Rule 5.5(b). Finally, each FCM Member agrees 

to submit to any compliance review by Nadex of its systems in this regard.

(j) With respect to the APs/employees of a FCM Member:

(i) Each FCM Member shall be responsible for diligently supervising the FCM Member’s 

AP’s/employee’s compliance with all Exchange rules.
32

(ii) Each FCM Member must maintain a complete and accurate list of all APs/employees 

of the FCM Member. Such list shall be promptly provided to the Exchange upon request.

(iii) APs/employees must comply with Exchange rules. Each AP/employee shall be bound 

by Exchange rules to the same extent as if such person were a member.

(iv) Each FCM Member shall be responsible for the acts or omissions of the FCM 

Member’s APs/employees, and may be liable for any fines imposed upon such APs/employees by 

the Exchange. Any violation of an Exchange rule by any such AP/employee may be considered a 

violation by the FCM Member.

(k) Each FCM Member must make and file reports in accordance with Commission Regulations 

in a manner and form and at such times as may be prescribed by the Commission.

(l) Each FCM Member must make and file reports with Nadex at such times, in such manner and 

form, and containing such information as Nadex may prescribe from time to time.

(m) Each FCM Member, upon a request of Nadex or any Regulatory Agency, must promptly 

respond to any requests for information.

(n) Each FCM Member may invest cleared swaps customer collateral only in accordance with 

Commission Regulations 22.2(e)(1) and 1.25.

(o) Each FCM Member must prepare, maintain and keep current those books and records 

required by the rules of Nadex, the CEA and/or the Commission’s Regulations. Such books and records 

shall be open to inspection and promptly provided to Nadex, its Designated Self Regulatory Organization 

(“DSRO”), the Commission and/or the U.S. Department of Justice, upon request.

RULE 3.5 SUPERVISION

Each Member and such Member’s designated supervisor must diligently supervise its Related Parties, 

Authorized Traders, partners, directors, officers, agents, contractors, representatives, and employees. For 

purposes of this Rule 3.5, Member means a non-individual Member of the Exchange, including an Entity 

Trading Member, a FCM Member, or a Market Maker.

Such Member must establish, maintain and enforce reasonable supervisory procedures to demonstrate 

compliance with Applicable Laws and the Rules of the Exchange.

Such Member or its designated supervisor may be held directly or jointly liable for violations of any Rules 

of the Exchange by such Related Parties, Authorized Traders, partners, directors, officers, agents, 

contractors, representatives, and employees, regardless of whether the Member or designated supervisor
33

is held responsible for the act or acts constituting the violation. Such Member or its designated supervisor 

will also be jointly liable for the payment of any resulting fines of any Rules of the Exchange.

RULE 3.6 AUTHORIZED TRADERS

(a) An Entity Trading Member must register one or more individuals who will be Authorized 

Trader(s) for the Entity Trading Member’s account, who are subject to approval by Nadex. The Entity 

Trading Member and the Authorized Trader must provide Nadex with any information it requests in 

connection with this registration process. Before an Authorized Trader may enter orders or execute trades 

on the Market, he/she must acknowledge having read and understood these Rules and agree to comply 

with these Rules. Only those individuals authorized by the Entity Trading Member and approved by 

Nadex may enter and execute transactions on the Market for the Entity Trading Member’s account. Any 

Authorized Trader engaging in activity on the market may do so using only that Authorized Trader’s 

unique username and login credentials.

(b) Nadex may withdraw or suspend the registration of any Authorized Trader if Nadex 

determines that;

(i) an Authorized Trader has caused the Entity Trading Member to fail to comply 

with the Rules of Nadex;

(ii) an Authorized Trader is not properly performing the responsibilities of an 

authorized representative of a Trading Member;

(iii) an Authorized Trader has failed to comply with the conditions set forth in 

paragraph (a) of this Rule; or

(iv) it is in the best interests of maintaining a fair and orderly market to do so.

(c) If the Entity Trading Member withdraws or Nadex suspends the registration of any Authorized 

Trader, the Trading Member must ensure that such Authorized Trader does not submit any quotes or 

orders into the Nadex system.

(d) The registration of an Authorized Trader will be withdrawn upon the written request of either 

the Authorized Trader or the Entity Trading Member for which an Authorized Trader is registered. Such 

written request shall be submitted in a manner prescribed by Nadex. Until such written request is received 

and processed by Nadex, or an Authorized Trader’s registration is suspended or withdrawn pursuant to 

paragraph (c) of this Rule, an Entity Trading Member will be responsible for all activity of such 

Authorized Trader(s) related to Nadex.
34

RULE 3.7 REJECTION OF APPLICANT AND LIMITATIONS OF TRADING PRIVILEGES

(a) Notwithstanding Nadex’s authority granted under any other Rule, Nadex may, in its sole 

discretion, deny any Member application, or suspend, revoke, limit, condition, restrict, or 

qualify the trading privileges of any account owner pursuant to this Section (a) or authorized 

trader of an account owner as it deems necessary or appropriate4.

(b) An account owner or an authorized trader of an account owner who has had trading privileges 

limited pursuant to Section (a) of this Rule will be provided, in writing, the reason such action 

was taken.

(c) If Nadex denies the membership application of any Person or places limitations on trading 

privileges pursuant to this section, the applicant, account owner or authorized trader whose 

trading privileges have been limited may appeal the decision by filing with the CEO of Nadex 

a petition for review of such membership denial or trading limitation. The petition should 

describe in detail the reasons why the membership application should be granted or trading 

limitations removed. The petition must be filed within thirty (30) calendar days from the date 

upon which notice of the denial of membership or limitation of trading privileges was provided 

by Nadex. The decision of the CEO will be final. A Person that has been denied membership 

by the CEO will not be eligible for reapplication during the six months immediately following 

such denial.

(d) If trading privileges are limited pursuant to Section (a) of this Rule, Nadex may initiate a 

transfer of the Member’s balance to the bank account on record.

RULE 3.8 COMMUNICATIONS BETWEEN NADEX AND MEMBERS AND OTHER 

PARTICIPANTS

Each Member must provide Nadex with its current electronic mail address and immediately (and in any 

event within 24 hours) update that address whenever it changes. All communications between Nadex, its 

Members, and other Participants, including confirmation of all transactions executed where applicable, 

may be transmitted by electronic mail and/or posted on the Nadex website in the English (American) 

language. Members and other Participants are responsible for promptly reviewing and, if necessary, 

responding to all electronic communications from Nadex.

4

Please reference Notice 851.042117 in the Notices section of the Nadex website for an informational Q&A page regarding 

this Rule.
35

RULE 3.9 DUES, FEES, AND EXPENSES PAYABLE BY MEMBERS

(a) Members are not required to pay dues.

(b) Members may be charged fees in connection with the trading of Contracts in an amount to be 

reflected from time to time on Nadex’s website.

(c) Members may be charged fees for settlement of Contracts at Expiration in an amount to be 

reflected from time to time on Nadex’s website.

(d) Members may be charged an inactivity fee after a period of account dormancy as reflected 

from time to time on Nadex’s website.

(e) Nadex or its settlement bank may also deduct from the Member’s account fees or expenses 

incurred in connection with the Member’s trading or account activity or Nadex’s administration in 

connection with that activity, such as fees for wire transfers, check processing via electronic check. All 

such fees will be charged in an amount to be reflected from time to time on Nadex’s website.

(f) If Nadex determines in the future to impose dues or additional fees, the Member will be 

provided notice of the change at the time the amended fees are filed with the Commission. The new fee 

structure will be implemented no earlier than on the first available trade date for which the change may 

be implemented according to the Commission’s self-certification filing requirements as set forth in 

Commission Regulation §40.6(a).

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36

CHAPTER 4 MARKET MAKERS

RULE 4.1 REGISTRATION OF MARKET MAKERS

(a) Only Trading Members in good standing who are not individuals may become a Market Maker 

of Nadex. A Member shall file a written Market Maker Application with Nadex. Nadex shall consider 

such factors as business reputation, financial resources and trading activity in relevant swaps, futures, 

options or related cash markets in determining whether to approve a Market Maker Application.

(b) The designation of any Market Maker may be suspended or terminated by Nadex at any time 

and for any reason.

RULE 4.2 APPOINTMENT OF MARKET MAKERS

(a) Nadex shall appoint Market Makers to certain Classes of Contracts (“Designated Classes”) 

traded on Nadex. In making such appointments, Nadex shall consider (i) the financial resources available 

to the Market Maker, and (ii) the Market Maker’s experience in market making in futures, options and 

other derivative products.

(b) No appointment of a Market Maker to a Designated Class shall be made without the Market 

Maker’s consent to such appointment, provided that refusal to accept appointment to a Designated Class 

may be deemed sufficient cause for denial, suspension, or termination of registration as a Market Maker.

(c) Nadex may suspend or terminate any appointment of a Market Maker to a Designated Class 

and may appoint more than one Market Maker to the same Designated Class.

(d) Nadex may periodically conduct an evaluation of any Market Maker to determine whether it 

has fulfilled performance standards relating to, among other things, quality of the markets, competitive 

market making, observance of ethical standards, and administrative soundness. If the Market Maker fails 

to meet minimum performance standards, Nadex may, among other things, (i) suspend, terminate or 

restrict the Market Maker’s appointment to a particular Designated Class, (ii) restrict the Market Maker 

from appointments to additional Designated Class(es),or (iii) suspend, terminate or restrict the Market 

Maker’s registration as such.

RULE 4.3 BENEFITS OF BECOMING A MARKET MAKER

(a) Market Makers will have access to Nadex via the FIX gateway for an additional fee to be 

determined by Nadex. Market Makers may connect via the FIX Gateway over the Internet or dedicated 

private circuit. Use of dedicated private circuit is only permitted for the submission of quotes.
37

(b) Market Makers may receive reduced trading fees as an incentive for fulfilling the obligations 

of a market maker. For example, trading fees for Market Maker transactions via the FIX gateway may be 

less than other Trading Member fees via the FIX gateway.

(c) Market Makers shall have access to a designated group of operational and technical specialists 

at Nadex who handle issues relating to Market Makers.

RULE 4.4 OBLIGATIONS OF MARKET MAKERS

(a) General – Transactions of Market Makers should constitute a course of dealings reasonably 

calculated to contribute to the maintenance of a fair and orderly market, and Market Makers shall not 

make bids or offers or enter into transactions that are inconsistent with such a course of dealings. 

Ordinarily, Market Makers shall be obligated to do the following:

(i) trade for the proprietary account of the Market Maker only;

(ii) maintain at least the minimum capital on deposit with Nadex in accordance with the 

terms of the applicable Market Maker Agreement;

(iii) comply with all other terms of the applicable Market Maker Agreement; and

(iv) maintain two-sided displayed quotes, insofar as required by the Market Maker 

Agreement, of a minimum designated quantity (“Size”) within a predefined spread (“Bid/Ask 

Spread”) for a Series of Contracts for a certain period of time throughout the trading day, and 

comply with all other terms of the applicable Market Maker Agreement.

(1) In ordinary market conditions, quotes must be made within a maximum 

Bid/Ask Spread.

(2) The Market Maker Agreement sets forth specific conditions under 

which a Market Maker is permitted to refrain from quoting binding bid and offer 

prices.

(b) A Market Maker has a continuous obligation to engage, to a reasonable degree under the 

existing circumstances, in dealings for the account of the Market Maker when there exists, or it is 

reasonably anticipated that there will exist, a lack of price continuity or a temporary disparity between the 

supply of and demand for quotations in a Series of a Designated Class to which the Market Maker is 

appointed. Without limiting the foregoing, a Market Maker is expected to perform the following activities 

in the course of maintaining a fair and orderly market;

(i) To post bid and ask quotations in all Designated Classes to which the Market Maker is 

appointed that, absent changed market conditions, will be honored by the Market Maker.
38

(ii) To update quotations in response to changed market conditions in all Designated 

Classes to which the Market Maker is appointed.

(iii) All Market Maker quotations shall be submitted as “Post-Only Quotes”. A Market 

Maker is not permitted to submit Non Post-Only Orders.

(iv) In the event a Market Maker has built a position size equal to or greater than 90% of 

any applicable position limit in a particular Class or Contract, Market Maker is temporarily 

relieved of its quoting obligation for such Class or Contract until Market Maker’s position 

in such Class or Contract has been reduced to 75% of the applicable position limit, at which 

time quoting obligations as set forth in the Market Maker Agreement will resume.

(c) Like other Members of Nadex, a Market Maker may not attempt to execute a trade unless it 

has the excess funds in its Nadex account necessary to fully collateralize its obligations of the trade.

(d) Approved Market Makers who are engaged in bona fide market-making activity shall not be 

subject to the normal contract position limits, but rather will be subject to alternative market maker 

position limits as specified in each Contract’s specifications in Chapter 12 of this Rulebook. A Market 

Maker taking advantage of an alternative market maker position limit must, within 1 Business Day 

following a request by Nadex’s Compliance Department, provide the Nadex Compliance Department with 

a trade register detailing all trading activity in any account owned or controlled by the Market Maker in 

any relevant Underlying market during the 15 minutes immediately before and after any expiration time 

identified by Nadex’s Compliance Department.

(e) Duly appointed Market Makers may be charged a Wide Spread Surcharge as set forth in the 

fee schedule.

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39

CHAPTER 5 METHOD FOR MEMBERS TO TRADE CONTRACTS

RULE 5.1 PRIOR REVIEW OF RISK DISCLOSURE STATEMENT AND THESE RULES AND 

ACCEPTANCE OF TERMS OF MEMBERSHIP AGREEMENT IS REQUIRED

(a) Trading Member Applicants: No Person may become a Trading Member of Nadex or trade 

any Contracts on the Market unless such Person has received, read, understood, and accepted the Nadex 

Risk Disclosure Statement, Terms of Use, Privacy Policy, these Rules, and the Nadex Membership 

Agreement for Trading Members, and has certified having have done so.

(b) FCM Member Applicants: No entity may become a FCM Member of Nadex or intermediate 

the trading of any Contracts on the Market unless such entity has received, read, understood, and accepted 

these Rules, Terms of use, Risk Disclosure Statement, Privacy Policy, and the Nadex Membership 

Agreement for FCM Members, and has certified having done so.

(c) Customers of FCM Members: No Person may be permitted by a FCM Member to enter orders 

or otherwise engage in any Nadex trading activity as a customer of that FCM Member unless such FCM 

Member has obtained certification from the customer that the customer has received, read, understood, 

and accepted these Rules, Risk Disclosure Statement, Privacy Policy, and the Terms of Use.

RULE 5.2 TRADING MEMBER AND AUTHORIZED TRADER ACCESS TO NADEX

(a) During the Nadex membership application process, an applicant to become a Trading Member 

will be required to choose a user identification (“ID”) and password. The applicant will be required to 

enter the ID and password to log onto and access secure portions of the Nadex website. Each time the 

applicant submits its unique user ID and password to Nadex in order to log onto Nadex, the applicant 

affirms that it understands and agrees to be bound by these Rules and other policies of Nadex, as amended.

(b) After an applicant’s membership application has been approved by Nadex and the applicant 

has deposited the requisite amount of funds into its account as specified under Rule 3.1(b), the applicant 

becomes a Trading Member. As a Trading Member, such Person will be able to access the Market, execute 

trades, and otherwise access information regarding, or perform functions in, such Person’s account using 

its ID and unique password.

(c) Each Authorized Trader shall maintain a unique ID and password, separate from the ID and 

password belonging to the Entity Trading Member and from any other Authorized Trader of the Entity 

Trading Member, in order to access the markets and engage in activity on behalf of its Entity Trading 

Member.
40

(d) For account security and audit trail purposes, each Trading Member agrees that Nadex may 

maintain logs of its IP address, and the IP address of any Authorized Trader, used to access the Nadex 

website.

(e) Each Trading Member will be responsible for protecting its ID and password, and with respect 

to an Entity Trading Member, the ID(s) and password(s) of its Authorized Trader(s), from improper 

disclosure. In addition, a Trading Member may not knowingly or negligently permit any Person not 

authorized by Nadex and by the Trading Member to use the ID and password to access the secure portion 

of the Nadex website. An Entity Trading Member and its Authorized Trader(s) are prohibited from 

allowing any other person or entity from using these credentials to access the Nadex markets. Each 

Trading Member is required to immediately notify Nadex if it knows, or has reason to believe, that its ID 

or the ID and/or password of any Authorized Trader have been disclosed to any Person not authorized by 

Nadex and the Trading Member to use such ID and/or password. Under any circumstances, the Trading 

Member will be deemed to know that such ID and/or password have been disclosed to an unauthorized 

person 12 hours after any order is entered by that unauthorized person in your account.

(f) Each Trading Member will be liable for all costs and any losses that it may incur from 

transactions executed on Nadex by any person, authorized or not, using its ID and password or the ID 

and/or password of any Authorized Trader. Nadex will not be responsible in any way for unauthorized 

transactions in a Trading Member’s account.

(g) Each Trading Member is responsible for contracting with an Internet service provider through 

which it will access the Nadex website and for having a backup service provider if the Trading Member 

thinks it is necessary. Each Trading Member is also responsible for maintaining an Internet connection 

speed adequate for its needs. Nadex will not be responsible in any way for any orders delayed or trades 

missed or not executed in a timely fashion because of failure of the Trading Member’s Internet service 

provider or slowness of its Internet connection speed. No communication from a Trading Member will be 

deemed to have been received by Nadex until that communication is logged by the Nadex server.

(h) Nadex in its discretion may place a Trading Member’s account on hold (prohibiting any order 

activity) or on hold-liquidation only (allowing only orders to liquidate existing positions). In such 

circumstances, Nadex will promptly notify the affected Trading Member of the nature of and reason for 

the action.

RULE 5.3 TRADING CONTRACTS – TRADING MEMBERS

(a) Trading Members will be able to trade (1) Variable Payout Contracts by entering bids or 

offers at prices based on the values or levels of the Underlying at which they are willing to open a Long 

Variable Payout Contract or a Short Variable Payout Contract and (2) Binary Contracts by entering bids 

to purchase or offers to sell those Contracts at which Trading Members are willing to open or close a 

long position in a Binary Contract or open or close a short position in a Binary Contract. After logging 

into the secure portion of the Nadex website, the Trading Member will input its orders into the Nadex 

trading system.
41

(b) When a Trading Member’s order is matched by an order from another Member(s);

(i) If the Trading Member’s order is to enter into one or more Variable Payout 

Contracts for which that Trading Member does not have an offsetting position in its account, 

Nadex will check its account to ensure it has enough funds to cover its maximum loss under 

the Variable Payout Contract(s) it is attempting to enter into. If the Trading Member does 

not have the necessary funds in its account, Nadex will cancel its order prior to trade 

execution. If the Trading member does have the necessary funds in its account, Nadex will 

execute the trade. Upon trade execution, Nadex will: (1) debit the funds from the Trading 

Member’s account in an amount necessary to cover the maximum loss, (2) credit that amount 

to the Nadex settlement account, and (3) place the Variable Payout Contracts that were the 

subject of the executed trade into the Trading Member’s account and (4) notify the Trading 

Member by electronic mail that the trade has been executed. The maximum amount that the 

Trading Member can lose under a Long Variable Payout Contract (and, therefore, the amount 

that will be debited from its account and then paid into the Nadex settlement account) is 

determined by subtracting the Floor from the Opening Trade Value and then multiplying the 

resulting figure by the Dollar Multiplier. The maximum amount that a Trading Member can 

lose under a Short Variable Payout Contract is determined by subtracting the Opening Trade 

Value from the Ceiling and then multiplying the resulting figure by the Dollar Multiplier.

(ii) If the transaction involves entering into one or more Variable Payout 

Contracts for which the Trading Member has an offsetting position in its account (for 

example, entering into a Short Variable Payout Contract of a Series when the Trading 

Member has a Long Variable Payout Contract of that same Series in its account), upon 

execution of the trade Nadex will: (1) close the offsetting position in the Trading Member’s 

account; (2) debit the Nadex settlement account in the amount of (A) any gains realized by 

the offsetting transaction; and (B) any funds that were debited from the Trading Member’s 

account at the time the Variable Payout Contract(s) that is being closed was entered into and 

that were not also used to pay any losses on such Contract(s); (3) credit those amounts to the 

Trading Member’s account; and (4) notify the Trading Member by electronic mail that the 

trade has been executed.

(iii) If the Trading Member’s order is to enter into one or more Binary Contracts 

for which it does not have an offsetting position in its account, Nadex will check the Trading 

Member’s account to ensure it has enough funds to cover its maximum loss under the Binary 

Contract(s) it is attempting to enter into. If the Trading Member does not have the necessary 

funds in its account, Nadex will cancel its order prior to trade execution. If the Trading 

Member does have the necessary funds in its account, Nadex will execute the trade. Upon 

trade execution, Nadex will: (1) debit the funds from the Trading Member’s account in an 

amount necessary to cover the maximum loss, (2) credit those funds to the Nadex settlement 

account, and (3) place the Binary Contracts that were the subject of the order into the Trading 

Member’s account and (4) notify the Trading Member by electronic mail that the trade has
42

been executed. The maximum amount that a Trading Member can lose under a long position 

in a Binary Contract (and, therefore, the amount that will be debited from the Trading 

Member’s account and then paid into the Nadex settlement account) is determined by the 

price at which the Trading Member entered into the long Binary Contract. The maximum 

amount that the Trading Member can lose under a short position in a Binary Contract is 

determined by subtracting the price at which it sold the position short from the Binary 

Contract’s Settlement Value. For example, if a Trading Member enters into a short position 

in a Binary Contract with a $100 settlement Value at a trade price of $40, the Trading 

Member’s maximum loss on that position would be $60 ($100- $40 = $60).

(iv) If the transaction involves entering into one or more Binary Contracts for 

which a Trading Member has an offsetting position in its account (for example, selling a 

position in a Binary Contract of a Series when the Trading Member is long a Binary Contract 

of that same Series in its account), upon execution of the trade Nadex will: (1) close the 

offsetting position in the Trading Member’s account; (2) debit the Nadex settlement account 

in the amount of (A) any gains realized by the offsetting transaction; and (B) any funds that 

were debited from the Trading Member’s account at the time the Binary Contract(s) that is 

being closed was entered into and that were not also used to pay any losses on such 

Contract(s); (3) credit those amounts to the Trading Member’s account; and (4) notify the 

Trading Member by electronic mail that the trade has been executed.

(c) If a Trading Member’s order is placed on the market and not immediately matched by an order 

from another Member, it will rest on the market until it is matched and executed in accordance with the 

procedures outlined above in this Rule, until the Member cancels it, or until it is cancelled by Nadex upon 

the Expiration of the Series or otherwise in accordance with these Rules.

RULE 5.4 TRADING CONTRACTS – CUSTOMERS OF FCM MEMBERS

(a) Nonmembers of Nadex will be able to trade Nadex Contracts only as Customers of an FCM 

Member and all Customer orders must be transmitted to Nadex from each Customer’s FCM Member. 

Each FCM Member shall maintain a secure connection to Nadex and comply with all technical and other 

requirements established by Nadex for this purpose.

(b) Each FCM Member shall maintain a separate Nadex Position Account for the positions of each 

of its Customers and will indicate, when submitting any orders to Nadex, the Customer Position Account 

for which the order is submitted, as well as any other information required by Nadex.

(c) FCM Members will be able to submit orders for their customers (“FCM Customer Orders”) to 

trade (1) Variable Payout Contracts by submitting bids or offers at prices at which the Customer is willing 

to open a Long Variable Payout Contract or a Short Variable Payout Contract and (2) Binary Contracts 

by entering bids to purchase or offers to sell those Contracts at which the Customer is willing to open or 

close a long position in a Binary Contract or open or close a short position in a Binary Contract.
43

(d) For purposes of this Rule, “settlement account” refers to the FCM Cleared Swaps Customer 

Account if the orders/trades are placed in a FCM Member’s Customer Position Account. “Settlement 

account” refers to the FCM Cleared Swaps Proprietary Account if the orders/trades are placed in a FCM 

test, error, or AP/employee Position Account.

(e) When a FCM Customer Order is matched by an order from another Member(s):

(i) If the FCM Customer Order is to enter into one or more Variable Payout 

Contracts for which that Customer does not have an offsetting position in its FCM Customer 

Position Account, Nadex will check the FCM settlement account to ensure it has enough funds 

to cover the maximum loss under the Variable Payout Contract(s) that the FCM Customer is 

attempting to enter into. If the FCM settlement account does not have the necessary funds for 

that trade, Nadex will cancel the FCM Customer Order prior to trade execution. If the FCM 

settlement account does have the necessary funds, Nadex will execute the trade. Upon trade 

execution, Nadex will: (1) debit the funds from the FCM settlement account in an amount 

necessary to cover the maximum loss, (2) credit that amount to the Nadex settlement account,

(3) place the Variable Payout Contracts that were the subject of the executed trade into the FCM 

Customer Position Account, and (4) notify the FCM Member by FIX message that the trade has 

been executed. The maximum amount that the FCM Customer can lose under a Long Variable 

Payout Contract (and, therefore, the amount that will be debited from the FCM settlement 

account and then paid into the Nadex settlement account) is determined by subtracting the Floor 

from the Opening Trade Value and then multiplying the resulting figure by the Dollar Multiplier. 

The maximum amount that the FCM Customer can lose under a Short Variable Payout Contract 

is determined by subtracting the Opening Trade Value from the Ceiling and then multiplying the 

resulting figure by the Dollar Multiplier.

(ii) If the transaction involves entering into one or more Variable Payout Contracts 

for which the FCM Customer has an offsetting position in its FCM Customer Position Account 

(for example, entering into a Short Variable Payout Contract of a Series when the FCM Customer 

has a Long Variable Payout Contract of that same Series in its FCM Customer Position Account), 

upon execution of the trade Nadex will: (1) close the offsetting position in the FCM Customer 

Position Account; (2) debit the Nadex settlement account in the amount of (A) any gains realized 

by the offsetting transaction; and (B) any funds that were debited from the FCM settlement 

account at the time the Variable Payout Contract(s) that is being closed was entered into and that 

were not also used to pay any losses on such Contract(s); (3) credit those amounts to the FCM 

settlement account; and (4) notify the FCM Member by FIX message that the trade has been 

executed.

(iii) If the FCM Customer Order is to enter into one or more Binary Contracts for 

which that Customer does not have an offsetting position in its FCM Customer Position Account, 

Nadex will check the FCM settlement account to ensure it has enough funds to cover its 

maximum loss under the Binary Contract(s) it is attempting to enter into. If the FCM settlement
44

account does not have the necessary funds for that trade, Nadex will cancel the FCM Customer 

Order prior to trade execution. If the FCM settlement account does have the necessary funds, 

Nadex will execute the trade. Upon trade execution, Nadex will: (1) debit the funds from the 

FCM settlement account in an amount necessary to cover the maximum loss, (2) credit those 

funds to the Nadex settlement account, (3) place the Binary Contracts that were the subject of 

the order into the FCM Customer Position Account and (4) notify the FCM Member by FIX 

message that the trade has been executed. The maximum amount that the FCM Customer can 

lose under a long position in a Binary Contract (and, therefore, the amount that will be debited 

from the FCM settlement account and then paid into the Nadex settlement account) is determined 

by the price at which the FCM Customer entered into the long Binary Contract. The maximum 

amount that the FCM Customer can lose under a short position in a Binary Contract is determined 

by subtracting the price at which it sold the position short from the Binary Contract’s Settlement 

Value. For example, if a FCM Customer enters into a short position in a Binary Contract with a

$100 Settlement Value at a trade price of $40, the FCM Customer’s maximum loss on that 

position would be $60 ($100 - $40 = $60).

(iv) If the transaction involves entering into one or more Binary Contracts for 

which that Customer has an offsetting position in its FCM Customer Position Account (for 

example, selling a position in a Binary Contract of a Series when the Customer is long a Binary 

Contract of that same Series in its FCM Customer Position Account), upon execution of the trade 

Nadex will: (1) close the offsetting position in the FCM Customer Position Account; (2) debit 

the Nadex settlement account in the amount of (A) any gains realized by the offsetting 

transaction; and (B) any funds that were debited from the FCM settlement account at the time 

the Binary Contract(s) that is being closed was entered into and that were not also used to pay 

any losses on such Contract(s); (3) credit those amounts to the FCM settlement account; and (4) 

notify the FCM Member by FIX Message that the trade has been executed.

(f) If a FCM Customer Order is placed on the market and not immediately matched by an order 

from another Member, it will rest on the market until it is matched and executed in accordance with the 

procedures outlined above in this Rule, until the FCM Customer cancels it, or until it is cancelled by 

Nadex upon the Expiration of the Series or otherwise in accordance with these Rules.

RULE 5.5 ORDER ENTRY

(a) Trading Member Orders

(i) A Trading Member, who is not engaged in activity pursuant to a Market Maker 

Agreement, will enter orders to trade Contracts by electronic transmission over the Internet. 

Order rate limiter functionality will cap the maximum number of orders that may be submitted 

to the Exchange per second (or per a specific time period expressed in seconds) per Trading 

Member or Authorized Trader of a Trading Member, in order to prevent a risk of harm to the 

Exchange. Similarly, Nadex may limit the number of messages submitted to the Exchange for 

the same purpose.
45

(ii) A Trading Member will enter an order to trade one or more Contracts by 

indicating to Nadex in the manner required by Nadex: (1) order direction (i.e., buy or sell); (2) 

order type (e.g., Limit Order or Market Order); (3) duration of the order (e.g., Fill or Kill, 

Immediate or Cancel, Good ‘Til Cancel); (4) the Series of Contract; (5) the limit price at which 

the Trading Member wants to buy or sell the Contract, in the case of Limit Orders; (6) the number 

of Contracts the Trading Member want to buy or sell, and (7) the Tolerance Protection in the 

case of Market Orders With Protection.

(iii) In order to enter an order to trade one or more Contracts, a Trading Member will 

be required to submit the order to Nadex. Once the order is accepted by Nadex, Nadex will assign 

to the order an order confirmation number. This confirmation number will appear next to the 

associated order on the Trading Member’s Order Ticket and Order History account pages. The 

Trading Member will be responsible for any and all order entries confirmed for its account and 

accepted by Nadex.

(iv) Any Member submitting orders, or any other messages directly to the Exchange, 

including but not limited to messages related to the cancellation or amendment of an order, 

whether manually or via automated functionality, must ensure adequate controls are in place to 

prevent excessive messaging or other activity that may be deemed detrimental or disruptive to 

the Exchange.

(b) FCM Customer Orders

(i) A FCM Customer may not submit orders directly to the Exchange and all such 

order must be submitted by that Customer’s FCM Member.

(ii) FCM Members may submit FCM Customer Orders by electronic transmission 

over a FIX Connection by Internet (SSL only), in accordance with Nadex’s applicable policies 

and procedures.

(iii) FCM Members will submit a FCM Customer Order to trade one or more 

Contracts by indicating to Nadex in the manner required by Nadex: (1) order direction (i.e., buy 

or sell); (2) order type (e.g., Limit Order or Market Order); (3) duration of the order (e.g., Fill or 

Kill, Immediate or Cancel, Good ‘Til Cancel); (4) the Series of Contract; (5) the limit price at 

which the FCM Customer wants to buy or sell the Contract, in the case of Limit Orders; (6) the 

number of Contracts the FCM Customer wants to buy or sell; (7) the Tolerance Protection in the 

case of Market Orders With Protection; (8) the FCM Customer Position Account identifier; and

(8) the user identifier for the person who directed the submission of the order to the Exchange.

(iv) Upon receipt of a FCM Customer Order to trade one or more Contracts, a FCM 

Member will be required to ensure that the FCM Customer has on deposit with the FCM Member 

enough funds to cover the FCM Customer’s maximum loss under the Contract(s) it is attempting 

to enter into before the order is submitted to Nadex. When the order has been submitted to and
46

accepted by Nadex, Nadex will assign to the order an order confirmation number. This 

confirmation number will appear next to the associated order on the FCM Member’s Order and 

Order History account pages. The FCM Member will be responsible for any and all order entries 

confirmed for its FCM Customer Position Accounts and its settlement accounts and accepted by 

Nadex.

(c) Nadex’s trading system will keep an electronic record of all orders to trade Contracts, and all 

executed Contract trades. The records kept by Nadex will include all of the terms identified in paragraphs 

(a)(ii) – (iii) and (b)(iii) – (iv) of this Rule as well as the date and time that the transaction was completed 

to the nearest tenth of a second, for all executed Contract trades and to the nearest second for all orders to 

trade Contracts.

RULE 5.6 RECORDKEEPING OF FCM CUSTOMER ORDERS

(a) FCM Members shall maintain an electronic record of all FCM Customer Orders to trade 

Contracts received by the FCM Member, and all order, trade and expiration confirmations received by the 

FCM Member regarding its customer’s accounts.

(b) Other than the electronic record required in subpart (a) of this rule, no FCM Member is 

required to create or maintain any separate record for FCM Customer Orders received by a Member or 

Authorized Trader which are immediately entered onto the Nadex system, unless otherwise required by 

these Rules. However, if a FCM Member receives a Customer order that cannot be immediately entered 

into the Nadex system, such Member or Authorized Trader must prepare a written record of the order and 

include the account designation, date and time of receipt and order instructions, including price, quantity 

and order type information. The written record of the order shall be time-stamped when received and 

appropriately indicate when (i) the order was submitted, (ii) confirmation of execution or cancellation 

after expiration and/or (iii) the order was cancelled in whole or in part.

(c) All time-stamps required under Rule 5.6(b) must show the time to the nearest minute.

(d) All written orders and any other original records pertaining to orders entered through the 

Nadex system must be retained by the FCM Member for no less than five years. For orders that were 

entered immediately upon receipt into the Nadex system, the electronic records required in subpart (a) of 

this rule shall be deemed the original records of the transaction.

RULE 5.7 HANDLING OF CUSTOMER ORDERS

(a) Withholding Orders Prohibited. No FCM Member or AP/employee thereof may withhold or 

withdraw from the market any order or any part of an order for the benefit of any Person other than the 

Person placing the order.

(b) Disclosing Orders Prohibited
47

(i) It is a violation of this Rule 5.7 for any Person to disclose another Person’s order 

to buy or sell any Contracts except as may be requested by Nadex or the Commission.

(ii) It is a violation of this Rule 5.7 for any Person to take action or direct another 

Person to take action based on non-public order information, however acquired.

(c) Trading Against Customer Orders Is Prohibited

(i) No FCM Member or AP/employee thereof in possession of a FCM Customer 

Order may enter into a transaction opposite such FCM Customer Order directly or indirectly for 

him/herself or any other Person with whom such FCM Member or AP/employee has a direct or 

indirect financial interest.

(d) Trading Ahead (Front-running) of Customer Orders Is Prohibited

(i)No FCM Member or AP/employee thereof in possession of a FCM Customer 

Order to be submitted to the Exchange shall enter an order to buy or sell in the same product for 

its/his own account or an account in which it/he has a direct or indirect financial interest.

RULE 5.8 TRANSFER TRADES AND ADJUSTED ORDERS

(a) A FCM Member may transfer a trade in any Contracts on the Exchange from one FCM 

Customer account to another account i) within the same FCM Member or ii) to another FCM Member, 

provided that the transfer would not result in a change in beneficial ownership in any Contract, unless the 

transfer is made in order to:

(i) correct an error in a previously executed transaction, in which case the FCM 

Member must be able to provide evidence of such error in a form prescribed by Nadex;

(ii) reflect a change in ownership occurring by operation of law due to the death or 

bankruptcy of a Person having an ownership interest in such Contract; or

(iii) facilitate a merger, consolidation, disposition of a line of business, 

reorganization, or similar event affecting such Person.

(b) A Member that transfers a Contract trade shall notify Nadex of the transfer in a manner and 

form as prescribed by Nadex.

(c) Transfers of FCM Customer trades shall be made at the historic price at which such 

transactions were executed.

(d) A FCM Member may not adjust the price at which an order was executed and will not be held 

responsible for executing or failing to execute an order unless such FCM Member was negligent or is 

settling a bona-fide dispute regarding negligence.
48

(e) A FCM Member may not be compelled to make an adjustment in the absence of a bona-fide 

dispute regarding negligence.

(f) FCM Members shall document all adjustments. FCM Members shall make and retain a record 

which contains the date the adjustment was received, the name of the person making the adjustment, the 

account to which the adjustment was credited, the amount of the adjustment, the order number and the 

reason for the adjustment. Such records must be provided to the Compliance department upon request.

RULE 5.9 DISPUTED ORDERS

(a) If a Member or a FCM Customer believes that an order to trade one or more Contracts was 

incorrectly executed or rejected by Nadex that Member or FCM Customer may request review of the order 

by providing the confirmation number for the order and stating the grounds for its disagreement with the 

handling of the order.

(b) Upon receipt of a request for review of an order and the accompanying confirmation number, 

Nadex will review its electronic audit trail to determine if the Nadex trading system correctly interpreted 

and executed the order.

(c) If the review described in paragraph (b) of this Rule reveals that the Nadex trading system 

made a mistake, the order will be cancelled and the accounts of all Members, including any FCM 

Customer Position Accounts, that were party to the order will be returned to their state before the trade 

was executed.

(d) If the review described in paragraph (b) of this Rule reveals that the Nadex trading system did 

not make a mistake, Nadex will inform the Person who requested the review of its determination that the 

order was properly handled, the evidence supporting that determination, and that an adjustment will not 

be made.

(e) A Trading Member or an FCM Member on behalf of a Customer may appeal a determination 

under paragraph (d) of this Rule to a Nadex compliance officer through the electronic mail address 

provided on the Nadex website. The Member making the appeal will be required to provide a response to 

the evidence described in paragraph (d) of this Rule that the order was properly handled, and the Member 

may provide any other information it wishes to disclose. If the Member’s appeal does not contain a 

response to the evidence described in paragraph (d), it will be rejected. The compliance officer will decide 

the appeal no later than 10 days after its receipt, and that decision will be final.

(f) Nadex will document in writing all requests for review of orders received by Nadex, the time 

and manner in which Nadex reviewed its electronic audit trail in response to the request, the outcome of 

that review, and the action or actions taken by Nadex in response to that review, including the results of 

any appeal filed under paragraph (e) of this Rule and the review conducted by the compliance officer in 

deciding that appeal.
49

RULE 5.10 ACCEPTABLE ORDERS

(a) A Member who is not a Market Maker may enter only Non-Post Only Orders (that is, any 

acceptable Order other than a Post-Only Quote as set forth in the definition of “Order” in Section 1.1 of 

this Rulebook) to trade Contracts on the Market.

(b) Duly appointed Market Makers who are making markets pursuant to such appointment shall 

submit market maker quotations as Post-Only Quotes. “Post-Only Quotes” are quotes that provide 

liquidity to a market in that they can be matched opposite any Non-Post Only Order submitted by a 

Member, but cannot be matched opposite another Post-Only Quote submitted by another Market Maker. 

For example, like a Good ‘Til Cancel Order, a Post-Only Quote is an offer to buy or sell the number of 

Contracts specified at the price specified, or a better price if a better price is available. However, unlike 

a Good ‘Til Cancel Order, Post-Only Quotes will not be matched opposite another Post-Only Quote. PostOnly Quotes can be submitted in one of two forms: Post-Only (Reject) and Post-Only (Price Adjustment) 

Quotes, as those terms are defined in Section 1.1.

RULE 5.11 PRIORITY OF ORDERS

Subject to the provisions of rule 5.10(b) regarding Post-Only orders, the Market’s trading algorithms 

execute all trades by matching orders according first by price and then time priority. This means that 

orders and quotes entered at different prices will be executed in order of price, from best to worst, 

regardless of what time they were placed on the Market, and orders and quotes placed on the Market at 

the same price will be executed in order of time, from oldest to most recent.

RULE 5.12 FILLING ORDERS TO TRADE CONTRACTS

Subject to the provisions of Rule 5.10(b) regarding Post-Only Quotes, the Nadex trading system will fill 

all orders to trade Contracts on an “or better” basis. This means that if a Member places an order to buy 

a Contract or Contracts at a price higher than the price of the best sell offer on the market, the system will 

fill that order to buy at the better sell offer price(s) until all available sell offers under or equal to that buy 

order’s limit price are filled or until that buy order is completely filled. Likewise, if a Member enters a 

sell order at a price lower than the price of the best bid, the system will fill that sell order at the better bid 

price(s) until all available bids over that sell order’s limit price are filled or that sell order is completely 

filled. If an order is only partially filled, the unfilled portion of that order will remain in the order book 

as a resting order at the limit price specified. Should an opposite order at the same price or better than the 

original order subsequently be placed in the system, the unfilled portion of the original order will be 

executed opposite that new order at the original order’s limit price.
50

RULE 5.13 MODIFICATION AND CANCELLATION OF ORDERS

(a) A Member can submit instructions to either cancel or modify an order which that Member has 

placed on the Market if that order has not yet been executed. Upon submission of instructions to either 

cancel or modify an order that has not been executed, the Nadex system will withdraw the order from the 

order book and confirm the cancellation of the order. If a Member seeks to amend an order, Nadex will 

provide the Member with the details of the existing order and the Member will be allowed to change any 

part of the order except the Underlying. Nadex will then provide a new order confirmation number and 

inform the Member that the system will treat the modified order as a new order, causing the amended 

order to lose its original time priority.

(b) Nadex will attempt to modify or cancel an existing order as soon as possible after a Member 

enters a modification or cancellation instructions. However, the order may be executed before Nadex is 

able to cancel or modify it. If an order has been filled in whole or in part, a Member may modify or cancel 

only that portion of the order (if any) that has not been executed.

RULE 5.14 TRADE CANCELLATIONS

(a) As a designated contract market, Nadex hasthe authority to adjust trade prices or cancel trades 

when necessary to mitigate market disrupting events caused by malfunctions in its electronic trading 

platform(s) or errors in orders submitted by Members and market participants. However, due to the fully 

collateralized and short-term nature of trading on Nadex, the circumstances in which this authority will 

be exercised are limited.

(b) Nadex, in its discretion and in accordance with these Rules, may cancel a trade in a Variable 

Payout Contract that has been executed on the market at a price that is inconsistent with prevailing market 

conditions due to improper or erroneous orders or quotes being matched on the Market (“Erroneous 

Trade”). With respect to Binary Contracts, Nadex will generally not cancel or adjust an Erroneous Trade 

except in extraordinary circumstances as determined by the Exchange.

(c) Nadex may review a Variable Payout Contract trade based on its own analysis of the Market 

or pursuant to a request for review by a Member or other third party. A request for a review by a Member 

or other third party must be received by Nadex no later than fifteen (15) minutes after the trade has been 

executed on the Market and before the expiration of the contract. Nadex will promptly determine whether 

the trade will be subject to review and then promptly post notice indicating that the trade is under review.

(i) During the review, Nadex will calculate a Fair Value for the underlying at the time of 

the questioned trade by utilizing the last value or price of the Underlying at the time of the 

trade and/or any other relevant market information obtained or presented to Nadex.

(ii) Once a Fair Value has been calculated, 5 percent of the maximum contract value will 

be added above such Fair Value and below such Fair Value to determine the “No Bust 

Range”. In the event that the Fair Value is less than 5 percent above the Floor or below
51

the Ceiling, the No Bust Range shall be a 10 percent range above the Floor or below the 

Ceiling. During conditions which would qualify as either a Suspension Event or 

Modification Event, or in other circumstances in which Nadex determines it is appropriate, 

Nadex may, without prior notice, temporarily double the No Bust Range.

(iii) If Nadex determines that a trade has been executed within the No Bust Range, the 

executed trade will stand. If Nadex determines that a trade has NOT been executed within 

the No Bust Range, Nadex will promptly cancel the trade by busting the Erroneous Trade 

off the market. Once the Erroneous Trade has been cancelled, Nadex shall:

(A) notify the Members that were parties to the Erroneous Trade(s) that 

Nadex has cancelled the Erroneous Trade(s). Nadex will notify such 

Members within thirty (30) minutes from receiving notice of the Erroneous 

Trade unless impractical to do so within the notice period.

(B) publish all necessary price corrections in a notification on the Nadex 

website.

(iv) The decisions of Nadex regarding Fair Value of the underlying, the No Bust Range, the 

doubling of the No Bust Range, the cancellation of an Erroneous Trade, or any other determination 

hereunder shall be final and not subject to appeal.

RULE 5.15 INVALIDATION OF ORDERS UPON SUSPENSION OR REVOCATION OF FCM 

MEMBER STATUS

(a) Upon suspension or revocation of a FCM Member by Nadex, any open order on the Market 

for such FCM Member’s Customer shall be cancelled by Nadex.

RULE 5.16 INVALIDATION OF TRADES UPON SUSPENSION OR REVOCATION OF FCM 

MEMBER STATUS

(a) Upon suspension or revocation of a FCM Member by Nadex, any trade subsequently executed 

on the Market for such FCM Member’s Customer shall be invalid. Nadex shall cancel any transaction 

pursuant to this Rule by entering a counter transaction onto the Market at the price at which the cancelled 

transaction was effected.

RULE 5.17 VIEWING THE MARKET AND EXECUTED ORDERS

Nadex will allow its Members to view the current best bid and offer on the Market, as well as the depth 

of the order book up to the fifth level of prices.
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RULE 5.18 HOURS FOR TRADING CONTRACTS

The Market will be open for execution of your orders during specified hours in a regular trading session 

from 6:00 p.m. (T-1) to 5:00 p.m. Eastern Time Sunday through Thursday, and during a regular trading 

session from 6:00 p.m. (T-1) to 4:15 p.m. Eastern Time on Friday. Specific listing hours for each contract 

are available on the Nadex website.

Please note that Nadex trading hours, including the trading hours and trading hours for individual 

contracts, are subject to change due to holiday, availability of underlying products, emergency, or other 

event necessitating a halting or closure of trading. Any changes to Nadex trading hours due to a US or 

foreign holiday will follow the Product Schedule Guidelines for Holidays, unless otherwise indicated on 

the Notices page of the Nadex website. Any other changes in trading hours or product availability will be 

posted on the Nadex website.

Members may access account information when the Market is closed. Members may enter new orders 

and/or cancel or modify open orders whenever those markets are available for trading.

RULE 5.19 PROHIBITED TRANSACTIONS AND ACTIVITIES

(a) Members are prohibited from entering orders on the Market if there are insufficient funds or 

Contracts in the Member’s settlement account to satisfy such orders if they are executed. Subject to the 

conditions set forth in Rule 9.2(f) and Rule 9.6, if you violate this Rule, the following penalties may apply:

Number of Per Incident 

Violations Within a 

Calendar Year

Penalty

1. $10 fee deducted from the Member’s settlement account.

2. $10 fee deducted from the Member’s settlement account, and 

the Member will be required to re-certify that it has read and 

agree to be bound by this Rule 5.13(a).

3. $15 fee deducted from the Member’s settlement account, and 

the Member will be required to give a satisfactory explanation 

as to why the Rule violation occurred, or (in the case of Trading 

Members) trading privileges may be suspended for 30 days.

4. $20 fee deducted from the Member’s settlement account and (in 

the case of Trading Members) suspension of trading privileges 

for 30 days (regardless of explanation).
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5. $25 fee deducted from the Member’s settlement account and (in 

the case of Trading Members) suspension of trading privileges 

for 6 months (regardless of explanation).

6. $30 fee and revocation of trading privileges (regardless of 

explanation).

Nadex may, in its discretion, take such other action against a Member or market participant if the 

circumstances warrant, subject to Rule 9.2(f) and Rule 9.6.

(b) No Person shall enter into or attempt to enter into any non-competitive trade on the Market, 

including any accommodation trade or any trade that has been directly or indirectly prearranged. For 

example, a Member may not agree in advance with another Member that one of the Members will enter 

an order and the other Member will attempt to trade against that order by timing the submission of orders 

or otherwise.

(c) No Person shall enter into or attempt to enter into any trade on the Market that:

(1) does not result in a change in beneficial ownership,

(2) is designed to unnaturally inflate trading volume,

(3) in any way attempts to circumvent the Market’s order processing, trade ordering, 

trade execution systems, or otherwise to circumvent exposure of the order to open 

and competitive bidding on the Market, or

(4) that has some other illegitimate purpose.

(d) No Person shall enter into any trade designed or used to cause any price for a Contract other 

than a true and bona fide price to be reported, registered, or recorded by the Market.

(e) No Person shall trade in, transfer, assign, or otherwise dispose of Contracts other than as 

provided for in these Rules.

(f) No Person shall enter into or agree to transfer or transfer the benefit of any position in any 

Contract to another person other than through a transaction executed through the Market.

(g) (1) No individual Trading Member shall trade for a person or entity other than itself and 

no Authorized Trader of an Entity Trading Member shall trade for a person or entity other 

than the Entity Trading Member for whom that Person is an Authorized Trader.
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(2) No individual or Entity Trading Member may deposit funds, or allow funds to be 

deposited into their Nadex account from any bank account or debit card not held in the 

same name as their Nadex account.5

(h) No Person shall engage in any activity that presents a risk of harm to Nadex, its Members, or 

the public.

(i) No Person shall engage in any activity that adversely affects the integrity of the Market or its 

underlying systems.

(j) No Person subject to arbitration under these rules shall fail to abide by an arbitration decision 

or award handed down under Chapter 10 of these Rules.

(k) No Person shall intentionally provide misleading, erroneous, or fraudulent information to 

Nadex on a membership application or otherwise.

(l) No Person shall create a false appearance of a partnership, agency, employment or affiliate 

relationship with Nadex and no Person shall unlawfully solicit customer funds for deposit at Nadex.

(m) No Member may operate or solicit in any capacity that may require registration with the 

Commodity Futures Trading Commission (CFTC) without being properly registered.

(n) No Person shall engage in any activity that is intended to, or has the effect of, manipulating 

the market in violation of Sections 6(c) and 9(a)(2) of the CEA and no Person shall engage in any other 

activity that would violate the CEA or the Commission’s Regulations.

(o) No Member shall deposit funds into its Nadex account from an account which does not hold 

sufficient funds at the time of deposit, and at the time the deposit is presented by Nadex for payment.

(p) No Member shall make a false representation to a third party regarding any deposit made into 

that Member’s Nadex account which would result in a chargeback or stop payment of funds to the 

Member’s account.

(q) No Member shall allow its settlement account balance to become negative by any means. In 

the event that a Member’s settlement account balance becomes negative, the Member must immediately 

deposit additional funds to correct the deficiency. Any Member whose settlement account carries a 

negative balance for 30 days or more is subject to summary termination of Membership. Nadex may, in 

its discretion, take such other action against a Member or market participant if the circumstances warrant, 

subject to Rule 9.2(f) and Rule 9.6.

5 Rule 5.19(g)(2) does not prevent the Trading Member from allowing deposits to be made to the Trading Member’s Nadex

account by the Exchange, including but not limited to, in the event of an order cancellation, trade cancellation, expiration 

value adjustment, ledger adjustment, refund of wire transfer fees, refund of returned deposit fees, or incentive program.
55

(r) No FCM Member shall enter any bids, offers or transactions on the Market if it knows or 

should know that it is subject to early warning reporting requirements under Commission Regulation 1.12, 

is subject to a proceeding in bankruptcy or is otherwise unable to pay its obligations as they become due, 

without the prior written approval of Nadex.

(s) No FCM Member shall knowingly carry an account, enter an order or effect any transactions 

for any employee of Nadex without the prior written consent of the employer.

(t) No Member shall engage in conduct or practices inconsistent with just and equitable principles 

of trade or conduct or practices detrimental to the best interests of the Exchange, its Members and/or FCM 

Customers.

(u) No FCM Member that receives an order to buy or sell a Contract for execution on Nadex shall 

directly or indirectly guarantee the execution of the order or any of its terms, including quantity or price. 

A FCM Member may only report to a FCM Customer a trade that has been executed or reported on the 

Nadex Market.

(v) If a Member is an Insider of any public company that has access to material non-public 

information that is the subject of an Underlying of any Contract, that Member is prohibited from 

attempting to enter into any trade or entering into any trade, either directly or indirectly, on the market in 

such Contracts. An “Insider” means any person who has access to or is in a position to have access to 

material non-public information before such information is made publicly available. Without limiting the 

generality of the foregoing restriction, an Insider includes any officer or director of a public company, any 

employee who works in the company’s financial or accounting department, and any employee of the 

company’s accounting firm who performs services for the public company.

(w) No Person shall engage in any activity that constitutes fraudulent or abusive trading, including 

but not limited to violating bids or offers; demonstrating intentional or reckless disregard for the orderly 

execution of transactions during the closing period; or spoofing.

(x) No Person shall engage in any trading activity intended to accomplish a “money pass”.

RULE 5.20 SPECULATIVE POSITION LIMITS

(a) Nadex has imposed Speculative Position Limits on certain Classes of Contracts as defined in 

Chapter 12 of these Rules, subject to the exemption and Alternative Position Limits for certain Market 

Makers defined in Rule 4.4(d). Any Trading Member or FCM Customer who exceeds a Speculative 

Position Limit or, if applicable, an Alternative Position Limit shall be deemed in violation of this Rule

5.20. In addition, any Trading Member (except for approved Market Makers) or FCM Customer entering 

bids or offers, if accepted, which would cause that Trading Member or FCM Customer to exceed the 

applicable Speculative Position Limit shall be in violation of this Rule. In the case of any violation of this

Rule by a FCM Customer, that Customer‘s FCM Member shall be held directly responsible for such 

violation.
56

(b) If a Member fails to reduce any position in a manner and time as directed by Nadex, Nadex

shall have the authority to liquidate the applicable position to a level below the defined Speculative 

Position Limit stipulated under the relevant Class of Contracts in Chapter 12 of these Rules or, if 

applicable, the Alternative Position Limit pursuant to Rule 4.4(d).

(c) In addition to the restrictions and requirements imposed in Section 5.20(a) and (b), the first 

violation of a Speculative Position Limit or Alternative Position Limit by a Member or FCM Customer 

may result in a letter of warning to be issued by the Nadex Compliance Department to the Trading Member 

or FCM Customer and its FCM Member or the initiation of proceedings in accordance with Chapter 9 of 

these rules.

(d) In addition to the restrictions and requirements placed in Section 5.20(c), any subsequent 

violation of a Speculative Position Limit or Alternative Position Limit by a Trading Member or FCM 

Customer within 12 months after a violation that resulted in a letter of warning, will result in the initiation 

of proceedings in accordance with Chapter 9 of these Rules.

(e) Position limits shall apply to i) all positions in accounts for which any Person by power of 

attorney or otherwise, directly or indirectly holds positions or controls trading, and ii) positions held by 

two or more Persons acting pursuant to an express or implied agreement or understanding the same as if 

the positions were held by, or the trading of the position were done by, a single individual.

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CHAPTER 6 CLEARING AND SETTLING CONTRACT TRADES, CONTRACTS AT 

EXPIRATION, AND MEMBER WITHDRAWAL REQUESTS AND REGULATORY 

REPORTING OF SWAP DATA

RULE 6.1 CLEARANCE AND SUBSTITUION

(a) In its capacity as a registered derivatives clearing organization, upon the successful matching 

of orders pursuant to Rules 5.3 or 5.4 Nadex shall immediately, through the process of novation, be 

substituted as, and assume the position of, seller to the Member buying and buyer to the Member selling 

the relevant Nadex contract. Upon such substitution, the buying and selling Members shall be released 

from their obligations to each other, and such Member shall be deemed to have bought the contracts from 

or sold the contracts to Nadex, as the case may be, and Nadex shall have all the rights and be subject to 

all the liabilities of such Member with respect to such transaction. Such substitution shall be effective in 

law for all purposes.

RULE 6.2 SETTLING CONTRACT TRADES

(a) Nadex will maintain, on its system, a record of each Member’s account balances and Contracts 

and (b) each FCM Member’s Cleared Swaps Customer Account and Cleared Swaps Proprietary Account 

balances and, by subaccount, the positions of each of its FCM Customers. Nadex will also maintain a 

“Nadex settlement account,” which will reflect funds used by Members to buy and sell Contracts. Nadex 

will also maintain a “Nadex proprietary account,” which will be credited with all fees debited from 

Member accounts due to trades and expiration settlements. All settlements among these accounts on the 

Nadex system will be instantaneous.

(b) All funds in Member accounts and in the Nadex settlement account will be maintained in an 

account at the Nadex settlement bank that is designated as a Cleared Swaps Customer Account under the 

CEA and the Commission’s Regulations. Because those funds will be commingled at the settlement bank, 

transfers among Member accounts and transfers between Member accounts and the Nadex settlement 

account will not be transmitted to the settlement bank. Such records will only be maintained on the Nadex 

system. However, once every settlement bank Business Day, Nadex will send to its settlement bank by 

batch mode electronic transmission instructions for the settlement bank to transfer fees credited by Nadex 

to the Nadex proprietary account on its system from the Cleared Swaps Customer Account at the 

settlement bank to the Nadex proprietary account at the settlement bank.

(c) The settlement bank will complete the transfer in the settlement instructions described in 

paragraph (b) of this Rule and notify Nadex of its completion.

RULE 6.3 SETTLING CONTRACTS AT EXPIRATION

(a) When a Series of Variable Payout Contracts expires, those Contracts will settle in an amount 

(if any) determined by the calculations set forth in the definitions for Long and Short Variable Payout 

Contracts set forth in Chapter 1 of these Rules. When a Series of Binary Contracts expires and has a
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Payout Criterion that encompasses the Expiration Value of the Underlying, such Binary Contract will pay 

the Settlement Value for such Binary Contracts (e.g. $100) to the holders of long positions in such Binary 

Contracts. Conversely, when a Series of Binary Contracts expires and has a Payout Criterion that does 

NOT encompass the Expiration Value of the Underlying, such Binary Contract will pay the Settlement 

Value for such Binary Contracts (e.g. $100) to the holders of short positions in such Binary Contracts.

(b) On the Settlement Date;

(i) Nadex will notify all Members which Contract is going to pay a Settlement 

Value and which Contract will not pay a Settlement Value.

(ii) Nadex will immediately settle the Variable Payout Contracts by (A) 

debiting Nadex’s settlement account in an amount equal to (1) any gains realized by

Members (including customers of FCM Members) plus (2) any blocked funds that were 

debited from Members’ accounts at the time the Variable Payout Contracts that are expiring 

were entered into that are not used to pay any losses on such Contract(s) and (B) crediting 

those amounts, respectively, to the accounts of (1) Members who realized such gains, in each 

case in the amount of such gains realized by each Member (including Customers of FCM 

Members), and (2) Members from whose accounts such blocked funds were taken, in each 

case in the amount of such blocked funds that was not required to pay losses experienced by 

such accounts on such Contracts.

(iii) Nadex will immediately settle the Binary Contracts by debiting the Nadex’s 

settlement account in an amount no less than the Settlement Value for such Contracts 

multiplied by the total number of outstanding in-the-money Binary Contract positions and 

credit those funds to the applicable settlement accounts of the Members holding the in-themoney Binary Contract positions (or, in the case of Customers of FCM Members holding the 

in-the-money Binary Contract positions, to the settlement account of the FCM Member).

(iv) Nadex will delete all Contracts of the expiring Series from Trading 

Members’ accounts and FCM Customer Position Accounts, as applicable.

(c) Any Person who believes there has been an error in settlement, must report that error to Nadex 

immediately. Such report must state the basis for the belief that there has been an error in settlement. If 

Nadex receives notice of a settlement error within twenty-four hours of the settlement, excluding nonTrading Days, Nadex will review that report and will correct any error that Nadex determines has been 

made. If Nadex does not receive notice of an error of settlement within twenty-four hours of the 

settlement, excluding non-Trading Days, then (i) settlement will be final and (ii) all Members agree that 

Nadex shall not be responsible to you in any fashion for an uncorrected error in settlement, including, 

without limitation, errors resulting from a calculation error, erroneous or incomplete data, and/or input of 

data, or inaccurate collection of the settlement data set.
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RULE 6.4 SETTLING MEMBER WITHDRAWAL REQUESTS

Within one settlement bank Business Day of when a Member requests to withdraw funds from its Nadex 

account, Nadex will transmit such request to its settlement bank in electronic batch mode transmission. 

The settlement bank will process that request and send those funds to the account at the Financial 

Institution as that term is defined in Rule 1.1, or Foreign Bank in the case of a non-United States resident 

Member who does not have an account at a US Financial Institution, registered with Nadex by the Member 

(unless the Member and, in the case of FCM Members, any FCM Customer of that FCM Member has 

unsatisfied outstanding obligations on Nadex, in which case Nadex may retain such balances as necessary 

to satisfy such obligations or until the Member otherwise satisfies such obligations). The Member should 

refer to Nadex’s website under the Fee Schedule for all fees and costs associated with withdrawal of funds 

from the Member’s Nadex account. Nadex may suspend or deny the processing of a Member withdrawal 

request if circumstances, whether present or imminent, would make the request impossible or impractical 

to fulfill, cause a potential risk of harm to Nadex or its Members, or if, in its discretion, Nadex determines 

the funds are relevant to a pending investigation.

RULE 6.5 REGULATORY REPORTING TO SWAP DATA REPOSITORY

In accordance with the CFTC Letter No 17-31 (“Letter”) issued by the Commodity Futures Trading 

Commission Division of Clearing and Risk and Division of Market Oversight on June 30, 2017, Nadex 

has been granted no-action relief with respect to various swap data reporting requirements of Parts 43 and 

45 of the Commission’s regulations for contracts traded on or pursuant to the rules of, and cleared by, 

Nadex. Nadex will comply with all conditions of such relief as set forth in that Letter.

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CHAPTER 7 ADJUSTMENTS NECESSITATED BY MATERIAL CHANGES IN THE 

UNDERLYING

RULE 7.1 ADJUSTMENTS

In the event that, prior to or during the term of a Series, changes beyond the control of Nadex occur in the 

availability of the Underlying, the way the Underlying is calculated or an Expiration Value for the 

Underlying is unavailable or undefined in light of intervening events, Nadex may delay listing a Series, 

adjust the terms of an outstanding Series, or take other action as it deems appropriate in its discretion to 

achieve fairness to holders of Contracts of the affected Series. In addition, if the outcome of the underlying 

event is unclear, Nadex may, at its sole discretion, delay settlement of the Series until the outcome is clear 

to Nadex as determined by reasonable means. While it is impossible to provide in advance for all possible 

events that could require an adjustment to be made, Nadex will abide by any guidelines that may be 

established in this Chapter for making Contract adjustments.

RULE 7.2 GOVERNMENT ACTIONS

Any change in instructions, order, ruling, directive, or law issued or enacted by any court or agency of the 

Federal Government of the United States that conflicts with the Rules contained in this Chapter shall take 

precedence, immediately become a part of these Rules, and be effective for all currently traded and newly 

listed Series.

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CHAPTER 8 INVESTMENT OF MEMBER ACCOUNT FUNDS

Direct Trading Member funds on deposit with Nadex and funds in the Nadex settlement account (i.e., the 

account containing the funds paid by Members to purchase Contracts and which are to be used to pay 

Members holding in-the-money Contracts at expiration) will be segregated as Member Property, as that 

term is defined in in CFTC Regulation 190.09(a), in cleared swap proprietary accounts, and funds of 

Cleared Swap Customers will be segregated as cleared swaps customer collateral in accordance with the 

Commission’s Regulations. Nadex may invest such funds subject to the limitations and conditions set 

forth in Commission Regulations 22.2(e)(1) and 1.25. Nadex may pay interest to Members’ accounts at 

a floating rate to be determined by Nadex on funds in Members’ Nadex accounts in excess of an amount 

to be determined by Nadex. Nadex will retain all profit from investment of Member funds not paid to 

Members in accordance with the preceding sentence.

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CHAPTER 9 RULE ENFORCEMENT

RULE 9.1 MONITORING THE MARKET

Nadex’s trading system will record and store for a period of not less than 5 years in a searchable, readonly database a record of all data entered into the Nadex trading system, including the Member’s identity 

and the information in Rule 5.5. Such records shall be maintained in a readily available manner during the 

first two years. Nadex shall conduct market surveillance and trade practice surveillance using this data 

with programs designed to alert Nadex when potentially unusual trading activity takes place. Nadex will 

initiate review and, where appropriate, investigate such unusual trading activity. Nadex will also 

investigate any time it has other reason to believe that inappropriate activity of any sort is taking place on 

the Market or its website.

RULE 9.2 INVESTIGATIONS, HEARINGS, AND APPEALS

(a) Nadex has a compliance department consisting of one or more compliance staff. The Chief 

Regulatory Officer is responsible for overseeing the compliance department. The Compliance Department 

shall investigate unusual trading activity or other activity that the Compliance Department has reasonable 

cause to believe could constitute a violation of these Rules. Investigations and all information and

documents collected or obtained in connection with an investigation which were not made public prior to 

the commencement of the investigation shall be treated as non-public and confidential and shall not be 

disclosed by any party, except in furtherance of a Nadex investigation, or as required by law or regulation, 

or as otherwise agreed to by Nadex. Nadex retains hearing officers, who adjudicate findings by the 

Compliance Department that are disputed by Members. Hearing officers and the Compliance Department 

may not communicate regarding the merits of a matter brought before the hearing officer without 

informing the Member who is the subject of the communication of its substance and allowing the Member 

an opportunity to respond. The Compliance Department and hearing officers may compel testimony, 

subpoena documents, and require statements under oath from any Member or its authorized representative. 

Hearing officers, Compliance Department staff and other employees or agents of Nadex working under 

their supervision, may not be a Member or an authorized representative of a Member or trade, directly or 

indirectly, in any commodity interest traded on or subject to the rules of any registered contract market.

(b) The Compliance Department will endeavor to complete any investigation within twelve 

months, unless there exists significant reason to extend it beyond such period. Upon the conclusion of any 

investigation, the Compliance Department will draft a document detailing the facts that led to the opening 

of the investigation, the facts that were found during the investigation, and the Compliance Department’s 

analysis and conclusion. If the Compliance Department concludes that there is reasonable cause to believe 

a Member has violated Nadex’s Rules or other applicable statutes or regulations, the Compliance

Department will submit by to the Member whose activity is the subject of the investigation a report, by 

electronic mail to that Member’s last known email address, that will include:

(i) the reason the investigation was begun;
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(ii) the charges or a summary of the charges, including the rule or rules alleged to 

have been violated;

(iii) the response, if any, or a summary of the response;

(iv) a summary of the investigation conducted;

(v) findings of fact and the Compliance Department’s conclusions as to each 

charge, including which of these Rules the Member or its authorized representative violated, if 

any;

(vi) a summary of the Member’s, and any relevant authorized representative’s, 

disciplinary history, if any; and

(vii) the penalty, if any, proposed by the Compliance Department.

(c) If the Compliance Department institutes an investigation in which any Affiliate of Nadex is a 

subject, Nadex’s Chief Regulatory Officer shall notify the Commission’s Division of Market Oversight 

of that fact. At the conclusion any such investigation, the Chief Regulatory Officer shall provide the 

Commission’s Division of Market Oversight with a copy of the documentation specified in subparagraph

(b) of this Rule.

(d) The Member whose activity is the subject of the investigation may contest the Compliance 

Department’s findings by forwarding a response to those findings by electronic mail to the Compliance 

Department within 15 days. Subject to subparagraph (a) of this Rule, the Member has a right to examine 

all relevant books, documents, or other evidence in the possession or under the control of Nadex, except 

that Nadex may withhold from inspection any documents that (i) are privileged or that constitute attorney 

work product, (ii) were prepared by any employee of Nadex but which will not be offered in evidence in 

the disciplinary proceedings, (iii) may disclose a technique or guideline used in examinations, 

investigations, or enforcement proceedings, or (iv) disclose the identity of a confidential source. The 

Member’s response must contain a detailed response to the findings and conclusions as to each charge and 

any other information the Member thinks is relevant.

(e) The Member whose activity is the subject of the investigation may request to enter settlement 

negotiations by forwarding a response to the Compliance Department’s findings by electronic mail to the 

Compliance Department within 15 days. Subject to subparagraph (a) of this Rule, the Member has a right 

to examine all relevant books, documents, or other evidence in the possession or under the control of 

Nadex, except that Nadex may withhold from inspection any documents that (i) are privileged or that 

constitute attorney work product, (ii) were prepared by any employee of Nadex but which will not be 

offered in evidence in the disciplinary proceedings, (iii) may disclose a technique or guideline used in 

examinations, investigations, or enforcement proceedings, or (iv) disclose the identity of a confidential 

source. The Member’s response must contain a response to each charge and the Member may provide
64

any other information the Member thinks is relevant. The outcome of settlement negotiations between the 

Member and the Compliance Department may include, but is not limited to, a letter of warning.

(f) If the findings of the Compliance Department are not contested by the Member, Nadex will 

deem those findings admitted by the Member, the findings of fact and the Compliance Department’s 

conclusions as to each charge shall become final and the Compliance Department shall impose the penalty 

(if any) proposed by the Compliance Department. The Member will be notified of the imposition of any 

penalty and sent a copy of the notice of disciplinary action by electronic mail to that Member’s last known 

email address.

(g) If the findings of the Compliance Department are contested, the Compliance Department’s 

report and the Member’s response contesting the Compliance Department’s findings and/or proposed 

sanction(s) will be submitted to a Nadex hearing officer. The hearing officer may not have a financial, 

personal or other direct interest in the matter under consideration.

(i) The hearing officer will conduct a hearing with the Compliance Department 

and the Member promptly following receipt of the Member’s response contesting the 

compliance officer’s finding and/or proposed sanction which the parties may attend 

telephonically. The Member respondent shall be provided reasonable notice of the hearing 

date. The hearing officer or the Compliance Department may extend the hearing date at its 

discretion for good cause shown, or by the parties’ mutual consent. The formal rules of 

evidence shall not apply, but the hearing must be fair.

(ii) At least 28 days in advance of a hearing, the Member respondent shall 

submit to the Compliance Department, and the Compliance Department shall submit to the 

Member respondent, copies of all books, documents, records and other tangible evidence, 

which each plans to rely on or refer to during its direct case at the hearing, and provide a list 

of the names and titles of witnesses that each plans to call on its direct case at the hearing. The 

hearing officer may refuse to consider any books, records, documents or other tangible 

evidence which was not made available to, or witnesses whose names and titles were not 

submitted to, the other party pursuant to this section. To the extent the Compliance 

Department or the Member respondent intends to call any expert witness at the hearing then 

such party shall provide to the other, at least 28 days prior to the date of the hearing, a 

summary of the expert’s opinions to be offered at the hearing and the basis and/or 

methodology underlying such opinions. In addition, the expert’s credentials (e.g., a 

curriculum vitae) and all documents or other materials on which the expert relied in forming 

his opinions shall be produced to the other party at the same time. For purposes of this 

provision, staff in the Compliance Department or other Nadex employee shall not be 

considered experts. The hearing officer may decline to consider any expert testimony beyond 

the scope of the submitted summary.
65

conclusions;

(iii) The hearing officer may question the parties or any witness during the 

hearing, request additional documentation or information from any party, and/or request posthearing briefs from the parties.

(iv) Promptly after that hearing, the hearing officer will issue findings, which 

will be delivered to the Member by electronic mail to the Member’s last known email address. 

The findings of the hearing officer will contain the following information:

(1) a summary of the charges and any answer to the charges;

(2) a summary of the evidence received;

(3) findings and conclusions with respect to each charge;

(4) an indication of each specific rule that the member was found to have violated;

(5) a declaration of any penalty to be imposed on the Member as the result of the findings and

(6) the effective date and duration of that penalty; and

(7) a statement that the Member has the right to appeal any adverse decision by the hearing

officer to the Nadex board of directors, but must do so within 15 days.

(i) The hearing officer’s decision shall be final on the date it is signed by the 

hearing officer. The hearing officer’s decision shall become the final decision of Nadex after 

the appeal period has lapsed.

(ii) The hearing will be recorded, and all information submitted by the parties 

(including the Compliance Department’s report and the Member’s response) as well as the 

recording of the hearing, will be preserved by the Compliance Department, along with the 

hearing officer’s findings, as the record of the proceedings (the “hearing record”).

(h) Either the Member or the Compliance Department may appeal the decision of the hearing 

officer within 15 days by filing an appeal by electronic mail with the Nadex board of directors and 

forwarding a copy to the other parties to the appeal. Any penalties will be stayed pending appeal unless 

the hearing officer determines that a stay pending appeal would likely be detrimental to the exchange, 

other Members, or the public. The board of directors will review the hearing record and any information 

submitted by the Compliance Department and the Member on appeal and issue its decision, which shall 

be final on the date of such issuance. The Member shall be notified of the decision by electronic mail to 

the Member’s last known email address. The hearing record, any information submitted on appeal, and 

the board’s decisions shall be preserved as the record on appeal. The decision will contain the information 

listed in paragraph (f) of this Rule, except for (f)(vi), and will also contain:
66

(i) a statement that any person aggrieved by the action may have a right to appeal 

the action pursuant to Part 9 of the Commission’s Regulations, within 30 days of service; and

(ii) a statement that any person aggrieved by the action may petition the 

Commission for a stay pursuant to Part 9 of the Commission’s Regulations, within 10 days of 

service.

RULE 9.3 SETTLEMENT OF INVESTIGATIONS

(a) Nadex may enter into settlements with any Member or its authorized representative who is the 

subject of an investigation. The Member, or its authorized representative may initiate a settlement offer. 

A Member, or its authorized representative, may submit an offer of settlement without admitting or 

denying the Rule violations or factual findings upon which the penalty is based, provided, however, that 

an offer must include a consent to the entry of findings regarding the conduct and Rule violations at issue, 

to the penalty to be imposed and to the effective date of the penalty. A settlement offer that is supported 

by the Compliance Department shall be forwarded to a Nadex hearing officer for consideration, along 

with the Compliance Department’s supporting statement. The hearing officer may accept, accept with 

modifications, or reject a proposed settlement offer. A settlement offer may be withdrawn at any time 

before it is accepted by the hearing officer.

(b) The hearing officer may accept or reject a proposed settlement, and the decision of the hearing 

officer will be final. In addition, the hearing officer may propose a modification to the proposed settlement 

for consideration by the Member or its authorized representative and the Compliance Department.

(c) Any settlement under this Rule will be written and will state:

(i) the charges or a summary of the charges;

(ii) the response, if any, or a summary of the response;

(iii) a summary of the investigation conducted;

(iv) findings and conclusions as to each charge, including each act the person 

charged was found to have committed or omitted, be committing or omitting, or be about to 

commit or omit, and each of these Rules that such act or practice violated, is violating, or is about 

to violate; and

(v) any penalty imposed and the penalty’s effective date.

(d) Failed settlement negotiations, or withdrawn settlement offers, will not prejudice a Member 

or otherwise affect subsequent procedures in the rule enforcement process.
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RULE 9.4 NOTICE AND PUBLICATION OF DISCIPLINARY ACTION

(a) Nadex will provide to the person charged, notice of the disciplinary action, appeal 

determination, or settlement in which sanctions are imposed, no later than two Business Days after it 

becomes final in accordance with the provisions of Commission Regulation 39.19(c)(4)(xi).

(b) Within two Business Days after a disciplinary action becomes final, notice of any disciplinary 

action outcome providing that a Member is suspended, expelled, disciplined or denied access to the 

Exchange shall be provided to the National Futures Association for inclusion in its internet accessible 

database of disciplinary matters.

(c) Nadex will make public notice of the disciplinary action by posting on its website, in 

accordance with Commission Regulation 9.13, the information required by Commission Regulation 9.11. 

The disciplinary action will be considered final on the date the notice of the disciplinary action is published 

on the Nadex website.

RULE 9.5 PENALTIES

As a result of a disciplinary proceeding or as part of a settlement, Nadex may impose one or more of 

the following penalties:

(a) a letter of warning, censure, or reprimand (although no more than one such letter may be issued 

to the same Person found to have committed the same rule violation within a rolling twelve month period);

(b) a fine or penalty fee, which Nadex may deduct from the Member’s account balance;

(c) disgorgement of profits that resulted from the violation of any Nadex Rule, which Nadex may 

deduct from the Member’s account balance;

(d) suspension of membership status or privileges for a specified period, including partial 

suspension of such privileges (for example, suspension of trading privileges in particular types of 

Contracts or of placement of certain types of orders);

(e) revocation of membership status or privileges, including partial revocation of such privileges 

(for example, revocation of trading privileges in particular types of Contracts or of placement of certain 

types of orders); and

(f) interest, at the prime rate, as reported by the Wall Street Journal as of the date the amount 

becomes due, on any outstanding account balance, monetary fine, penalty fee, or disgorgement amount 

owed, compounded monthly and calculated from the date when the amount was first due and payable.
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RULE 9.6 SUMMARY SUSPENSION

(a) Nadex may summarily suspend or restrict a Member (or any of its Authorized Traders or, in 

the case of FCM Members, its customers) privileges if the Chief Regulatory Officer believes suspension 

or restriction is necessary to protect the swaps or commodity futures markets, Nadex, the public, or other 

Members.

(b) Whenever practicable Nadex will notify the Member whose privileges are to be summarily 

suspended by electronic mail before the action is taken. If prior notice is not practicable, the Member shall 

be served with notice by electronic mail at the earliest opportunity. This notice shall:

(i) state the action taken or to be taken;

(ii) briefly state the reasons for the action;

(iii) state the time and date when the action became or becomes effective and its 

duration; and

(iv) state that any person aggrieved by the action may petition the Commission for 

a stay of the effective date of the action pending a hearing pursuant to Part 9 of the Commission’s 

Regulations, within 10 days of service.

(c) The Member (or Authorized Trader or customer of an FCM Member) whose privileges are to 

be summarily suspended shall be given an opportunity for appeal under the procedures outlined in Rule 

9.2(f) of these Rules. The decision affirming, modifying, or reversing the summary suspension shall be 

furnished by electronic mail to the suspended Member or Authorized Trader or, with respect to a FCM 

Customer, to the FCM Member, and the Commission no later than one Business Day after it is issued. The 

decision shall contain:

(i) a description of the action taken and the reasons for the action;

(ii) a brief summary of the evidence received during the appeal process;

(iii) findings and conclusions;

(iv) a determination as to whether the summary action that was taken should be 

affirmed, modified, or reversed;

(v) a declaration of any action to be taken against the suspended Member as the 

result of that determination;

(vi) the effective date and duration of that action;
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conclusions;

(vii) a determination of the appropriate relief based on the findings and

(viii) a statement that any person aggrieved by the action may have a right to appeal

the action pursuant to Part 9 of the Commission’s Regulations, within 30 days of service; and

(ix) a statement that any person aggrieved by the action may petition the 

Commission for a stay pursuant to Part 9 of the Commission’s Regulations, within 10 days of 

service.

RULE 9.7 REPRESENTATION BY COUNSEL

A Member, Authorized Trader or FCM Customer who is a subject of any proceedings under this Chapter 

has the right to retain and be represented by counsel during such proceedings.

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CHAPTER 10 LIMITATION OF LIABILITY; TIME PERIOD IN WHICH TO BRING 

ACTIONS; GOVERNING LAW; ARBITRATION

RULE 10.1 LIMITATION OF LIABILITY

(a) EACH MEMBER OF NADEX AGREES THAT NEITHER NADEX NOR ITS 

OFFICERS, DIRECTORS, AGENTS, EMPLOYEES, AND/OR SOFTWARE, HARDWARE, AND 

SERVICE PROVIDERS (COLLECTIVELY REFERRED TO AS “NADEX PARTIES”) SHALL HAVE 

ANY RESPONSIBILITY FOR COMPLIANCE BY MEMBER WITH ANY LAW OR REGULATION 

GOVERNING MEMBER’S CONDUCT. MOREOVER, EACH MEMBER OF NADEX ALSO 

AGREES THAT NO NADEX PARTY SHALL BE LIABLE IN ANY MANNER WHATSOEVER FOR 

ANY LOSS OR DAMAGE SUSTAINED BY MEMBER, INCLUDING ANY CONSEQUENTIAL 

LOSS, LOSS OF PROFIT OR LOSS OF TRADING OPPORTUNITY, AS A RESULT OF ANY 

ACTUAL OR PROPOSED TRANSACTIONS OR AS A DIRECT OR INDIRECT RESULT OF ANY 

SERVICES PROVIDED BY NADEX PARTIES (INCLUDING, WITHOUT LIMITATION, ANY 

FAILURE IN NADEX’S SYSTEMS OR ANY INACCURATE INFORMATION PROVIDED BY A 

NADEX PARTY), UNLESS THE RELEVANT NADEX PARTY IS DETERMINED BY FINAL 

RULING OF AN ARBITRATION PROCEEDING TO HAVE ACTED OR FAILED TO ACT IN A 

MANNER THAT IS GROSSLY NEGLIGENT, RECKLESS, OR FRAUDULENT. FOR THE 

AVOIDANCE OF DOUBT, NOTHING IN THIS RULE IS INTENDED TO LIMIT THE LIABILITY 

OF ANY PERSON AS MAY BE PROVIDED IN THE CEA, THE REGULATIONS OF THE 

COMMISSION, OR BY ACTS OF WILLFUL OR WANTON MISCONDUCT OR FRAUD.

(b) EACH MEMBER OF NADEX AGREES THAT IT MAY NOT BRING ANY ACTION 

AGAINST A NADEX PARTY UNLESS IT BRINGS SUCH ACTION WITHIN 2 YEARS OF THE 

FIRST OCCURRENCE OR LACK OF OCCURRENCE OF THE ACT OR OMISSION COMPLAINED 

OF.

(c) EACH MEMBER OF NADEX AGREES THAT ANY ACTION IT BRINGS AGAINST A 

NADEX PARTY WILL BE GOVERNED BY ILLINOIS LAW, WITHOUT REGARD TO STATUTES, 

PRECEDENT, LEGAL DOCTRINE, OR CONTRACTUAL PROVISIONS THAT WOULD REQUIRE 

THE APPLICATION OF THE LAWS OF A DIFFERENT JURISDICTION.

(d) EACH MEMBER OF NADEX AGREES THAT ANY ACTION IT BRINGS AGAINST A 

NADEX PARTY OR AGAINST ANOTHER NADEX MEMBER WILL BE RESOLVED BY BINDING 

ARBITRATION, IN ACCORDANCE WITH THE RULES OF THIS CHAPTER AND OTHER RULES 

OF NADEX, IF APPLICABLE.
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RULE 10.2 ARBITRATION OF MEMBER-MEMBER DISPUTES

Any dispute, controversy, or claim between or among Members arising out of or relating to transactions 

on Nadex shall be submitted to binding arbitration in Cook County, Illinois before, and according to the 

Member arbitration rules of, National Futures Association. The decision of the arbitrator or arbitrators 

will be final, and judgment upon that decision may be entered in any court of competent jurisdiction. 

Unless the arbitrator or arbitrators find that one of the parties has acted in bad faith, each party will pay 

its own expenses.

RULE 10.3 ARBITRATION OF NADEX-MEMBER DISPUTES

Any dispute, controversy, or claim brought against Nadex by any Member shall be submitted to binding 

arbitration in Cook County, Illinois. Unless the arbitrator or arbitrators find that one of the parties has 

acted in bad faith, each party will pay its own expenses. Upon request of either party the arbitrator or 

arbitrators will make a finding as to whether Nadex has acted in a manner that is grossly negligent, 

reckless, or fraudulent.

RULE 10.4 ARBITRATION OF FCM MEMBER-CUSTOMER DISPUTES

Any dispute, controversy, or claim brought against any FCM Member by a customer may be submitted to 

binding arbitration in Cook County, Illinois before, and according to the customer arbitration rules of, 

National Futures Association. The decision of the arbitrator or arbitrators will be final, and judgment upon 

that decision may be entered in any court of competent jurisdiction. Unless the arbitrator or arbitrators 

find that one of the parties has acted in bad faith, each party will pay its own expenses.

RULE 10.5 FAILURE TO ABIDE BY ARBITRATION DECISION

It will be a violation of the Nadex Rules for a Member to fail to pay an award or otherwise satisfy or abide 

by a judgment in arbitration, and Nadex may take disciplinary action against any such Member, including 

suspension or revocation of Membership.

RULE 10.6 CHANGE IN ARBITRATION PROCEDURE

Nadex will file all changes to its arbitration procedure with the Commission.

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CHAPTER 11 COMMISSION REGULATIONS THAT HAVE BEEN ADAPTED TO BE PART 

OF THE RULES

The following Rules are adaptations of regulations adopted by the Commission. They must be followed 

by Members and Nadex itself, and any violation of these regulations will be a punishable violation of the 

Rules.

RULE 11.1 ACTIVITIES OF SELF-REGULATORY ORGANIZATION EMPLOYEES AND 

GOVERNING MEMBERS WHO POSSESS MATERIAL, NON-PUBLIC INFORMATION 

(ADAPTED FROM COMMISSION REGULATION 1.59)

(a) Definitions. For purposes of this Rule:

(1) Self-regulatory organization means “self-regulatory organization,” as defined in 

Commission regulation 1.3(ee), and includes the term “clearing organization,” as defined in Commission 

regulation 1.3(d).

(2) Governing board member means a member, or functional equivalent thereof, of the board 

of governors of a self-regulatory organization.

(3) Committee member means a member, or functional equivalent thereof, of any committee 

of a self-regulatory organization.

(4) Employee means any person hired or otherwise employed on a salaried or contract basis 

by a self-regulatory organization, but does not include:

(i) Any governing board member compensated by a self-regulatory organization 

solely for governing board activities; or

(ii) Any committee member compensated by a self-regulatory organization solely 

for committee activities; or

(iii) Any consultant hired by a self-regulatory organization.

(5) Material information means information which, if such information were publicly 

known, would be considered important by a reasonable person in deciding whether to trade a particular 

commodity interest on a contract market or a swap execution facility, or to clear a swap contract through 

a derivatives clearing organization. As used in this Rule, “material information” includes, but is not 

limited to, information relating to present or anticipated cash positions, commodity interests, trading 

strategies, the financial condition of members of self-regulatory organizations or members of linked 

exchanges or their customers or option customers, or the regulatory actions or proposed regulatory actions 

of a self-regulatory organization or a linked exchange.
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(6) Non-public information meansinformation which has not been disseminated in a manner 

which makes it generally available to the trading public.

(7) Linked exchange means:

(i) any board of trade, exchange or market outside the United States, its territories 

or possessions, which has an agreement with a contract market in the United States that permits positions 

in a commodity interest which have been established on one of the two markets to be liquidated on the 

other market;

(ii) any board of trade, exchange or market outside the United States, its territories 

or possessions, the products of which are listed on a United States contract market or a trading facility 

thereof; or

(iii) any securities exchange, the products of which are held as margin in a 

commodity account or cleared by a securities clearing organization pursuant to a cross-margining 

arrangement with a futures clearing organization; or

(iv) any clearing organization which clears the products of any of the foregoing

markets.

(8) Commodity interest means any commodity futures or commodity option or swap

contract traded on or subject to the rules of a contract market, swap execution facility, or linked exchange, 

or cleared by a derivatives clearing organization, or cash commodities traded on or subject to the rules of 

a board of trade which has been designated as a contract market.

(9) Related commodity interest means any commodity interest which is traded on or subject 

to the rules of a contract market, a swap execution facility, linked exchange, or other board of trade, 

exchange or market, or cleared by a derivatives clearing organization, other than the self-regulatory 

organization by which a person is employed, and with respect to which:

(i) Such employing self-regulatory organization has recognized or established 

intermarket spread margins or other special margin treatment between that other commodity interest and 

a commodity interest which is traded on or subject to the rules of the employing self-regulatory 

organization; or

(ii) Such other self-regulatory organization has recognized or established 

intermarket spread margins or other special margin treatment with another commodity interest as to which 

the person has access to material, nonpublic information.

(10) Pooled investment vehicle means a trading vehicle organized and operated as a 

commodity pool within Commission Regulation 4.10(d), and whose units of participation have been 

registered under the Securities Act of 1933, or a trading vehicle for which Commission Regulation 4.5
74

makes available relief from regulation as a commodity pool operator, i.e., registered investment 

companies, insurance company separate accounts, bank trust funds, and certain pension plans.

(b) Employees of self-regulatory organizations; Self-regulatory organization rules.

(1) Employees of Nadex are prohibited from:

(i) trading, directly or indirectly, in any commodity interest traded on or cleared by 

Nadex or in any related commodity interest;

(ii) trading directly or indirectly in any commodity interest traded on or cleared by 

contract markets, swap execution facility, or clearing organizations other than Nadex and in any 

commodity interest traded on or cleared by a linked exchange if the employee has access to material nonpublic information concerning such commodity interest.

(2) Employees of Nadex are prohibited from disclosing to any other person any material, 

non-public information which such employee obtains as a result of his or her employment at Nadex where 

such employee has or should have a reasonable expectation that the information disclosed may assist another 

person in trading any commodity interest; however, this Rule does not prohibit disclosures made in the course 

of an employee’s duties, or disclosures made to another self-regulatory organization, linked exchange, court 

of competent jurisdiction or representative of any agency or department of the federal or state government 

acting in his or her official capacity.

(c) Members of Nadex’s governing boards and committees and Nadex consultants; Nadex’s 

Rules. No member of Nadex’s governing board or of a committee of Nadex and no Nadex consultant 

shall use or disclose, for any purpose other than the performance of such person’s official duties as a 

governing board or committee member or consultant, material, non-public information obtained as a result 

of such person’s official duties.

(d) Prohibited conduct.

(1) No person who is an employee of, a member of the governing board of, or a member of 

any committee of, or a consultant of Nadex shall:

(i) Trade for such person’s own account, or for or on behalf of any other account, 

in any commodity interest on the basis of any material, non-public information obtained through special 

access related to the performance of such person’s official duties as an employee, board or committee 

member, or consultant; or

(ii) Disclose for any purpose inconsistent with the performance of such person’s 

official duties as an employee, board or committee member, or consultant, any material, non-public 

information obtained through special access related to the performance of such duties.
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(2) No person shall trade for such person’s own account, or for or on behalf of any account, 

in any commodity interest, on the basis of any material, non-public information that such person knows 

was obtained in violation of paragraph (d)(1) from an employee of, a member of the governing board of, 

a member of any committee, or a consultant of a self-regulatory organization.

RULE 11.2 SERVICE ON SELF-REGULATORY ORGANIZATION GOVERNING BOARDS OR 

COMMITTEES BY PERSONS WITH DISCIPLINARY HISTORIES (ADAPTED FROM 

COMMISSION REGULATION 1.63)

(a) Definitions. For purposes of this section:

(1) Self-regulatory organization means a “self-regulatory organization” as defined in 

Commission Regulation 1.3(ee), and includes a “clearing organization” as defined in Commission 

Regulation 1.3(d), except as defined in paragraph (b)(6) of this Rule.

(2) Disciplinary committee means any person or committee of persons, or any subcommittee 

thereof, that is authorized by a self-regulatory organization to issue disciplinary charges, to conduct 

disciplinary proceedings, to settle disciplinary charges, to impose disciplinary sanctions or to hear appeals 

thereof.

(3) Arbitration panel means any person or panel empowered by a self-regulatory 

organization to arbitrate disputes involving such organization’s members or their customers.

(4) Oversight panel means any panel authorized by a self-regulatory organization to review, 

recommend or establish policies or procedures with respect to the self-regulatory organization’s 

surveillance, compliance, rule enforcement or disciplinary responsibilities.

(5) Final decision means:

(i) A decision of a self-regulatory organization which cannot be further appealed 

within the self-regulatory organization, is notsubject to the stay of the Commission or a court of competent 

jurisdiction, and has not been reversed by the Commission or any court of competent jurisdiction; or,

(ii) Any decision by an administrative law judge, a court of competent jurisdiction 

or the Commission which has not been stayed or reversed.

(6) Disciplinary offense means:

(i) Any violation of the rules of a self-regulatory organization except those rules

related to;

(A) Decorum or attire,
76

(B) Financial requirements, or

(C) Reporting or recordkeeping unless resulting in fines aggregating 

more than $5,000 within any calendar year;

(ii) Any rule violation described in subparagraphs (a)(6)(i) (A) through (C) of this 

Rule which involves fraud, deceit or conversion or results in a suspension or expulsion;

(iii) Any violation of the Act or the regulations promulgated thereunder;

(iv) Any failure to exercise supervisory responsibility with respect to acts 

described in paragraphs (a)(6)(i) through (iii) of this Rule when such failure is itself a violation of either 

the rules of a self-regulatory organization, the Act or the regulations promulgated thereunder; or

(v) A disciplinary offense must arise out of a proceeding or action which is brought 

by a self-regulatory organization, the Commission, any federal or state agency, or other governmental 

body.

(7) Settlement agreement means any agreement consenting to the imposition of sanctions by 

a self-regulatory organization, a court of competent jurisdiction or the Commission.

(b) A person is ineligible to serve on any Nadex disciplinary committees, arbitration panels, 

oversight panels or governing board if that person:

(1) Was found within the prior three years by a final decision of a self-regulatory 

organization, an administrative law judge, a court of competent jurisdiction or the Commission to have 

committed a disciplinary offense;

(2) Entered into a settlement agreement within the prior three years in which any of the 

findings or, in the absence of such findings, any of the acts charged included a disciplinary offense;

(3) Currently is suspended from trading on any contract market, is suspended or expelled 

from membership with any self-regulatory organization, is serving any sentence of probation or owes any 

portion of a fine imposed pursuant to either:

(i) A finding by a final decision of a self-regulatory organization, an administrative 

law judge, a court of competent jurisdiction or the Commission that such person committed a disciplinary 

offense; or,

(ii) A settlement agreement in which any of the findings or, in the absence of such 

findings, any of the acts charged included a disciplinary offense.
77

(4) Currently is subject to an agreement with the Commission or any self-regulatory 

organization not to apply for registration with the Commission or membership in any self-regulatory 

organization;

(5) Currently is subject to or has had imposed on him within the prior three years a 

Commission registration revocation or suspension in any capacity for any reason, or has been convicted 

within the prior three years of any of the felonies listed in section 8a(2)(D) (ii) through (iv) of the Act; or

(6) Currently is subject to a denial, suspension or disqualification from serving on the 

disciplinary committee, arbitration panel or governing board of any self-regulatory organization as that 

term is defined in section 3(a)(26) of the Securities Exchange Act of 1934.

(c) No person may serve on a disciplinary committee, arbitration panel, oversight panel or 

governing board of Nadex if such person is subject to any of the conditions listed in paragraphs (b) (1) 

through (6) of this Rule.

(d) Nadex shall submit to the Commission a schedule listing all those rule violations which 

constitute disciplinary offenses as defined in paragraph (a)(6)(i) of this Rule and to the extent necessary 

to reflect revisions shall submit an amended schedule within thirty days of the end of each calendar year.

Nadex must maintain and keep current the schedule required by this section, post the schedule in a public 

place designed to provide notice to members and otherwise ensure its availability to the general public.

(e) Nadex shall submit to the Commission within thirty days of the end of each calendar year a 

certified list of any persons who have been removed from its disciplinary committees, arbitration panels, 

oversight panels or governing board pursuant to the requirements of this regulation during the prior year.

(f) Whenever Nadex finds by final decision that a person has committed a disciplinary offense 

and such finding makes such person ineligible to serve on that self-regulatory organization’s disciplinary 

committees, arbitration panels, oversight panels or governing board, Nadex shall inform the Commission 

of that finding and the length of the ineligibility in any notice it is required to provide to the Commission 

pursuant to either section 17(h)(1) of the Act or Commission Regulation 9.11.

RULE 11.3 VOTING BY INTERESTED MEMBERS OF SELF-REGULATORY ORGANIZATION 

GOVERNING BOARDS AND VARIOUS COMMITTEES (ADAPTED FROM 

COMMISSION REGULATION 1.69)

(a) Definitions. For purposes of this section:

(1) Disciplinary committee means any person or committee of persons, or any subcommittee 

thereof, that is authorized by Nadex to issue disciplinary charges, to conduct disciplinary proceedings, to 

settle disciplinary charges, to impose disciplinary sanctions, or to hear appeals thereof in cases involving
78

any violation of the Rules of Nadex except those cases where the person or committee is authorized 

summarily to impose minor penalties for violating Rules regarding decorum, attire, the timely submission 

of accurate records for clearing or verifying each day’s transactions or other similar activities.

(2) Family relationship of a person means the person’s spouse, former spouse, parent, 

stepparent, child, stepchild, sibling, stepbrother, stepsister, grandparent, grandchild, uncle, aunt, nephew, 

niece or in-law.

(3) Governing board means Nadex’s board of directors, board of governors, board of 

managers, or similar body, or any subcommittee thereof, duly authorized, pursuant to a rule of Nadex that 

has been approved by the Commission or has become effective pursuant to Section 5c(c) of the Act and 

Part 40 of the Commission Regulations to take action or to recommend the taking of action on behalf of 

Nadex.

(4) Oversight panel means any panel, or any subcommittee thereof, authorized by Nadex to 

recommend or establish policies or procedures with respect to Nadex’s surveillance, compliance, rule 

enforcement, or disciplinary responsibilities.

(5) Member’s affiliated firm is a firm in which the member is a “principal,” as defined in 

Commission Regulation 3.1(a), or an employee.

(6) Named party in interest means a person or entity that is identified by name as a subject 

of any matter being considered by a governing board, disciplinary committee, or oversight panel.

(7) Self-regulatory organization means a “self-regulatory organization” as defined in 

Commission Regulation 1.3(ee) and includes a “clearing organization” as defined in Commission 

Regulation 1.3(d), but excludes registered futures associations for the purposes of paragraph (b)(2) of this 

section.

(8) Significant action includes any of the following types of Nadex actions or rule changes 

that can be implemented without the Commission’s prior approval:

(i) Any actions or rule changes which address an “emergency” as defined in 

Commission Regulation 40.1; and,

(ii) Any changes in margin levels that are designed to respond to extraordinary 

market conditions such as an actual or attempted corner, squeeze, congestion or undue concentration of 

positions, or that otherwise are likely to have a substantial effect on prices in any contract traded or cleared 

at Nadex; but does not include any rule not submitted for prior Commission approval because such rule is 

unrelated to the terms and conditions of any contract traded at Nadex.

(b) Nadex Rules. Nadex shall maintain in effect Rules that have been submitted to the 

Commission pursuant to Section 5c(c) of the Act and Part 40 of the Commission Regulations to address
79

the avoidance of conflicts of interest in the execution of its self-regulatory functions. Such Rules must 

provide for the following:

(1) Relationship with named party in interest—

(i) Nature of relationship. A member of Nadex’s governing board, disciplinary 

committee or oversight panel must abstain from such body’s deliberations and voting on any matter 

involving a named party in interest where such member:

(A) Is a named party in interest;

(B) Is an employer, employee, or fellow employee of a named party

in interest;

(C) Is associated with a named party in interest through a “broker

association” as defined in Commission Regulation 156.1;

(D) Has any other significant, ongoing business relationship with a 

named party in interest, not including relationships limited to executing futures or option 

transactions opposite of each other or to clearing futures or option transactions through the same 

clearing member; or

(E) Has a family relationship with a named party in interest.

(ii) Disclosure of relationship. Prior to the consideration of any matter involving a 

named party in interest, each member of a Nadex governing board, disciplinary committee or oversight 

panel must disclose to the appropriate Nadex staff whether he or she has one of the relationships listed in 

paragraph (b)(1)(i) of this Rule with a named party in interest.

(iii) Procedure for determination. Nadex must establish procedures for 

determining whether any member of its governing board, disciplinary committees or oversight committees 

is subject to a conflicts restriction in any matter involving a named party in interest. Taking into 

consideration the exigency of the committee action, such determinations should be based upon:

(A) Information provided by the member pursuant to paragraph

(b)(1)(ii) of this Rule; and

available to Nadex.

(B) Any other source of information that is held by and reasonably

(2) Financial interest in a significant action—

(i) Nature of interest. A member of a Nadex governing board, disciplinary 

committee or oversight panel must abstain from such body’s deliberations and voting on any significant
80

action if the member knowingly has a direct and substantial financial interest in the result of the vote based 

upon either exchange or non-exchange positions that could reasonably be expected to be affected by the 

action.

(ii) Disclosure of interest. Prior to the consideration of any significant action, each 

member of a Nadex governing board, disciplinary committee or oversight panel must disclose to the 

appropriate Nadex staff the position information referred to in paragraph (b)(2)(iii) of this Rule that is 

known to him or her. This requirement does not apply to members who choose to abstain from 

deliberations and voting on the subject significant action.

(iii) Procedure for determination. Nadex must establish procedures for determining 

whether any member of its governing board, disciplinary committees or oversight committees is subject 

to a conflicts restriction under this section in any significant action. Such determination must include a 

review of:

(A) Gross positions held at Nadex in the member’s personal 

accounts or “controlled accounts,” as defined in Commission Regulation 1.3(j);

(B) Gross positions held at Nadex in proprietary accounts, as defined 

in Commission Regulation 1.17(b)(3), at the member’s affiliated firm;

(C) Gross positions held at Nadex in accounts in which the member 

is a principal, as defined in Commission Regulation 3.1(a);

(D) Net positions held at Nadex in “customer” accounts, as defined 

in Commission Regulation 1.17(b)(2), at the member’s affiliated firm; and

(E) Any other types of positions, whether maintained at Nadex or 

elsewhere, held in the member’s personal accounts or the proprietary accounts of the member’s 

affiliated firm that the self-regulatory organization reasonably expects could be affected by the 

significant action.

(iv) Bases for determination. Taking into consideration the exigency of the

significant action, such determinations should be based upon:

(A) The most recent large trader reports and clearing records

available to Nadex;

(B) Information provided by the member with respect to positions

pursuant to paragraph (b)(2)(ii) of this Rule; and

(C) Any other source of information that is held by and reasonably

available to Nadex.
81

(3) Participation in deliberations.

(i) Under the Rules required by this section, a Nadex governing board, disciplinary 

committee or oversight panel may permit a member to participate in deliberations prior to a vote on a 

significant action for which he or she otherwise would be required to abstain, pursuant to paragraph (b)(2) 

of this Rule, if such participation would be consistent with the public interest and the member recuses 

himself or herself from voting on such action.

(ii) In making a determination as to whether to permit a member to participate in 

deliberations on a significant action for which he or she otherwise would be required to abstain, the 

deliberating body shall consider the following factors:

(A) Whether the member’s participation in deliberations is 

necessary for the deliberating body to achieve a quorum in the matter; and

(B) Whether the member has unique orspecial expertise, knowledge 

or experience in the matter under consideration.

(iii) Prior to any determination pursuant to paragraph (b)(3)(i) of this Rule, the 

deliberating body must fully consider the position information which is the basis for the member’s direct 

and substantial financial interest in the result of a vote on a significant action pursuant to paragraph (b)(2) 

of this Rule.

(4) Documentation of determination. Nadex’s governing boards, disciplinary committees, 

and oversight panels must reflect in their minutes or otherwise document that the conflicts determination 

procedures required by this section have been followed. Such records also must include:

(i) The names of all members who attended the meeting in person or who otherwise 

were present by electronic means;

(ii) The name of any member who voluntarily recused himself or herself or was 

required to abstain from deliberations and/or voting on a matter and the reason for the recusal or 

abstention, if stated; and

(iii) Information on the position information that was reviewed for each member.

Remainder of page left blank
82

CHAPTER 12 TERMS OF CONTRACTS TRADED ON NADEX

The following Rules set forth the terms of the Contracts traded on Nadex. You should not trade any 

Contract unless you are certain that you completely understand its terms. Additional information with 

respect to each Contract can be found on the home page for the specific Contract.

RULE 12.1 TERMS THAT ARE UNIFORM ACROSS CONTRACTS

There are certain terms that are uniform across Contracts.

(a) The minimum unit of trading for each Contract is one Contract.

(b) All Contract prices are quoted in U.S. dollars and cents per Contract.

(c) The minimum quote increment for each Contract is $.01 per Contract.

(d) All Expiration Values will be posted on Nadex’s website no later than the close of business of 

the Expiration Date of a Contract Series.

(e) At the time Nadex sets the Payout Criterion for any Binary Contract, Nadex will review its 

then-existing Binary Contracts in the same Class having the same Expiration time. No new Binary 

Contract in that same Class and having the same Expiration time will be offered with the same Payout 

Criterion. Instead, in instances where a duplicate Payout Criterion would be generated under the 

applicable product rule, the Payout Criterion for that Contract will be adjusted by pre-determined levels 

which shall be published on the Nadex website.

(f) All Nadex Binary Contracts and Variable Payout Contracts are deemed to be “swaps” as 

defined in 17 USC 1a(47).

(g) Issuance – Except as otherwise provided for in a particular contract’s specifications or where the 

issuance of a contract(s) as described herein may be impacted by a recognized holiday, for each planned 

release by the Source Agency of the Underlying, Nadex will issue various Contracts, each of a different Series. 

A new issuance of Contracts will commence no later than two (2) Business Days following the Expiration 

Date.

(h) Halted Markets - In the event that any market irregularities are declared by the Chief 

Executive Officer of the Exchange, or to prevent or reduce the potential risk of price distortions or market 

disruptions, a market may be paused or halted for trading, and the Commission will be notified, if 

required, pursuant to Commission Regulations. An explanation will be posted on the Nadex Notices 

section of the website within a reasonable amount of time but no later than 24 hours after the initiation 

of the halt.
83

(i) Discretion to Refrain from Listing Contracts - Nadex may, in its discretion, temporarily 

refrain from the listing of any contract due to the unavailability of the underlying market upon which the 

Contract is based, or any other condition Nadex determines may be detrimental to the listing of the 

Contract.

(j) Limit Up/Limit Down - In the event the corresponding underlying market upon which any 

Nadex contract is based is subject to a lock limit up or down, Nadex may halt trading in its related market, 

and/or refrain from listing contracts in that market, until trading resumes in the underlying market. Should 

Nadex halt and/or refrain from listing contracts pursuant to this section, notice of the halt, and any 

adjustments to the settlement process, will be posted on the Notices page as soon as practicable.

(k) Contract Modifications - Specifications shall be fixed as of the first day of trading of a 

contract. If any U.S. governmental agency or body issues an order, ruling, directive or law that conflicts 

with the requirements of these rules, such order, ruling, directive or law shall be construed to take 

precedence and become part of these rules, and all open and new contracts shall be subject to such 

government orders.

(l) Volume Threshold Level - The current Volume Threshold Level is 2506contracts or more 

per day.

(m) Adjustment of Acceptable Bid/Ask Spread for Currency Settlement – Nadex may adjust 

the parameters of the acceptable bid/ask spread in any underlying foreign currency market when 

determining the midpoint price in connection with the collection of market data used in the calculation 

of the expiration value of a Nadex Foreign Currency Binary or Variable Payout contract, as Nadex deems 

necessary or appropriate based on the underlying market conditions in order to produce an accurate 

representation of the underlying market value for settlement purposes. Any adjustment to the acceptable 

spread will be indicated on the Nadex website on the Notices page.

(n) CONTRACT DURATION

(i) Daily Contracts means a Series of Contracts that have an Expiration Date 

within 24 hours after they are issued.

(ii) Intraday Contracts means a Series of Contracts that expire on the same

trade date as, and within nine hours or less, of issuance.

6

The volume threshold level of 250 contracts or more per day was set pursuant to No-Action Letter No. 16-32, issued on April 8, 2016, 

which allows the level to be set at 250 through September 28, 2017. This relief was extended on September 25, 2017 in CFTC Staff Letter 

17-45 and again in Staff Letter 20-30. The 250 volume threshold level will continue until September 29, 2023.
84

(iii) Weekly Contracts mean a Series of Contracts that have an Expiration Date 

that is no less than three calendar days7and no greater than seven calendar days from the date 

on which the Contracts are issued.

(iv) Monthly Contracts means a Series of Contracts that have a Payout 

Criterion based on the last reported level of the Underlying by the Source Agency. Monthly 

Contracts have an Expiration Date that is no less than twenty-one calendar days and no greater 

than thirty-five calendar days from the date on which the last reported level of the Underlying 

is released by the Source Agency.

(v) Open Contracts means a Series of Contracts whose Expiration Date is 

dependent on the Release Date of the underlying Source Agency, and does not follow a 

standardized set pattern.

RULE 12.2 - 12.3 [RESERVED]

RULE 12.4 GOLD VARIABLE PAYOUT CONTRACTS

RULE 12.4.1 GOLD “CALL SPREAD” VARIABLE PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Gold Variable 

Call Spread Payout Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price, per troy ounce (in 

US dollars), of the Gold Futures Contracts (“GFC”) traded on the COMEX® Division of the New York 

Mercantile Exchange (“NYMEX”®)8. The GFC trade prices that will be used for the Underlying will be 

taken from the February, April, June, August, or December GFC delivery months (each a “GFC Delivery 

Month”). The Start and End Date for which Nadex will use a specific delivery month as the Underlying 

will be set based on the Settlement date of the Underlying futures contract. The date on which a new 

delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day 

after the End Date for the previous delivery month contract. The last day on which a delivery month will 

be used as the Underlying for Nadex contracts (i.e. “End Date”) is the third to last Business Day of the 

month preceding the month of the Underlying futures contracts Expiration Date. For example, the Comex 

Gold April 2014 futures have an Expiration Date of April 28, 2014. The last day on which the Gold April

7

In circumstances where the Expiration Date is less than three calendar days from the Contract’s issue date as a result of the 

Source Agency rescheduling the release of the Expiration Value due to a public holiday, the Contract shall nevertheless be 

considered a Weekly Contract.

8 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the 

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
85

2014 futures prices will be used as the Underlying for Nadex contracts and to calculate the Expiration 

Value on the Expiration Date for the relevant Gold contracts will be the third to last Business Day of the 

preceding month, March. Therefore, the End Date for using Comex Gold April 2014 futures will be March 

27, 2014 and the Start Date for the next delivery month, Comex Gold June 2014 futures, will be March 

28, 2014.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Gold Variable Payout Contract, the Payout 

Criteria for the Contracts will be set as follows:

(i) DAILY GOLD CALL SPREAD VARIABLE PAYOUT CONTRACTS, 1:30

PM ET CLOSE - At the commencement of trading in a Daily Gold Call Spread Variable Payout Contract, 

referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout 

Criteria listed below:

(1) DAILY GOLD CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 50.00. 

(bb) FLOOR – The Floor shall be X – 50.00.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(2) In each case, “X” equals the last Gold price, as reported by the Source Agency, rounded to 

the nearest 50.

(ii) DAILY GOLD CALL SPREAD CONTRACTS, 1:30 PM ET CLOSE - Nadex

shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the Payout 

Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 50.

(2) CONTRACT 2: The Ceiling shall be X + 25; The Floor shall be X – 25.

(3) CONTRACT 3: The Ceiling shall be X + 50; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(5) In each case, “X” equals the last Gold price, as reported by the Source Agency, rounded to 

the nearest 50.
86

(iii) INTRADAY GOLD CALL SPREAD CONTRACTS, 8AM ET to 1:30 PM

ET CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which 

conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 40.

(2) CONTRACT 2: The Ceiling shall be X + 20; The Floor shall be X – 20.

(3) CONTRACT 3: The Ceiling shall be X + 40; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(5) In each case, “X” equals the last Gold price, as reported by the Source Agency, rounded to 

the nearest 10.

(iv) INTRADAY 2-HOUR GOLD CALL SPREAD CONTRACTS, 10:00AM,

11:00AM, 12:00PM, and 1:00PM ET CLOSE - Nadex shall list a set of three (3) Call Spread Contracts 

that open 2 hours prior to the stated closing time(s) above with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 15.

(2) CONTRACT 2: The Ceiling shall be X + 7.5; The Floor shall be X – 7.5.

(3) CONTRACT 3: The Ceiling shall be X + 15; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(5) In each case, “X” equals the last Gold price, as reported by the Source Agency, rounded 

to the nearest 10.

(v) Nadex may list additional Call Spread Contracts with different ranges of Payout 

Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Gold Call Spread Contracts shall be 0.10.

(g) POSITION LIMIT – The Position Limits for Gold Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Gold 

Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts per strike 

level.
87

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Gold Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of Gold released by the 

Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency by 

taking all GFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the Gold 

Call Spread Contract, provided at least twenty-five (25) trade prices are captured during the ten (10) 

second period, removing the highest twenty (20) percent of GFC trade prices and the lowest twenty (20) 

percent of GFC trade prices from the data set9, and using the remaining GFC trade prices to calculate the 

Expiration Value. The calculation used is a simple average of the remaining GFC trade prices in the data 

set, rounded to one decimal point past the precision of the underlying market. In the event the time it takes 

to collect at least twenty-five (25) GFC trade prices exceeds the ten (10) seconds just prior to the close of

trading ofthe GoldCall SpreadContract, the Expiration Value is calculated by the Source Agency by taking 

the last twenty-five (25) GFC trade prices just prior to the close of trading of the Gold Call Spread Contract

removing the highest five (5) GFC trade prices and the lowest five (5) GFC trade prices, and using the

remaining fifteen (15) GFC trade prices to calculate the Expiration Value. The calculation used is a simple 

average of all fifteen (15) GFC trade prices, rounded to one decimal point past the precision of the 

underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.4.2 GOLD “TOUCH BRACKET” VARIABLE PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Gold Touch 

Bracket Variable Payout Contracts issued by Nadex.

9

If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
88

(b) UNDERLYING – The Underlying for this Class of Contracts is the price, per troy ounce (in 

US dollars), of the Gold Futures Contracts (“GFC”) traded on the COMEX® Division of the New York 

Mercantile Exchange (“NYMEX”®)10. The GFC trade prices that will be used for the Underlying will be 

taken from the February, April, June, August, or December GFC delivery months (each a “GFC Delivery 

Month”). The Start and End Date for which Nadex will use a specific delivery month as the Underlying 

will be set based on the Settlement date of the Underlying futures contract. The date on which a new 

delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day 

after the End Date for the previous delivery month contract. The last day on which a delivery month will 

be used as the Underlying for Nadex contracts (i.e. “End Date”) is the third to last Business Day of the 

month preceding the month of the Underlying futures contracts Expiration Date. For example, the Comex 

Gold April 2014 futures have an Expiration Date of April 28, 2014. The last day on which the Gold April 

2014 futures prices will be used as the Underlying for Nadex contracts and to calculate the Expiration 

Value on the Expiration Date for the relevant Gold contracts will be the third to last Business Day of the 

preceding month, March. Therefore, the End Date for using Comex Gold April 2014 futures will be March 

27, 2014 and the Start Date for the next delivery month, Comex Gold June 2014 futures, will be March 

28, 2014.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Gold Touch Bracket Contracts, the Payout 

Criteria for the Contracts will be set as follows:

(i) WEEKLY GOLD TOUCH BRACKET VARIABLE PAYOUT CONTRACTS,

Close Time is the earlier of 1:30 PM ET on the last Trade Day of the contract listing, or when the Gold 

Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. Nadex shall list a 

set of four (4) Touch Bracket Variable Payout Contracts, referred to as a “Touch Bracket”, that open at 

6:00PM ET on the first Trade Day of the week, with overlapping ranges, which conform to the Payout 

Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 16; The Floor shall be X – 4.

(2) CONTRACT 1: The Ceiling shall be X + 12; The Floor shall be X – 8.

(3) CONTRACT 1: The Ceiling shall be X + 8; The Floor shall be X – 12.

10 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the 

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
89

(4) CONTRACT 1: The Ceiling shall be X + 4; The Floor shall be X – 16.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(6) In each case, “X” equals the last Gold price, as reported by the Source Agency, rounded 

to the nearest 1.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new Touch 

Bracket with a Ceiling of X + 16 (or 4) and a Floor of X – 4 (or 16) where X equals the Ceiling (or Floor) 

of the Touch Bracket that expired early. The newly listed Touch Bracket will have the same Last Trade 

Day as originally established for the expired Touch Bracket and the same Dollar Multiplier as the expired 

Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for Gold Touch Bracket Variable Payout 

Contracts shall be 0.1.

(g) POSITION LIMIT – The Position Limit for Gold Touch Bracket Variable Payout Contracts 

shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Gold 

Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 Contracts per 

strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Gold Touch Bracket Contract Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) GOLD INDEX VALUE – The Source Agency shall calculate and produce a Gold Index Value 

once each second throughout the life of the Gold Variable Payout Contracts. That is, each second the 

Source Agency will calculate a Gold Index Value by taking all GFC trade prices occurring in the ten (10) 

seconds leading up to the Calculation Time, provided at least twenty-five (25) trade prices are captured 

during the ten (10) second period, removing the highest twenty (20) percent of GFC trade prices and the
90

lowest twenty (20) percent of GFC trade prices from the data set11, and using the remaining GFC trade 

prices to calculate the Index Value. The calculation used is a simple average of the remaining GFC trade 

prices in the data set, rounded to one decimal point past the precision of the underlying market. In the 

event the time it takes to collect at least twenty-five (25) GFC trade prices exceeds the ten (10) seconds 

just prior to the Calculation Time, the Index Value is calculated by the Source Agency by taking the last 

twenty-five (25) GFC trade prices just prior to the Calculation Time removing the highest five (5) GFC 

trade prices and the lowest five (5) GFC trade prices, and using the remaining fifteen (15) GFC trade 

prices to calculate the Index Value. The calculation used is a simple average of all fifteen (15) GFC trade 

prices, rounded to one decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the Gold Index Value as released by the 

Source Agency at Expiration.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.5 GOLD BINARY CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Gold Binary 

Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price, per troy ounce (in 

US dollars), of Gold obtained from the Gold Futures Contracts (“GFC”) traded on the COMEX Division 

of the New York Mercantile Exchange (“NYMEX®”)12. The GFC trade prices that will be used for the 

Underlying will be taken from the February, April, June, August, or December GFC delivery months (each 

a “GFC Delivery Month”). The Start and End Date for which Nadex will use a specific delivery month

as the Underlying will be set based on the Settlement date of the Underlying futures contract. The date on

which a new delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one

calendar day after the End Date for the previous delivery month contract. The last day on which a delivery 

month will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the third to last Business

Day of the month preceding the month of the Underlying futures contracts Expiration Date. For example,

the Comex Gold April 2014 futures have an Expiration Date of April 28, 2014. The last day on which the 

Gold April 2014 futures prices will be used as the Underlying for Nadex contracts and to calculate the

Expiration Value on the Expiration Date for the relevant Gold contracts will be the third to

11 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.

12 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
91

last Business Day of the preceding month, March. Therefore, the End Date for using Comex Gold April 

2014 futures will be March 27, 2014 and the Start Date for the next delivery month, Comex Gold June 

2014 futures, will be March 28, 2014.13

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the Gold Binary Contract, the Payout Criteria for the 

Contracts will be set as follows:

(i) WEEKLY GOLD BINARY CONTRACTS

(1) EXPIRATION TIME – 1:30PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

10.0.

(3) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will be listed for 

each Weekly Gold Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “W” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in 0.5 as reported 

by the Source Agency. Six (6) strike levels will be generated above Binary Contract W 

at an interval of 10.0, and six (6) strike levels will be generated below Binary Contract 

W at an interval of 10.0 (e.g. W – 10.0; W; W + 10.0). The Contract will have a Payout 

Criterion of greater than the strike level value.

(ii) DAILY GOLD BINARY CONTRACTS

(1) EXPIRATION TIME – 1:30PM ET CLOSE

13 Weekly contracts listed on a Monday during a week containing an Underlying futures rollover date will be listed using the 

Underlying futures month scheduled to be used to determine the settlement value on the day the contract expires. For 

example, the End Date for which Nadex will use the Comex Gold April 2014 Underlying futures to determine the settlement 

value is March 27, 2014. March 27, 2014 is a Thursday, however, and any Nadex weekly contracts listed for this roll week 

and expiring on Friday, March 28, 2014, will be listed using the Comex Gold June 2014 futures as its Underlying, as June is 

the futures month scheduled to be used to determine the Settlement Value of the Nadex weekly contract on its expiration 

date. Therefore, the Start Date for the Comex Gold June 2014 futures will be Monday, March 24, 2014 for any Nadex 

weekly contracts listed on this date.
92

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 3.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels will be listed 

for each Daily Gold Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Y” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in 1.0 as 

reported by the Source Agency. Ten (10) strike levels will be generated above Binary 

Contract Y at an interval of 3, and ten (10) strike levels will be generated below Binary 

Contract Y at an interval of 3 (e.g. Y – 3; Y; Y + 3). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iii) INTRADAY GOLD BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 11:00AM, 12:00PM, 1:00PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 3.

(3) NUMBER OF STRIKE LEVELS LISTED - Nine (9) strike levels will be listed for each 

Intraday Gold Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be

measured in U.S. centsrounded to the nearest value ending in 0.1 asreported by the Source

Agency. Four (4) strike levels will be generated above Binary Contract Z at an interval 

of 3, and four (4) strike levels will be generated below Binary Contract Z at an interval 

of 3 (e.g. Z – 3; Z; Z + 3). The Contract will have a Payout Criterion of greater than the 

strike level value.

(iv) Nadex may list additional Gold Binary Contract with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Gold Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for the Gold Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Gold 

Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.
93

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration 

Date. No trading in the Gold Binary Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the

Gold Expiration Value is to be released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money Gold Binary Contract is

$100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of Gold released by the 

Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency by 

taking all GFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the Gold 

Binary Contract, provided at least twenty-five (25) trade prices are captured during the ten (10) second 

period, removing the highest twenty (20) percent of GFC trade prices and the lowest twenty (20) percent 

of GFC trade prices from the data set14, and using the remaining GFC trade prices to calculate the 

Expiration Value. The calculation used is a simple average of the remaining GFC trade prices in the data 

set, rounded to one decimal point past the precision of the underlying market. In the event the time it takes 

to collect at least twenty-five (25) GFC trade prices exceeds the ten (10) seconds just prior to the close of

trading of the Gold Binary Contract, the Expiration Value is calculated by the Source Agency by taking 

the last twenty-five (25) GFC trade prices just prior to the close of trading of the Gold Binary Contract 

removing the highest five (5) GFC trade prices and the lowest five (5) GFC trade prices, and using the

remaining fifteen (15) GFC trade prices to calculate the Expiration Value. The calculation used is a simple 

average of all fifteen (15) GFC trade prices, rounded to one decimal point past the precision of the 

underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series. If there are less than 250 GFC trade 

prices available during a single trading day prior to the issuance of a new Gold Contract Nadex may switch 

to the next available GFC Delivery Month that provides at least 250 GFC trade prices.

14 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
94

RULE 12.6 SILVER VARIABLE PAYOUT CONTRACTS

RULE 12.6.1 SILVER “CALL SPREAD” VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Silver Call Spread 

Variable Payout Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price, cents per troy ounce 

(in US Currency), of Silver obtained from the Silver Futures Contracts (“SFC”) traded on the COMEX 

Division of the New York Mercantile Exchange (“NYMEX”®15). The SFC trade prices that will be used 

to for the Underlying will be taken from the March, May, July, September, or December SFC delivery 

months (each a “SFC Delivery Month”). The Start and End Date for which Nadex will use a specific 

delivery month as the Underlying will be set based on the Settlement date of the Underlying futures 

contract. The date on which a new delivery month will be used as the Underlying for Nadex contracts (i.e. 

“Start Date”) is one calendar day after the End Date for the previous delivery month contract. The last 

day on which a delivery month will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the 

third to last Business Day of the month preceding the month of the Underlying futures contracts Expiration 

Date. For example, the Comex Silver March 2014 futures have an Expiration Date of March 27, 2014.

The last day on which the Silver March 2014 futures prices will be used as the Underlying for Nadex 

contracts and to calculate the Expiration Value on the Expiration Date for the relevant Silver contracts

will be the third to last Business Day of the preceding month, February. Therefore, the End Date for using 

Comex Silver March 2014 futures will be February 26, 2014 and the Start Date for the next delivery 

month, Comex Silver May 2014 futures, will be February 27, 2014.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Silver Call Spread Variable Payout 

Contract, the Payout Criteria for the Contracts will be set as follows;

(i) DAILY SILVER CALL SPREAD VARIABLE PAYOUT CONTRACTS, 1:25

PM ET CLOSE - At the commencement of trading in a Daily Call Spread Silver Variable Payout Contract, 

referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout 

Criteria listed below:

15 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the 

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
95

(1) DAILY SILVER CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 2.00. 

(bb) FLOOR – The Floor shall be X – 2.00.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last Silver price, as reported by the Source Agency, rounded 

to the nearest .50.

(ii) DAILY SILVER CALL SPREAD CONTRACTS, 1:25 PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, 

which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 2.00.

(2) CONTRACT 2: The Ceiling shall be X + 1.00; The Floor shall be X – 1.00.

(3) CONTRACT 3: The Ceiling shall be X + 2.00; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last Silver price, as reported by the Source Agency, rounded 

to the nearest .50.

(iii) INTRADAY SILVER CALL SPREAD CONTRACTS, 8AM ET

to 1:25 PM ET CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with 

overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 1.50.

(2) CONTRACT 2: The Ceiling shall be X + .075; The Floor shall be X – .075.

(3) CONTRACT 3: The Ceiling shall be X + 1.50; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last Silver price, as reported by the Source Agency, rounded 

to the nearest .25.

(iv) INTRADAY 2-HOUR SILVER CALL SPREAD CONTRACTS,

10:00AM, 11:00AM, 12:00PM, and 1:00PM ET CLOSE - Nadex shall list a set of three (3)
96

Call Spread Contracts that open 2 hours prior to the stated closing time(s) above with 

overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – .50.

(2) CONTRACT 2: The Ceiling shall be X + .25; The Floor shall be X – .25.

(3) CONTRACT 3: The Ceiling shall be X + .50; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last Silver price, as reported by the Source Agency, rounded 

to the nearest .25.

(v) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Silver Call Spread Contracts shall be .01.

(g) POSITION LIMIT – The Position Limits for Silver Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Silver 

Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts per strike 

level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Silver Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE –The Expiration Value is the price or value of Silver Index Value 

released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is calculated 

by the Source Agency by taking all SFC trade prices occurring in the ten (10) seconds leading up to the 

close of trading of the Silver Call Spread Contract, provided at least twenty-five (25) trade prices are 

captured during the ten (10) second period, removing the highest twenty (20) percent of SFC trade prices
97

and the lowest twenty (20) percent of SFC trade prices from the data set16, and using the remaining SFC 

trade prices to calculate the Expiration Value. The calculation used is a simple average of the remaining 

SFC trade prices in the data set, rounded to one decimal point past the precision of the underlying market. 

In the event the time it takes to collect at least twenty-five (25) SFC trade prices exceeds the ten (10) 

seconds just prior to the close of trading of the Silver Call Spread Contract, the Expiration Value is 

calculated by the Source Agency by taking the last twenty-five (25) SFC trade prices just prior to the close 

of trading of the Silver Call Spread Contract removing the highest five (5) SFC trade prices and the lowest 

five (5) SFC trade prices, and using the remaining fifteen (15) SFC trade prices to calculate the Expiration 

Value. The calculation used is a simple average of all fifteen (15) SFC trade prices, rounded to one decimal 

point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series. If there are less than 250 SFC trade 

prices available during a single trading day prior to the issuance of a new Silver Contract Nadex may 

switch to the next available SFC Delivery Month that provides at least 250 SFC trade prices.

RULE 12.6.2 SILVER “TOUCH BRACKET” VARIABLE PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Silver Touch 

Bracket Variable Payout Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price, cents per troy ounce 

(in US Currency), of Silver obtained from the Silver Futures Contracts (“SFC”) traded on the COMEX 

Division of the New York Mercantile Exchange (“NYMEX”®17). The SFC trade prices that will be used 

to for the Underlying will be taken from the March, May, July, September, or December SFC delivery 

months (each a “SFC Delivery Month”). The Start and End Date for which Nadex will use a specific 

delivery month as the Underlying will be set based on the Settlement date of the Underlying futures 

contract. The date on which a new delivery month will be used as the Underlying for Nadex contracts (i.e. 

“Start Date”) is one calendar day after the End Date for the previous delivery month contract. The last 

day on which a delivery month will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the 

third to last Business Day of the month preceding the month of the Underlying futures contracts Expiration 

Date. For example, the Comex Silver March 2014 futures have an Expiration Date of March 27, 2014.

The last day on which the Silver March 2014 futures prices will be used as the Underlying for

16 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.

17 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
98

Nadex contracts and to calculate the Expiration Value on the Expiration Date for the relevant Silver 

contracts will be the third to last Business Day of the preceding month, February. Therefore, the End Date 

for using Comex Silver March 2014 futures will be February 26, 2014 and the Start Date for the next 

delivery month, Comex Silver May 2014 futures, will be February 27, 2014.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Silver Touch Bracket Contracts, the Payout 

Criteria for the Contracts will be set as follows:

(i) WEEKLY SILVER TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 1:25 PM ET on the last Trade Day of the contract listing, or 

when the Silver Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a “Touch 

Bracket”, that open at 3:00AM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.6; The Floor shall be X – 0.15.

(2) CONTRACT 1: The Ceiling shall be X + 0.45; The Floor shall be X – 0.3.

(3) CONTRACT 1: The Ceiling shall be X + 0.3; The Floor shall be X – 0.45.

(4) CONTRACT 1: The Ceiling shall be X + 0.15; The Floor shall be X – 0.6.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(6) In each case, “X” equals the last Crude Oil price, as reported by the Source Agency, 

rounded to the nearest 0.25.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new Touch 

Bracket with a Ceiling of X + 0.6 (or 0.15) and a Floor of X – 0.15 (or 0.6) where X equals the Ceiling 

(or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have the same 

Last Trade Day as originally established for the expired Touch Bracket and the same Dollar Multiplier as 

the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for Silver Touch Bracket Variable Payout 

Contracts shall be 0.01.
99

(g) POSITION LIMIT – The Position Limit for Silver Touch Bracket Variable Payout Contracts 

shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Silver 

Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 Contracts per 

strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Silver Touch Bracket Contract Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) SILVER INDEX VALUE – The Source Agency shall calculate and produce a Silver Index 

Value once each second throughout the life of the Silver Variable Payout contracts. That is, each second 

the Source Agency will calculate a Silver Index Value by taking all SFC trade prices occurring in the ten

(10) seconds leading up to the Calculation Time, provided at least twenty-five (25) trade prices are 

captured during the ten (10) second period, removing the highest twenty (20) percent of SFC trade prices 

and the lowest twenty (20) percent of SFC trade prices in the data set18, and using the remaining SFC trade 

prices in the data set, to calculate the Index Value. The calculation used is a simple average of the 

remaining SFC trade prices in the data set, rounded to one decimal point past the precision of the 

underlying market. In the event the time it takes to collect at least twenty-five (25) SFC trade prices 

exceeds the ten (10) seconds just prior to the Calculation Time, the Index Value is calculated by the Source 

Agency by taking the last twenty-five (25) SFC trade prices just prior to the Calculation Time, removing 

the highest five (5) SFC trade prices and the lowest five (5) SFC trade prices, and using the remaining 

fifteen (15) SFC trade prices to calculate the Index Value. The calculation used is a simple average of all 

fifteen (15) SFC trade prices, rounded to one decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the Silver Index Value as released by the 

Source Agency at Expiration.

18 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
100

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.7 SILVER BINARY CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Silver Binary 

Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price, cents per troy ounce 

(in US Currency), of Silver obtained from the Silver Futures Contracts (“SFC”) traded on the COMEX 

Division of the New York Mercantile Exchange (“NYMEX”®19). The SFC trade prices that will be used 

to for the Underlying will be taken from the March, May, July, September, or December SFC delivery 

months (each a “SFC Delivery Month”). The Start and End Date for which Nadex will use a specific 

delivery month as the Underlying will be set based on the Settlement date of the Underlying futures 

contract. The date on which a new delivery month will be used as the Underlying for Nadex contracts (i.e. 

“Start Date”) is one calendar day after the End Date for the previous delivery month contract. The last 

day on which a delivery month will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the 

third to last Business Day of the month preceding the month of the Underlying futures contracts Expiration 

Date. For example, the Comex Silver March 2014 futures have an Expiration Date of March 27, 2014.

The last day on which the Silver March 2014 futures prices will be used as the Underlying for Nadex 

contracts and to calculate the Expiration Value on the Expiration Date for the relevant Silver contracts

will be the third to last Business Day of the preceding month, February. Therefore, the End Date for using 

Comex Silver March 2014 futures will be February 26, 2014 and the Start Date for the next delivery 

month, Comex Silver May 2014 futures, will be February 27, 2014.20

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Binary Contract.

19 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the 

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.

20 Weekly contracts listed on a Monday during a week containing an Underlying futures rollover date will be listed using the

Underlying futures month scheduled to be used to determine the settlement value on the day the contract expires. For 

example, the End Date for which Nadex will use the Comex Silver March 2014 Underlying futures to determine the 

settlement value is February 26, 2014. February 26, 2014 is a Wednesday, however, and any Nadex weekly contracts listed 

for this roll week and expiring on Friday, February 28, 2014, will be listed using the Comex Silver May 2014 futures as its 

Underlying, as May is the futures month scheduled to be used to determine the Settlement Value of the Nadex weekly 

contract on its expiration date. Therefore, the Start Date for the Comex Silver May 2014 futures will be Monday, February 

24, 2014 for any Nadex weekly contracts listed on this date.
101

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the Silver Binary Contract, the Payout Criteria for the 

Contracts will be set as follows:

(i) INTRADAY SILVER BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 11:00AM, 12:00PM, 1:00PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

0.06.

(3) NUMBER OF STRIKE LEVELS LISTED - Nine (9) strike levels will be listed for each 

Intraday Silver Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in 0.01 as reported by the 

Source Agency. Four (4) strike levels will be generated above Binary Contract Z at an

interval of 0.06, and four (4)strike levels will be generated below Binary Contract Z at an 

interval of 0.06 (e.g. Z – 0.06; Z; Z + 0.06). The Contract will have a Payout Criterion of 

greater than the strike level value.

(ii) Nadex may list additional Silver Binary Contract with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Silver Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for Silver Binary Contracts shall be 2,000 Contracts 

per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for Silver 

Binary Contracts for contracted Market Makers shall be 4,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration

Date.

(j) SETTLEMENT DATE – The Settlement Date will be the same date as the Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the

Silver price is released by the Source Agency.
102

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money Silver Binary Contract is

$100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of Silver released by the 

Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency by 

taking all SFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the Silver 

Binary Contract, provided at least twenty-five (25) trade prices are captured during the ten (10) second 

period, removing the highest twenty (20) percent of SFC trade prices and the lowest twenty (20) percent 

of SFC trade prices from the data set21, and using the remaining SFC trade prices to calculate the 

Expiration Value. The calculation used is a simple average of the remaining SFC trade prices in the data 

set, rounded to one decimal point past the precision of the underlying market. In the event the time it takes 

to collect at least twenty-five (25) SFC trade prices exceeds the ten (10) seconds just prior to the close of 

trading of the Silver Binary Contract, the Expiration Value is calculated by the Source Agency by taking 

the last twenty-five (25) SFC trade prices just prior to the close of trading of the Silver Binary Contract

removing the highest five (5) SFC trade prices and the lowest five (5) SFC trade prices, and using the 

remaining fifteen (15) SFC trade prices to calculate the Expiration Value. The calculation used is a simple

average of all fifteen (15) SFC trade prices, rounded to one decimal point past the precision of the 

underlying market.

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series. If there are less than 250 SFC trade 

prices available during a single trading day prior to the issuance of a new Silver Contract Nadex may 

switch to the next available SFC Delivery Month that provides at least 250 SFC trade prices.

RULE 12.8 CRUDE OIL VARIABLE PAYOUT CONTRACTS

RULE 12.8.1 CRUDE OIL “CALL SPREAD” VARIABLE PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Crude Oil Call 

Spread Variable Payout Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is WTI Light, Sweet Crude Oil 

price per barrel (in US dollars), obtained from the WTI Light, Sweet Crude Oil Futures contracts (“CFC”)

21 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
103

traded on the New York Mercantile Exchange (“NYMEX®”22). The CFC trade prices that will be used 

for the Underlying will be taken from all twelve CFC delivery months: January, February, March, April, 

May, June, July, August, September, October, November, or December (each a “CFC Delivery Month”). 

The date on which a new delivery month will be used as the Underlying for Nadex contracts (i.e. “Start 

Date”) is one calendar day after the End Date for the previous delivery month contract. The last day on 

which a delivery month will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday 

of the week preceding the Underlying futures contracts Expiration Date. If the Underlying futures 

contracts Expiration Date falls on a Monday, the End Date for that specific delivery month will be the 

Friday of the week preceding the week of the Underlying futures contracts Expiration Date, i.e. not the 

Friday that is one Business Day prior to the Monday Expiration Date. For example, the Nymex Crude Oil 

March 2012 futures have an Expiration Date of February 21, 2012. The last day on which the Crude Oil 

March 2012 futures prices will be used as the Underlying for Nadex contracts and to calculate the 

Expiration Value on the Expiration Date for the relevant Crude Oil contracts will be the Friday of the 

preceding week. Therefore, the End Date for using Nymex Crude Oil March 2012 futures will be February 

17, 2012 and the Start Date for the next delivery month, Nymex Crude Oil April 2012 futures, will be 

February 18, 2012. The Nymex Crude Oil November 2012 futures, however, have an Expiration Date of 

Monday, October 22, 2012. The last day on which the Crude Oil November 2012 futures prices will be 

as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date for 

the relevant Crude Oil contracts will be October 12, 2012, rather than October 19, 2012, and the Start Date 

for the next delivery month, Nymex Crude Oil December 2012 futures will be October 13, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Crude Oil Variable Payout Contract, the 

Payout Criteria for the Contracts will be set as follows;

(i) DAILY CRUDE OIL CALL SPREAD VARIABLE PAYOUT CONTRACTS,

2:30 PM ET CLOSE - At the commencement of trading in a Daily Crude Oil Call Spread Variable Payout 

Contract, referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Contract, which conforms to 

the Payout Criteria listed below:

(1) DAILY CRUDE OIL CALL SPREAD CONTRACT

22 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the 

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
104

(aa) CEILING – The Ceiling shall be X + 5. 

(bb) FLOOR – The Floor shall be X – 5.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last Crude Oil price, as reported by the Source Agency, 

rounded to the nearest 1.

(ii) DAILY CRUDE OIL CALL SPREAD CONTRACTS, 2:30 PM ET CLOSE -

Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 5.

(2) CONTRACT 2: The Ceiling shall be X + 2.50; The Floor shall be X – 2.50.

(3) CONTRACT 3: The Ceiling shall be X + 5; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last Crude Oil price, as reported by the Source Agency, 

rounded to the nearest 1.

(iii) INTRADAY CRUDE OIL CALL SPREAD CONTRACTS, 8AM ET to 2:30

PM ET CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which 

conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 3.

(2) CONTRACT 2: The Ceiling shall be X + 1.50; The Floor shall be X – 1.50.

(3) CONTRACT 3: The Ceiling shall be X + 3; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last Crude Oil price, as reported by the Source Agency, 

rounded to the nearest 0.50.

(iv) INTRADAY 2-HOUR CRUDE OIL CALL SPREAD CONTRACTS,

10:00AM, 11:00AM, 12:00PM, 1:00PM and 2:00PM ET CLOSE - Nadex shall list a set of five (5) Call 

Spread Contracts that open 2 hours prior to the stated closing time(s) above with overlapping ranges, 

which conform to the Payout Criteria listed below:
105

(1) CONTRACT 1: The Ceiling shall be X – 0.75; The Floor shall be X – 2.25.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 1.50.

(3) CONTRACT 3: The Ceiling shall be X + 0.75; The Floor shall be X – 0.75.

(4) CONTRACT 4: The Ceiling shall be X + 1.50; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 2.25; The Floor shall be X + 0.75.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(7) In each case, “X” equals the last Crude Oil price, as reported by the Source Agency, 

rounded to the nearest 0.25.

(v) Nadex may list additional Call Spread Contracts with different ranges of Payout 

Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Crude Oil Call Spread Contracts shall be 0.01.

(g) POSITION LIMIT – The Position Limits for Crude Oil Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Crude 

Oil Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts per strike 

level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

Crude Oil Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of Crude Oil released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all CFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the 

Crude Oil Call Spread Contract, provided at least twenty-five (25) trade prices are captured during the
106

ten (10) second period, removing the highest twenty (20) percent of CFC trade prices and the lowest 

twenty (20) percent of CFC trade prices in the data set23, and using the remaining CFC trade prices in the 

data set, to calculate the Expiration Value. The calculation used is a simple average of the remaining 

CFC trade prices in the data set, rounded to one decimal point past the precision of the underlying market. 

In the event the time it takes to collect at least twenty-five (25) CFC trade prices exceeds the ten (10) 

seconds just prior to the close of trading of the Crude Oil Call Spread Contract, the Expiration Value is 

calculated by the Source Agency by taking the last twenty-five (25) CFC trade prices just prior to the 

close of trading of the Crude Oil Call Spread Contract removing the highest five (5) CFC trade prices 

and the lowest five (5) CFC trade prices, and using the remaining fifteen (15) CFC trade prices to 

calculate the Expiration Value. The calculation used is a simple average of all fifteen (15) CFC trade 

prices, rounded to one decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.8.2 CRUDE OIL “TOUCH BRACKET” VARIABLE PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Crude Oil Touch 

Bracket Variable Payout Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is WTI Light, Sweet Crude Oil 

price per barrel (in US dollars), obtained from the WTI Light, Sweet Crude Oil Futures contracts (“CFC”) 

traded on the New York Mercantile Exchange (“NYMEX®”24). The CFC trade prices that will be used 

for the Underlying will be taken from all twelve CFC delivery months: January, February, March, April, 

May, June, July, August, September, October, November, or December (each a “CFC Delivery Month”). 

The date on which a new delivery month will be used as the Underlying for Nadex contracts (i.e. “Start 

Date”) is one calendar day after the End Date for the previous delivery month contract. The last day on 

which a delivery month will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday 

of the week preceding the Underlying futures contracts Expiration Date. If the Underlying futures 

contracts Expiration Date falls on a Monday, the End Date for that specific delivery month will be the 

Friday of the week preceding the week of the Underlying futures contracts Expiration Date, i.e. not the 

Friday that is one Business Day prior to the Monday Expiration Date. For example, the Nymex Crude Oil

23 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.

24 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
107

March 2012 futures have an Expiration Date of February 21, 2012. The last day on which the Crude Oil 

March 2012 futures prices will be used as the Underlying for Nadex contracts and to calculate the 

Expiration Value on the Expiration Date for the relevant Crude Oil contracts will be the Friday of the 

preceding week. Therefore, the End Date for using Nymex Crude Oil March 2012 futures will be February 

17, 2012 and the Start Date for the next delivery month, Nymex Crude Oil April 2012 futures, will be 

February 18, 2012. The Nymex Crude Oil November 2012 futures, however, have an Expiration Date of 

Monday, October 22, 2012. The last day on which the Crude Oil November 2012 futures prices will be 

as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date for 

the relevant Crude Oil contracts will be October 12, 2012, rather than October 19, 2012, and the Start Date 

for the next delivery month, Nymex Crude Oil December 2012 futures will be October 13, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Crude Oil Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY CRUDE OIL TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 2:30 PM ET on the last Trade Day of the contract listing, or 

when the Crude Oil Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a “Touch 

Bracket”, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 1.2; The Floor shall be X – 0.3.

(2) CONTRACT 1: The Ceiling shall be X + 0.9; The Floor shall be X – 0.6.

(3) CONTRACT 1: The Ceiling shall be X + 0.6; The Floor shall be X – 0.9.

(4) CONTRACT 1: The Ceiling shall be X + 0.3; The Floor shall be X – 1.2.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(6) In each case, “X” equalsthe last Crude Oil price, as reported by the Source Agency, rounded 

to the nearest 0.25.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new Touch 

Bracket with a Ceiling of X + 1.2 (or 0.3) and a Floor of X – 0.3 (or 1.2) where X equals the Ceiling (or 

Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have the same Last
108

Trade Day as originally established for the expired Touch Bracket and the same Dollar Multiplier as the 

expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for Crude Oil Touch Bracket Variable Payout 

Contracts shall be 0.01.

(g) POSITION LIMIT – The Position Limit for Crude Oil Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Crude 

Oil Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Crude Oil Touch Bracket Contract Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) CRUDE OIL INDEX VALUE – The Source Agency shall calculate and produce a Crude Oil 

Index Value once each second throughout the life of the Crude Oil Variable Payout contracts. That is, 

each second the Source Agency will calculate a Crude Oil Index Value by taking all CFC trade prices 

occurring in the ten (10) seconds leading up to the Calculation Time, provided at least twenty-five (25) 

trade prices are captured during the ten (10) second period, removing the highest twenty (20) percent of 

CFC trade prices and the lowest twenty (20) percent of CFC trade prices in the data set25, and using the 

remaining CFC trade prices in the data set, to calculate the Index Value. The calculation used is a simple 

average of the remaining CFC trade prices in the data set, rounded to one decimal point past the precision 

of the underlying market. In the event the time it takes to collect at least twenty-five (25) CFC trade prices 

exceeds the ten (10) seconds just prior to the Calculation Time, the Index Value is calculated by the Source

Agency by taking the last twenty-five (25) CFC trade prices just prior to the Calculation Time

25 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
109

removing the highest five (5) CFC trade prices and the lowest five (5) CFC trade prices, and using the 

remaining fifteen (15) CFC trade prices to calculate the Index Value. The calculation used is a simple 

average of all fifteen (15) CFC trade prices, rounded to one decimal point past the precision of the 

underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the Crude Oil Index Value as released by 

the Source Agency at Expiration.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.9 CRUDE OIL BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Crude Oil Binary 

Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is WTI Light, Sweet Crude Oil 

price per barrel (in US dollars), obtained from the WTI Light, Sweet Crude Oil Futures contracts (“CFC”) 

traded on the New York Mercantile Exchange (“NYMEX®”26). The CFC trade prices that will be used 

for the Underlying will be taken from all twelve CFC delivery months: January, February, March, April, 

May, June, July, August, September, October, November, or December (each a “CFC Delivery Month”). 

The date on which a new delivery month will be used as the Underlying for Nadex contracts (i.e. “Start 

Date”) is one calendar day after the End Date for the previous delivery month contract. The last day on 

which a delivery month will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday 

of the week preceding the Underlying futures contracts Expiration Date. If the Underlying futures 

contracts Expiration Date falls on a Monday, the End Date for that specific delivery month will be the 

Friday of the week preceding the week of the Underlying futures contracts Expiration Date, i.e. not the 

Friday that is one Business Day prior to the Monday Expiration Date. For example, the Nymex Crude Oil 

March 2012 futures have an Expiration Date of February 21, 2012. The last day on which the Crude Oil 

March 2012 futures prices will be used as the Underlying for Nadex contracts and to calculate the 

Expiration Value on the Expiration Date for the relevant Crude Oil contracts will be the Friday of the 

preceding week. Therefore, the End Date for using Nymex Crude Oil March 2012 futures will be February 

17, 2012 and the Start Date for the next delivery month, Nymex Crude Oil April 2012 futures, will be 

February 18, 2012. The Nymex Crude Oil November 2012 futures, however, have an Expiration Date of 

Monday, October 22, 2012. The last day on which the Crude Oil November 2012 futures prices will be 

as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date for

26 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the 

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
110

the relevant Crude Oil contracts will be October 12, 2012, rather than October 19, 2012, and the Start Date 

for the next delivery month, Nymex Crude Oil December 2012 futures will be October 13, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the Crude Oil Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY CRUDE OIL BINARY CONTRACTS

(1) EXPIRATION TIME – 2:30PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

1.00.

(3) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will be listed for 

each Weekly Crude Oil Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “W” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in either 0.25 or

0.75 as reported by the Source Agency. Six (6) strike levels will be generated above 

Binary Contract W at an interval of 1.00, and six (6) strike levels will be generated below 

Binary Contract W at an interval of 1.00 (e.g. W – 1.00; W; W + 1.00). The Contract will 

have a Payout Criterion of greater than the strike level value.

(ii) DAILY CRUDE OIL BINARY CONTRACTS

(1) EXPIRATION TIME – 2:30PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

0.40.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-three (23)strike levels will be listed 

for each Daily Crude Oil Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Y” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts,
111

and shall be measured in U.S. cents rounded to the nearest value ending in 0.5 as 

reported by the Source Agency. Eleven (11) strike levels will be generated above Binary 

Contract Y at an interval of 0.40, and eleven (11) strike levels will be generated below 

Binary Contract Y at an interval of 0.40 (e.g. Y – 0.40; Y; Y + 0.40). The Contract will 

have a Payout Criterion of greater than the strike level value.

(iii) INTRADAY CRUDE OIL BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

0.2.

(3) NUMBER OF STRIKE LEVELS LISTED - Nine (9) strike levels will be listed for each 

Intraday Crude Oil Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in 0.01 as reported by the 

Source Agency. Four (4) strike levels will be generated above Binary Contract Z at an

interval of 0.2, and four (4) strike levels will be generated below Binary Contract Z at an

interval of 0.2 (e.g. Z – 0.2; Z; Z + 0.2). The Contract will have a Payout Criterion of 

greater than the strike level value.

(iv) Nadex may list additional Crude Oil Binary Contract with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the Crude Oil Binary Contract shall be $0.25.

(g) POSITION LIMIT – The Position Limits for the Crude Oil Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Crude 

Oil Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration

Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date on which the Crude Oil Binary

Contract as reported by the Source Agency.
112

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

Crude Oil price or level is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on the Settlement Date. The Settlement Value of an in the money Crude Oil Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of Crude Oil released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all CFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the 

Crude Oil Binary Contract, provided at least twenty-five (25) trade prices are captured during the ten (10) 

second period, removing the highest twenty (20) percent of CFC trade prices and the lowest twenty (20) 

percent of CFC trade prices in the data set27, and using the remaining CFC trade prices in the data set, to 

calculate the Expiration Value. The calculation used is a simple average of the remaining CFC trade prices 

in the data set, rounded to one decimal point past the precision of the underlying market. In the event the 

time it takes to collect at least twenty-five (25) CFC trade prices exceeds the ten (10) seconds just prior to 

the close of trading of the Crude Oil Binary Contract, the Expiration Value is calculated by the Source 

Agency by taking the last twenty-five (25) CFC trade prices just prior to the close of trading of the Crude 

Oil Binary Contract removing the highest five (5) CFC trade prices and the lowest five (5) CFC trade

prices, and using the remaining fifteen (15) CFC trade prices to calculate the Expiration Value. The

calculation used is a simple average of all fifteen (15) CFC trade prices, rounded to one decimal point past 

the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.10 NATURAL GAS VARIABLE PAYOUT CONTRACTS

RULE 12.10.1 NATURAL GAS “CALL SPREAD” VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Natural Gas Call 

Spread Variable Payout Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Natural Gas price per 

mmBtu (millions British thermal units, in US dollars), obtained from the Natural Gas Futures contracts

27 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
113

(“NFC”) traded on the New York Mercantile Exchange (“NYMEX”®).28 The NFC trade prices that will 

be used for the Underlying will be taken from all twelve NFC delivery months: January, February, March, 

April, May, June, July, August, September, October, November, or December (each an “NFC Delivery 

Month”). The date on which a new delivery month will be used as the Underlying for Nadex contracts 

(i.e. “Start Date”) is one calendar day after the End Date for the previous delivery month contract. The 

last day on which a delivery month will be used as the Underlying for Nadex contracts (i.e. “End Date”) 

is the Friday of the week preceding the Underlying futures contracts Expiration Date. If the Underlying 

futures contracts Expiration Date falls on a Monday, the End Date for that specific delivery month will be 

the Friday of the week preceding the week of the Underlying futures contracts Expiration Date, i.e. not 

the Friday that is one Business Day prior to the Monday Expiration Date. For example, the Nymex Natural 

Gas February 2012 futures have an Expiration Date of January 27, 2012. The last day on which the Natural 

Gas February 2012 futures prices will be used as the Underlying for Nadex contracts and to calculate the 

Expiration Value on the Expiration Date for the relevant Natural Gas contracts will be the Friday of the 

preceding week. Therefore, the End Date for using Nymex Natural Gas February 2012 futures will be

January 20, 2012 and the Start Date for the next delivery month, Nymex Natural Gas March 2012 futures, 

will be January 21, 2012. The Nymex Natural Gas March 2012 futures, however, have an Expiration Date 

of Monday, February 27, 2012. The last day on which the Natural Gas March 2012 futures prices will be 

as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date for the

relevant Natural Gas contracts will be February 17, 2012, rather than February 24, 2012, and the Start Date 

for the next delivery month, Nymex Natural Gas April 2012 futures will be February 18, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Natural Gas Call Spread Variable Payout 

Contract, the Payout Criteria for the Contracts will be set as follows;

(i) DAILY NATURAL GAS CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 2:30 PM ET CLOSE - At the commencement of trading in a Daily Natural Gas Call Spread 

Variable Payout Contract, referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Payout 

Contract, which conforms to the Payout Criteria listed below:

(1) DAILY NATURAL GAS CALL SPREAD CONTRACT

28 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the 

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
114

(aa) CEILING – The Ceiling shall be X + 0.5. 

(bb) FLOOR – The Floor shall be X – 0.5.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1000.

(2) In each case, “X” equals the last Natural Gas price, as reported by the Source Agency, 

rounded to the nearest 0.1.

(ii) DAILY NATURAL GAS CALL SPREAD CONTRACTS, 2:30 PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform 

to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 0.5.

(2) CONTRACT 2: The Ceiling shall be X + 0.25; The Floor shall be X – 0.25.

(3) CONTRACT 3: The Ceiling shall be X + 0.5; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1000.

(5) In each case, “X” equals the last Natural Gas price, as reported by the Source Agency, 

rounded to the nearest 0.1.

(iii) INTRADAY NATURAL GAS CALL SPREAD CONTRACTS, 8AM ET to

2:30 PM ET CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, 

which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 0.4.

(2) CONTRACT 2: The Ceiling shall be X + 0.2; The Floor shall be X – 0.2.

(3) CONTRACT 3: The Ceiling shall be X + 0.4; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1000.

(5) In each case, “X” equals the last Natural Gas price, as reported by the Source Agency, 

rounded to the nearest 0.1.

(iv) INTRADAY 2-HOUR NATURAL GAS CALL SPREAD CONTRACTS,

10:00AM, 11:00AM, 12:00PM, 1:00PM and 2:00PM ET CLOSE - Nadex shall list a set of three (3) Call 

Spread Contracts that open 2 hours prior to the stated closing time(s) above with overlapping ranges, 

which conform to the Payout Criteria listed below:
115

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 0.2.

(2) CONTRACT 2: The Ceiling shall be X + 0.1; The Floor shall be X – 0.1.

(3) CONTRACT 3: The Ceiling shall be X + 0.2; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1000.

(5) In each case, “X” equals the last Natural Gas price, as reported by the Source Agency, 

rounded to the nearest 0.05.

(v) Nadex may list additional Call Spread Contracts with different ranges of Payout 

Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Natural Gas Call Spread Contracts shall be

0.001.

(g) POSITION LIMIT – The Position Limits for Natural Gas Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Natural 

Gas Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts per strike 

level.

(i) LAST TRADING DATE – The Last Trading Date for this Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Natural Gas Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE –The Expiration Value is the price or value of Natural Gas Index 

Value released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is 

calculated by the Source Agency by taking all NFC trade prices occurring in the ten (10) seconds leading 

up to the close of trading of the Natural Gas Call Spread Contract, provided at least twenty-five (25) trade 

prices are captured during the ten (10) second period, removing the highest twenty (20) percent of NFC
116

trade prices and the lowest twenty (20) percent of NFC trade prices in the data set29, and using the 

remaining NFC trade prices in the data set, to calculate the Expiration Value. The calculation used is a 

simple average of all the remaining NFC trade prices in the data set, rounded to one decimal point past 

the precision of the underlying market. In the event the time it takes to collect at least twenty-five (25) 

NFC trade prices exceeds the ten (10) seconds just prior to the close of trading of the Natural Gas Call 

Spread Contract, the Expiration Value is calculated by the Source Agency by taking the last twenty-five

(25) NFC trade prices just prior to the close of trading of the Natural Gas Call Spread Contract removing 

the highest five (5) NFC trade prices and the lowest five (5) NFC trade prices, and using the remaining 

fifteen (15) NFC trade prices to calculate the Expiration Value. The calculation used is a simple average 

of all fifteen (15) NFC trade prices, rounded to one decimal point past the precision of the underlying 

market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.10.2 NATURAL GAS “TOUCH BRACKET” VARIABLE PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Natural Gas Touch 

Bracket Variable Payout Contracts issued by Nadex.

(b) UNDERLYING - The Underlying for this Class of Contracts is the Natural Gas price per 

mmBtu (millions British thermal units, in US dollars), obtained from the Natural Gas Futures contracts 

(“NFC”) traded on the New York Mercantile Exchange (“NYMEX”®).30 The NFC trade prices that will 

be used for the Underlying will be taken from all twelve NFC delivery months: January, February, March, 

April, May, June, July, August, September, October, November, or December (each an “NFC Delivery 

Month”). The date on which a new delivery month will be used as the Underlying for Nadex contracts 

(i.e. “Start Date”) is one calendar day after the End Date for the previous delivery month contract. The 

last day on which a delivery month will be used as the Underlying for Nadex contracts (i.e. “End Date”) 

is the Friday of the week preceding the Underlying futures contracts Expiration Date. If the Underlying 

futures contracts Expiration Date falls on a Monday, the End Date for that specific delivery month will be 

the Friday of the week preceding the week of the Underlying futures contracts Expiration Date, i.e. not 

the Friday that is one Business Day prior to the Monday Expiration Date. For example, the Nymex Natural

29 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.

30 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
117

Gas February 2012 futures have an Expiration Date of January 27, 2012. The last day on which the Natural 

Gas February 2012 futures prices will be used as the Underlying for Nadex contracts and to calculate the 

Expiration Value on the Expiration Date for the relevant Natural Gas contracts will be the Friday of the 

preceding week. Therefore, the End Date for using Nymex Natural Gas February 2012 futures will be

January 20, 2012 and the Start Date for the next delivery month, Nymex Natural Gas March 2012 futures, 

will be January 21, 2012. The Nymex Natural Gas March 2012 futures, however, have an Expiration Date 

of Monday, February 27, 2012. The last day on which the Natural Gas March 2012 futures prices will be 

as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date for the

relevant Natural Gas contracts will be February 17, 2012, rather than February 24, 2012, and the Start Date 

for the next delivery month, Nymex Natural Gas April 2012 futures will be February 18, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Natural Gas Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY NATURAL GAS TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 2:30 PM ET on the last Trade Day of the contract listing, or 

when the Natural Gas Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a “Touch 

Bracket”, that open at 3:00AM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.20; The Floor shall be X – 0.05.

(2) CONTRACT 1: The Ceiling shall be X + 0.15; The Floor shall be X – 0.10.

(3) CONTRACT 1: The Ceiling shall be X + 0.10; The Floor shall be X – 0.15.

(4) CONTRACT 1: The Ceiling shall be X + 0.05; The Floor shall be X – 0.20.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(6) In each case, “X” equals the last Natural Gas price, as reported by the Source Agency, 

rounded to the nearest 0.25.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new Touch 

Bracket with a Ceiling of X + 0.20 (or 0.05) and a Floor of X – 0.05 (or 0.20) where X equals the Ceiling 

(or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have the same
118

Last Trade Day as originally established for the expired Touch Bracket and the same Dollar Multiplier as 

the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for Natural Gas Touch Bracket Variable Payout 

Contracts shall be 0.001.

(g) POSITION LIMIT – The Position Limit for Natural Gas Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Natural 

Gas Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Natural Gas Touch Bracket Contract Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) NATURAL GAS INDEX VALUE – The Source Agency shall calculate and produce a 

Natural Gas Index Value once each second throughout the life of the Natural Gas Variable Payout 

contracts. That is, each second the Source Agency will calculate a Natural Gas Index Value by taking all 

NFC trade prices occurring in the ten (10) seconds leading up to the Calculation Time, provided at least 

twenty-five (25) trade prices are captured during the ten (10) second period, removing the highest twenty

(20) percent of SFC trade prices and the lowest twenty (20) percent of NFC trade prices in the data set31, 

and using the remaining NFC trade prices in the data set, to calculate the Index Value. The calculation 

used is a simple average of the remaining NFC trade prices in the data set, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least twenty-five

(25) NFC trade prices exceeds the ten (10) seconds just prior to the Calculation Time, the Index Value is 

calculated by the Source Agency by taking the last twenty-five (25) NFC trade prices just prior to the

31 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
119

Calculation Time, removing the highest five (5) NFC trade prices and the lowest five (5) NFC trade prices, 

and using the remaining fifteen (15) NFC trade prices to calculate the Index Value. The calculation used 

is a simple average of all fifteen (15) NFC trade prices, rounded to one decimal point past the precision 

of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the Natural Gas Index Value as released by 

the Source Agency at Expiration.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.11 NATURAL GAS BINARY CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Natural Gas 

Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Natural Gas price per 

mmBtu (millions British thermal units, in US dollars), obtained from the Physical Natural Gas Futures 

contracts (“NFC”) traded on the New York Mercantile Exchange (“NYMEX”®32). The NFC trade prices 

that will be used for the Underlying will be taken from all twelve NFC delivery months: January, February, 

March, April, May, June, July, August, September, October, November, or December (each an “NFC 

Delivery Month”). The date on which a new delivery month will be used as the Underlying for Nadex 

contracts(i.e. “Start Date”) is one calendar day after the End Date for the previous delivery month contract. 

The last day on which a delivery month will be used as the Underlying for Nadex contracts (i.e. “End 

Date”) is the Friday of the week preceding the Underlying futures contracts Expiration Date. If the 

Underlying futures contracts Expiration Date falls on a Monday, the End Date for that specific delivery 

month will be the Friday of the week preceding the week of the Underlying futures contracts Expiration 

Date, i.e. not the Friday that is one Business Day prior to the Monday Expiration Date. For example, the 

Nymex Natural Gas February 2012 futures have an Expiration Date of January 27, 2012. The last day on 

which the Natural Gas February 2012 futures prices will be used as the Underlying for Nadex contracts 

and to calculate the Expiration Value on the Expiration Date for the relevant Natural Gas contracts will 

be the Friday of the preceding week. Therefore, the End Date for using Nymex Natural Gas February 

2012 futures will be January 20, 2012 and the Start Date for the next delivery month, Nymex Natural Gas 

March 2012 futures, will be January 21, 2012. The Nymex Natural Gas March 2012 futures, however,

32 NYMEX® is a registered service mark of the New York Mercantile Exchange, Inc. COMEX® is a registered service mark of the 

Commodity Exchange, Inc. Nadex is not affiliated with the New York Mercantile Exchange, Inc. or the Commodity Exchange, Inc. and 

neither the New York Mercantile Exchange, the Commodity Exchange, Inc., nor their affiliates, sponsor or endorse Nadex or any of its 

products in any way.
120

have an Expiration Date of Monday, February 27, 2012. The last day on which the Natural Gas March 

2012 futures prices will be as the Underlying for Nadex contracts and to calculate the Expiration Value 

on the Expiration Date for the relevant Natural Gas contracts will be February 17, 2012, rather than 

February 24, 2012, and the Start Date for the next delivery month, Nymex Natural Gas April 2012 futures 

will be February 18, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the Natural Gas Binary Contract, the Payout Criteria 

for the Contracts will be set as follows:

(i) WEEKLY NATURAL GAS BINARY CONTRACTS

(1) EXPIRATION TIME – 2:30PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

0.20.

(3) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will be listed for 

each Weekly Natural Gas Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “W” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in either 0.250 

or 0.750 as reported by the Source Agency. Six (6) strike levels will be generated above 

Binary Contract W at an interval of 0.20, and six (6) strike levels will be generated below 

Binary Contract W at an interval of 0.20 (e.g. W – 0.20; W; W + 0.20). The Contract will 

have a Payout Criterion of greater than the strike level value.

(ii) DAILY NATURAL GAS BINARY CONTRACTS

(1) EXPIRATION TIME – 2:30PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be

0.06.

(3) NUMBER OF STRIKE LEVELS LISTED – Fifteen (15) strike levels will be listed for 

each Daily Natural Gas Binary Contract Series.
121

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Y” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in 0.1 as 

reported by the Source Agency. Seven (7) strike levels will be generated above Binary 

Contract Y at an interval of 0.06, and seven (7) strike levels will be generated below 

Binary Contract Y at an interval of 0.06 (e.g. Y – 0.06; Y; Y + 0.06). The Contract will 

have a Payout Criterion of greater than the strike level value.

(iii) INTRADAY NATURAL GAS BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

0.01.

(3) NUMBER OF STRIKE LEVELS LISTED - Nine (9) strike levels will be listed for each 

Intraday Natural Gas Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in 0.01 as reported by the 

Source Agency. Four (4) strike levels will be generated above Binary Contract Z at an

interval of 0.01, and four (4)strike levels will be generated below Binary Contract Z at an 

interval of 0.01 (e.g. Z – 0.01; Z; Z + 0.01). The Contract will have a Payout Criterion of 

greater than the strike level value.

(iv) Nadex may list additional Natural Gas Binary Contract with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Natural Gas Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for Natural Gas Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Natural 

Gas Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration

Date.

(j) SETTLEMENT DATE – The Settlement Date will be the same date as the Expiration Date.
122

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

Natural Gas Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money Natural Gas Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of Natural Gas released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all NFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the 

Natural Gas Binary Contract, provided at least twenty-five (25) trade prices are captured during the ten

(10) second period, removing the highest twenty (20) percent of NFC trade prices and the lowest twenty

(20) percent of NFC trade prices in the data set33, and using the remaining NFC trade prices in the data 

set, to calculate the Expiration Value. The calculation used is a simple average of all the remaining NFC 

trade prices in the data set, rounded to one decimal point past the precision of the underlying market. In 

the event the time it takes to collect at least twenty-five (25) NFC trade prices exceeds the ten (10) seconds 

just prior to the close of trading of the Natural Gas Binary Contract, the Expiration Value is calculated by 

the Source Agency by taking the last twenty-five (25) NFC trade prices just prior to the close of trading 

of the Natural Gas Binary Contract removing the highest five (5) NFC trade prices and the lowest five (5) 

NFC trade prices, and using the remaining fifteen (15) NFC trade prices to calculate the Expiration Value. 

The calculation used is a simple average of all fifteen (15) NFC trade prices, rounded to one decimal point 

past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.12 -12.23 [RESERVED]

RULE 12.24 BITCOIN CRYPTOCURRENCY “TOUCH BRACKET” VARIABLE PAYOUT 

CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Bitcoin 

Cryptocurrency (“Bitcoin”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch Bracket”, 

issued by Nadex.

33 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
123

(b) UNDERLYING – The Underlying for this Class of Contracts is the spot bitcoin 

cryptocurrency as reported in the ICE® Cryptocurrency Data34 aggregated by Blockstream® Corporation35

and distributed by ICE Data® Connectivity and Feeds, Inc.36, herein referred to as “IDCF BIT”, quoted in 

US dollars.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at 

the time the Variable Payout Contracts are initially issued. For the Bitcoin Touch Brackets, the Payout 

Criteria for the Contracts will be set as follows:

(i) WEEKLY BITCOIN TOUCH BRACKET VARIABLE PAYOUT CONTRACTS,

Expiration is the earlier of (a) 4:15PM ET on the Last Trade Day of the contract listing, or (b) 

when the Bitcoin Index Value is equal to or greater than the Ceiling, or equal to or less than the 

Floor. Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, each referred to 

as a ‘Touch Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping 

ranges, which conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 400; The Floor shall be X – 100.

(2) CONTRACT 2: The Ceiling shall be X + 300; The Floor shall be X – 200.

(3) CONTRACT 3: The Ceiling shall be X + 200; The Floor shall be X – 300.

(4) CONTRACT 4: The Ceiling shall be X + 100; The Floor shall be X – 400.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

34 ICE®

is a registered mark of IntercontinentalExchange, Inc. (“ICE”). Nadex is not affiliated with ICE 

or ICE Data Connectivity and Feeds, Inc., and the Bitcoin Cryptocurrency “Touch Bracket” Variable 

Payout Contracts are not sponsored, endorsed, sold or promoted by ICE or ICE Data Connectivity and 

Feeds, Inc. in any way.

35 Blockstream® is a registered mark of Blockstream Corporation (“Blockstream”). Nadex is not affiliated 

with Blockstream and the Bitcoin Cryptocurrency “Touch Bracket” Variable Payout Contracts are not 

sponsored, endorsed, sold or promoted by Blockstream.

36 ICE® is a registered mark of IntercontinentalExchange, Inc. (“ICE”) and ICE Data® is a registered mark 

of Intercontinental Exchange Holdings, Inc (“ICE Holdings”). Nadex is not affiliated with ICE, ICE 

Holdings, or ICE Data Connectivity and Feeds, Inc., and the Bitcoin Cryptocurrency “Touch Bracket” 

Variable Payout Contracts are not sponsored, endorsed, sold or promoted by ICE, Ice Holdings, or ICE 

Data Connectivity and Feeds, Inc. in any way.
124

(6) In each case, “X” equals the last IDCF BIT value, as reported by the Source 

Agency, rounded to the nearest 1.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new Touch Bracket 

with a Ceiling of X + 400 (or 100) and a Floor of X – 100 (or 400) where X equals the Ceiling (or 

Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have the same 

Last Trade Day as originally established for the expired Touch Bracket and the same Dollar 

Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK –The Minimum Tick size for the Bitcoin Touch Bracket Variable Payout 

Contracts shall be 1.

(g) POSITION LIMIT –The Position Limit for the Bitcoin Touch Bracket Variable Payout 

Contracts shall be 25010 Contracts.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

Bitcoin Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 2510,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Bitcoin Touch Bracket Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) BITCOIN INDEX VALUE – The Source Agency shall calculate and produce a Bitcoin 

Index Value once each second throughout the life of the Bitcoin Touch Bracket Contracts. That is, each 

second the Source Agency will calculate a Bitcoin Index Value by taking by taking all IDCF BIT trade 

prices occurring in the ten (10) seconds leading up to the Calculation Time, provided at least twenty-five

(25) trade prices are captured during the ten (10) second period, removing the highest twenty (20) percent 

of IDCF BIT trade prices and the lowest twenty (20) percent of IDCF BIT trade prices from the data set37,

37 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices 

to be removed from the set will be rounded down. For example, if the number of trade prices collected 

during the last 10 seconds prior to the close of trading was 31, 20% of the data set would be 6.2 trade
125

and using the remaining IDCF BIT trade prices to calculate the Bitcoin Index Value for that second. The 

calculation used is a simple average of the remaining IDCF BIT trade prices in the data set, rounded to 

one decimal point past the precision of the Underlying market. In the event the time it takes to collect at 

least twenty-five (25) IDCF BIT trade prices exceeds the ten (10) second period, the Bitcoin Index Value 

will be calculated by the Source Agency by taking the last twenty-five (25) IDCF BIT trade prices just 

prior to the Calculation Time, removing the highest five (5) IDCF BIT trade prices and the lowest five (5) 

IDCF BIT trade prices, and using the remaining fifteen (15) IDCF BIT trade prices to calculate the Bitcoin 

Index Value. The calculation used is a simple average of all fifteen (15) IDCF BIT trade prices, rounded 

to one decimal point past the precision of the Underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the Bitcoin Index Value released by the 

Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12. 25 ETHER CRYPTOCURRENCY “TOUCH BRACKET” VARIABLE PAYOUT 

CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Ether 

Cryptocurrency (“Ether”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch Bracket”, 

issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the spot Ether 

cryptocurrency reported in the ICE® Cryptocurrency Data38, aggregated by Blockstream® Corporation39

and distributed by ICE Data® Connectivity and Feeds, Inc.40, herein referred to as “IDCF ETH”, quoted 

in US dollars.

prices. As 6.2 is a non-integer number, the value will be rounded down, and the 6 highest and 6 lowest 

trade prices will be removed from the data set.

38 ICE® is a registered mark of IntercontinentalExchange, Inc. (“ICE”). Nadex is not affiliated with ICE 

or ICE Data Connectivity and Feeds, Inc., and the Ether Cryptocurrency “Touch Bracket” Variable Payout 

Contracts are not sponsored, endorsed, sold or promoted by ICE or ICE Data Connectivity and Feeds, Inc. 

in any way.

39 Blockstream® is a registered mark of Blockstream Corporation (“Blockstream”). Nadex is not affiliated 

with Blockstream and the Ether Cryptocurrency “Touch Bracket” Variable Payout Contracts are not 

sponsored, endorsed, sold or promoted by Blockstream.

40 ICE® is a registered mark of IntercontinentalExchange, Inc. (“ICE”) and ICE Data® is a registered mark 

of Intercontinental Exchange Holdings, Inc (“ICE Holdings”). Nadex is not affiliated with ICE, ICE 

Holdings, or ICE Data Connectivity and Feeds, Inc., and the Ether Cryptocurrency “Touch Bracket”
126

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at 

the time the Variable Payout Contracts are initially issued. For the Ether Touch Brackets, the Payout 

Criteria for the Contracts will be set as follows:

(i) WEEKLY ETHER TOUCH BRACKET VARIABLE PAYOUT CONTRACTS,

Expiration is the earlier of (a) 4:15PM ET on the Last Trade Day of the Contract listing, or (b) when the 

Ether Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. Nadex shall 

list a set of four (4) Touch Bracket Variable Payout Contracts, each referred to as a ‘Touch Bracket’, that 

open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, which conform to the 

Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 200; The Floor shall be X - 50.

(2) CONTRACT 2: The Ceiling shall be X + 150; The Floor shall be X – 100.

(3) CONTRACT 3: The Ceiling shall be X + 100; The Floor shall be X - 150.

(4) CONTRACT 4: The Ceiling shall be X + 50; The Floor shall be X – 200.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

(6) In each case, “X” equals the last IDCF ETH value, as reported by the Source 

Agency, rounded to the nearest 1.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new Touch Bracket 

with a Ceiling of X + 200 (or 50) and a Floor of X – 50 (or 200) where X equals the Ceiling (or Floor) of 

the Touch Bracket that expired early. The newly listed Touch Bracket will have the same Last Trade Day 

as originally established for the expired Touch Bracket and the same Dollar Multiplier as the expired 

Touch Bracket.

(f) MINIMUM TICK –The Minimum Tick size for the Ether Touch Bracket Variable Payout 

Contracts shall be 1.

(g) POSITION LIMIT –The Position Limit for the Ether Touch Bracket Variable Payout 

Contracts shall be 25010 Contracts.

Variable Payout Contracts are not sponsored, endorsed, sold or promoted by ICE, ICE Holdings, or ICE 

Data Connectivity and Feeds, Inc. in any way.
127

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

Ether Touch Bracket Variable Payout Contracts for contracted Market Makersshall be 2510,000 Contracts 

per strike level

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Ether Touch Bracket Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either 

a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) ETHER INDEX VALUE – The Source Agency shall calculate and produce a Ether Index 

Value once each second throughout the life of the Ether Touch Bracket Contracts. That is, each second 

the Source Agency will calculate a Ether Index Value by taking by taking all IDCF ETH trade prices 

occurring in the ten (10) seconds leading up to the Calculation Time, provided at least twenty-five (25) 

trade prices are captured during the ten (10) second period, removing the highest twenty (20) percent of 

IDCF ETH trade prices and the lowest twenty (20) percent of IDCF ETH trade prices from the data set41, 

and using the remaining IDCF ETH trade prices to calculate the Ether Index Value for that second. The 

calculation used is a simple average of the remaining IDCF ETH trade prices in the data set, rounded to 

one decimal point past the precision of the Underlying market. In the event the time it takes to collect at 

least twenty-five (25) IDCF ETH trade prices exceeds the ten (10) second period, the Ether Index Value 

will be calculated by the Source Agency by taking the last twenty-five (25) IDCF ETH trade prices just 

prior to the Calculation Time, removing the highest five (5) IDCF ETH trade prices and the lowest five

(5) IDCF ETH trade prices, and using the remaining fifteen (15) IDCF ETH trade prices to calculate the 

Ether Index Value. The calculation used is a simple average of all fifteen (15) IDCF ETH trade prices, 

rounded to one decimal point past the precision of the Underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the Ether Index Value released by the 

Source Agency at Expiration on the Expiration Date.

41 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices 

to be removed from the set will be rounded down. For example, if the number of trade prices collected 

during the last 10 seconds prior to the close of trading was 31, 20% of the data set would be 6.2 trade 

prices. As 6.2 is a non-integer number, the value will be rounded down, and the 6 highest and 6 lowest 

trade prices will be removed from the data set.
128

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a 

delay, postponement or otherwise in such release announcement by the Source Agency, the Settlement 

Date will be delayed until the Underlying number is released for that Series.

RULE 12.26 CURRENCY EXCHANGE AUD/USD VARIABLE PAYOUT CONTRACTS

RULE 12.26.1 CURRENCY EXCHANGE AUD/USD “CALL SPREAD” VARIABLE

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange AUD/USD (“AUD/USD”) Call Spread Variable Payout Contracts, referred to as a “Call 

Spread”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Australian dollar/US 

dollar, herein referred to as “AUD/USD” as quoted in US dollars per Australian dollar obtained from the 

spot AUD/USD foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the AUD/USD Call Spread Variable Payout 

Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY AUD/USD CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE – At the commencement of trading in a Weekly AUD/USD Call Spread, Nadex shall 

list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY AUD/USD CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0375.

(bb) FLOOR – The Floor shall be X – 0.0375.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last AUD/USD price, as reported by the Source Agency,

rounded to the nearest 0.0010.

(ii) WEEKLY AUD/USD CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly AUD/USD Call 

Spread, Nadex shall list five (5) Call Spread Contracts with overlapping ranges, which conforms to the 

Payout Criteria listed below:
129

(1) CONTRACT 1: The Ceiling shall be X – 0.0125; The Floor shall be X – 0.0375.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 0.0250.

(3) CONTRACT 3: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.

(4) CONTRACT 4: The Ceiling shall be X + 0.0250; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 0.0375; The Floor shall be X – 0.0125.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(7) In each case, “X” equals the last AUD/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(iii) DAILY AUD/USD CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE - At the commencement of trading in a Daily AUD/USD Call Spread Variable Payout 

Contract, referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Contract, which conforms to 

one of the Payout Criteria listed below:

(1) DAILY AUD/USD CALL SPREAD CONTRACT:

(aa) CEILING – The Ceiling shall be X + 0.0250. 

(bb) FLOOR – The Floor shall be X – 0.0250.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last AUD/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(iv) DAILY AUD/USD CALL SPREAD CONTRACTS, 3:00 PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform 

to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 0.0250.

(2) CONTRACT 2: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.

(3) CONTRACT 3: The Ceiling shall be X + 0.0250; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.
130

(5) In each case, “X” equals the last AUD/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(v) INTRADAY AUD/USD CALL SPREAD CONTRACTS, 6:00PM to

11:00PM, 11:00PM to 7:00AM, and 7:00AM to 3:00PM ET CLOSE - Nadex shall list a set of three (3) 

Call Spread Contracts with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0200.

(2) CONTRACT 2: The Ceiling shall be X + 0.0100; The Floor shall be X – 0.0100

(3) CONTRACT 3: The Ceiling shall be X + 0.0200; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last AUD/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(vi) INTRADAY 2-HOUR AUD/USD CALL SPREAD CONTRACTS, 

8:00PM, 9:00PM, 10:00PM, 11:00PM, 12:00AM, 1:00AM, 2:00AM, 3:00AM, 4:00AM, 5:00AM,

6:00AM, 7:00AM, 8:00AM, 9:00AM, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, and 3:00PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts that open 2 hours prior to the stated 

closing time(s) above with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0100.

(2) CONTRACT 2: The Ceiling shall be X + 0.0050; The Floor shall be X – 0.0050

(3) CONTRACT 3: The Ceiling shall be X + 0.0100; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last AUD/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(vii) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for AUD/USD Call Spread Contracts shall be 

0.0001.

(g) POSITION LIMIT – The Position Limits for AUD/USD Call Spread Contracts shall be 250 

Contracts per Class.
131

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

AUD/USD Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series isthe same date asthe Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

AUD/USD Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of AUD/USD Index 

Value released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is 

calculated by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or 

less) occurring in the ten (10) seconds leading up to the close of trading of the AUD/USD Call Spread 

Contract, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing 

the highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data 

set42, using the remaining AUD/USD Midpoints to calculate the Expiration Value. The calculation used 

is a simple average of the remaining AUD/USD Midpoints, rounded to one decimal point past the 

precision of the underlying market. In the event the time it takes to collect at least ten (10) Midpoints (ten 

pips wide or less) exceeds the ten (10)second time period, the Expiration Value is calculated by the Source 

Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior 

to the close of trading of the AUD/USD Call Spread Contract and removing the highest three (3) Midpoints 

and the lowest three (3) Midpoints, using the remaining four (4) AUD/USD Midpoints to calculate the 

Expiration Value. The calculation used is a simple average of all four (4) AUD/USD Midpoints, rounded 

to one decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

42 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
132

RULE 12.26.2 CURRENCY EXCHANGE AUD/USD “TOUCH BRACKET” VARIABLE

PAYOUT CONTRACTS

(p) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange AUD/USD (“AUD/USD”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(q) UNDERLYING – The Underlying for this Class of Contracts is the Australian dollar/US 

dollar, herein referred to as “AUD/USD” as quoted in US dollars per Australian dollar obtained from the 

spot AUD/USD foreign currency market.

(r) SOURCE AGENCY – The Source Agency is Nadex.

(s) TYPE – The Type of Contract is a Variable Payout Contract.

(t) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the AUD/USD Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY AUD/USD TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Expiration is the earlier of (a) 3:00PM ET on the Last Trade Day of the contract listing, 

or (b) when the AUD/USD Index Value is equal to or greater than the Ceiling, or equal to or less than the 

Floor. Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, each referred to as a 

‘Touch Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, 

which conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.0080; The Floor shall be X- 0.0020.

(2) CONTRACT 2: The Ceiling shall be X + 0.0060; The Floor shall be X – 0.0040.

(3) CONTRACT 3: The Ceiling shall be X + 0.0040; The Floor shall be X- 0.0060.

(4) CONTRACT 4: The Ceiling shall be X + 0.0020; The Floor shall be X – 0.0080.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(6) In each case, “X” equals the last AUD/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0001.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.0080 (or 0.0020) and a Floor of X – 0.0020 (or 0.0080) where X 

equals the Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket 

will have the same Last Trade Day as originally established for the expired Touch Bracket and the same 

Dollar Multiplier as the expired Touch Bracket.
133

(u) MINIMUM TICK –The Minimum Tick size for the AUD/USD Touch Bracket Variable 

Payout Contracts shall be 0.0001.

(v) POSITION LIMIT –The Position Limit for AUD/USD Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(w) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the

AUD/USD Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(x) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Settlement

Date.

(y) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(z) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

AUD/USD Expiration Value is released by the Source Agency.

(aa) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(bb) AUD/USD INDEX VALUE – The Source Agency shall calculate and produce a AUD/USD 

Index Value once each second throughout the life of the AUD/USD Variable Payout contracts. That is, 

each second the Source Agency will calculate a AUD/USD Index Value by taking all Midpoints between 

the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing the 

highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set43, 

using the remaining AUD/USD Midpoints to calculate the AUD/USD Index Value for that second. The 

calculation used is a simple average of the remaining AUD/USD Midpoints, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least ten (10) 

Midpoints (ten pips wide or less) exceeds the ten (10) second time period, the AUD/USD Index Value is 

calculated by the Source Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten 

pips wide or less) just prior to the Calculation Time and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) AUD/USD Midpoints to calculate the AUD/USD

43 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
134

Index Value. The calculation used is a simple average of all four (4) AUD/USD Midpoints, rounded to 

one decimal point past the precision of the underlying market.

(cc) EXPIRATION VALUE – The Expiration Value is the AUD/USD Index Value released by 

the Source Agency at Expiration on the Expiration Date.

(dd) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.27 CURRENCY EXCHANGE AUD/USD BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange AUD/USD (“AUD/USD”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Australian dollar/US dollar 

herein referred to as “AUD/USD” as quoted in U.S. dollars per Australian dollar obtained from the spot 

AUD/USD foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the AUD/USD Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY AUD/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0050.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly AUD/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “W” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in either 0.0025 or 0.0075 as reported by the Source Agency. 

Six (6) strike levels will be generated above Binary Contract W at an interval
135

of 0.0050, and seven (7) strike levels will be generated below Binary 

Contract W at an interval of 0.0050 (e.g. W – 0.0050; W; W + 0.0050). The 

Contract will have a Payout Criterion of greater than the strike level value.

(ii) DAILY AUD/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 3 AM, 7 AM, 11 AM, 3 PM, 7 PM, 11 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0012.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily AUD/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0020 as reported by the Source Agency. Ten (10) strike 

levels will be generated above Binary Contract X at an interval of 0.0012, and 

ten (10) strike levels will be generated below Binary Contract X at an interval 

of 0.0012 (e.g. X – 0.0012; X; X + 0.0012). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iii) INTRADAY 2-HOUR AUD/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 8 PM, 9 PM, 10 PM, 11 PM, 12 AM, 1 AM, 2 AM,

3 AM, 4 AM, 5 AM, 6 AM, 7 AM, 8 AM, 9 AM, 10 AM, 11 AM, 12 PM,

1 PM , 2 PM, 3 PM, 4 PM, 5 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0004.

(3) NUMBER OF STRIKE LEVELS LISTED – Nineteen (19) strike levels 

will be listed for each Intraday 2-Hour AUD/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest
136

value ending in either 0.0000, 0.0002, 0.0004, 0.0006, or 0.0008 as reported by the 

Source Agency. Nine (9) strike levels will be generated above Binary Contract Y at 

an interval of 0.0004, and nine (9) strike levels will be generated below Binary 

Contract Y at an interval of 0.0004 (e.g. Y – 0.0004; Y; Y + 0.0004). The Contract 

will have a Payout Criterion of greater than the strike level value.

(iv) INTRADAY 5-MINUTE AUD/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 5-Minute Binary Contracts will expire every 5 

minutes beginning Sunday at 6:05pm ET and ending Friday at 4:00pm ET.

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level

shall be 0.0002 for expirations occurring between 6:05pm ET and 8:05am ET and 

between 12:10pm ET and 5:00pm ET; the interval width shall be 0.0004 for 

expirations occurring between 8:10am ET and 12:05pm ET.

(3) NUMBER OF STRIKE LEVELS LISTED – Five (5) strike levels

will be listed for each Intraday 5-Minute AUD/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.0001, 0.0003, 0.0005, 0.0007, or 0.0009 as reported by the 

Source Agency. For expirations occurring between 6:05pm ET and 8:05am ET and 

between 12:10pm ET and 5:00pm ET, two (2) strike levels will be generated above 

Binary Contract Z at an interval of 0.0002, and two (2) strike levels will be generated 

below Binary Contract Z at an interval of 0.0002 (e.g. Z – 0.0002; Z; Z + 0.0002). The 

Contract will have a Payout Criterion of greater than the strike level value. For 

expirations occurring between 8:10am ET and 12:05pm ET, two (2) strike levels will 

be generated above Binary Contract Z at an interval of 0.0004, and two (2)strike levels 

will be generated below Binary Contract Z at an interval of 0.0004 (e.g. Z – 0.0004; 

Z; Z + 0.0004). The Contract will have a Payout Criterion of greater than the strike 

level value.

(5) Nadex may, in its discretion, temporarily refrain from the listing of any 5-Minute 

Binary Contract due to the unavailability of the underlying market upon

which the Contract is based, or any other condition Nadex determines may be 

detrimental to the listing of the Contract.
137

(v) Nadex may list additional AUD/USD Binary Contracts with different 

ranges of Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for AUD/USD Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for AUD/USD Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

AUD/USD Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same as the Expiration 

Date. No trading in the AUD/USD Binary Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date on which the AUD/USD number 

as reported by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

AUD/USD number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on the Settlement Date. The Settlement Value of an in the money AUD/USD Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of AUD/USD released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the AUD/USD Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set44, using the remaining AUD/USD Midpoints 

to calculate the Expiration Value. The calculation used is a simple average of the remaining AUD/USD 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the AUD/USD Binary Contract 

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the remaining four

(4) AUD/USD Midpoints to calculate the Expiration Value. The calculation used is a

44 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
138

simple average of all four (4) AUD/USD Midpoints, rounded to one decimal point past the precision of 

the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.28 CURRENCY EXCHANGE EUR/USD VARIABLE PAYOUT CONTRACTS

RULE 12.28.1 CURRENCY EXCHANGE EUR/USD “CALL SPREAD” VARIABLE 

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange EUR/USD (“EUR/USD”) Call Spread Variable Payout Contracts, referred to as a “Call 

Spread”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Euro/US dollar, herein 

referred to as “EUR/USD” as quoted in US dollars per Euro obtained from the spot EUR/USD foreign 

currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the EUR/USD Call Spreads, the Payout 

Criteria for the Contracts will be set as follows:

(i) WEEKLY EUR/USD CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE – At the commencement of trading in a Weekly EUR/USD Call Spread, Nadex shall 

list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY EUR/USD CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0375. 

(bb) FLOOR – The Floor shall be X – 0.0375.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last EUR/USD price, as reported by the Source Agency,

rounded to the nearest 0.0010.
139

(ii) WEEKLY EUR/USD CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE – At the commencement of trading in a Weekly EUR/USD Call Spread, Nadex shall 

list five (5) Call Spread Contracts with overlapping ranges, which conforms to the Payout Criteria listed 

below:

(1) CONTRACT 1: The Ceiling shall be X – 0.0125; The Floor shall be X – 0.0375.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 0.0250.

(3) CONTRACT 3: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.

(4) CONTRACT 4: The Ceiling shall be X + 0.0250; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 0.0375; The Floor shall be X – 0.0125.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(7) In each case, “X” equals the last EUR/USD price, as reported by the Source Agency,

rounded to the nearest 0.0010.

(iii) EUR/USD CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE - At the commencement of trading in a Daily EUR/USD Call Spread, Nadex shall 

list one (1) Call Spread Contract, which conforms to one of the Payout Criteria listed below:

(1) DAILY EUR/USD CALL SPREAD CONTRACT:

(aa) CEILING – The Ceiling shall be X + 0.0250. 

(bb) FLOOR – The Floor shall be X – 0.0250.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last EUR/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(iv) DAILY EUR/USD CALL SPREAD CONTRACTS, 3:00 PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform 

to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 0.0250.

(2) CONTRACT 2: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.

(3) CONTRACT 3: The Ceiling shall be X + 0.0250; The Floor shall be X.
140

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last EUR/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(v) INTRADAY EUR/USD CALL SPREAD CONTRACTS, 6:00PM to

11:00PM, 11:00PM to 7:00AM, and 7:00AM to 3:00PM ET CLOSE - Nadex shall list a set of three (3) 

Call Spread Contracts with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0250.

(2) CONTRACT 2: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125

(3) CONTRACT 3: The Ceiling shall be X + 0.0250; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last EUR/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(vi) INTRADAY 2-HOUR EUR/USD CALL SPREAD CONTRACTS, 

8:00PM, 9:00PM, 10:00PM, 11:00PM, 12:00AM, 1:00AM, 2:00AM, 3:00AM, 4:00AM, 5:00AM,

6:00AM, 7:00AM, 8:00AM, 9:00AM, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, and 3:00PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts that open 2 hours prior to the stated 

closing time(s) above with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0100.

(2) CONTRACT 2: The Ceiling shall be X + 0.0050; The Floor shall be X – 0.0050

(3) CONTRACT 3: The Ceiling shall be X + 0.0100; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last EUR/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(vii) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for EUR/USD Call Spread Variable Payout 

Contracts shall be 0.0001.
141

(g) POSITION LIMIT – The Position Limits for EUR/USD Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

EUR/USD Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series isthe same date asthe Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

EUR/USD Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of EUR/USD Index 

Value released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is 

calculated by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or 

less) occurring in the ten (10) seconds leading up to the close of trading of the EUR/USD Call Spread 

Contract, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing 

the highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data 

set45, using the remaining EUR/USD Midpoints to calculate the Expiration Value. The calculation used 

is a simple average of the remaining EUR/USD Midpoints, rounded to one decimal point past the precision 

of the underlying market. In the event the time it takes to collect at least ten (10) Midpoints (ten pips wide 

or less) exceeds the ten (10) second time period, the Expiration Value is calculated by the Source Agency 

by taking the last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior to the 

close of trading of the EUR/USD Call Spread Contract and removing the highest three (3) Midpoints and 

the lowest three (3) Midpoints, using the remaining four (4) EUR/USD Midpoints to calculate the 

Expiration Value. The calculation used is a simple average of all four (4) EUR/USD Midpoints, rounded 

to one decimal point past the precision of the underlying market.

45 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
142

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.28.2 CURRENCY EXCHANGE EUR/USD “TOUCH BRACKET” VARIABLE

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange EUR/USD (“EUR/USD”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Euro/US dollar, herein 

referred to as “EUR/USD” as quoted in US dollars per Euro obtained from the spot EUR/USD foreign 

currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at 

the time the Variable Payout Contracts are initially issued. For the EUR/USD Touch Bracket Contracts, 

the Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY EUR/USD TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Expiration is the earlier of (a) 3:00PM ET on the Last Trade Day of the contract listing, 

or (b) when the EUR/USD Index Value is equal to or greater than the Ceiling, or equal to or less than the 

Floor. Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, each referred to as a 

‘Touch Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, 

which conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.0080; The Floor shall be X- 0.0020.

(2) CONTRACT 2: The Ceiling shall be X + 0.0060; The Floor shall be X – 0.0040.

(3) CONTRACT 3: The Ceiling shall be X + 0.0040; The Floor shall be X- 0.0060.

(4) CONTRACT 4: The Ceiling shall be X + 0.0020; The Floor shall be X – 0.0080.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(ii) In each case, “X” equals the last EUR/USD price, as reported by the 

Source Agency, rounded to the nearest 0.0001.
143

(iii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.0080 (or 0.0020) and a Floor of X – 0.0020 (or 0.0080) where X 

equals the Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket 

will have the same Last Trade Day as originally established for the expired Touch Bracket and the same 

Dollar Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK –The Minimum Tick size for the EUR/USD Touch Bracket Variable Payout 

Contracts shall be 0.0001.

(g) POSITION LIMIT –The Position Limit for EUR/USD Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

EUR/USD Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

EUR/USD Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EUR/USD INDEX VALUE – The Source Agency shall calculate and produce a EUR/USD 

Index Value once each second throughout the life of the EUR/USD Variable Payout contracts. That is, 

each second the Source Agency will calculate a EUR/USD Index Value by taking all Midpoints between 

the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing the 

highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set46, 

using the remaining EUR/USD Midpoints to calculate the EUR/USD Index Value for that second. The 

calculation used is a simple average of the remaining EUR/USD Midpoints, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least ten (10)

46 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
144

Midpoints (ten pips wide or less) exceeds the ten (10) second time period, the EUR/USD Index Value is 

calculated by the Source Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten

pips wide or less) just prior to the Calculation Time and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) EUR/USD Midpoints to calculate the EUR/USD 

Index Value. The calculation used is a simple average of all four (4) EUR/USD Midpoints, rounded to 

one decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the EUR/USD Index Value released by the 

Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.29 CURRENCY EXCHANGE EUR/USD BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange EUR/USD (“EUR/USD”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Euro/US dollar herein 

referred to as “EUR/USD” as quoted in U.S. dollars per Euro obtained from the spot EUR/USD foreign 

currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the EUR/USD Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY EUR/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0050.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly EUR/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “W” is valued ‘at-the-money’ in relation to the Underlying
145

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0025 or 0.0075 as reported by the Source Agency. Six (6) 

strike levels will be generated above Binary Contract W at an interval of 

0.0050, and seven (7) strike levels will be generated below Binary Contract W 

at an interval of 0.0050 (e.g. W – 0.0050; W; W + 0.0050). The Contract will 

have a Payout Criterion of greater than the strike level value.

(ii) DAILY EUR/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 3 AM, 7 AM, 11 AM, 3 PM, 7 PM, 11 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0012.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily EUR/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0020 as reported by the Source Agency. Ten (10) strike 

levels will be generated above Binary Contract X at an interval of 0.0012, and 

ten (10) strike levels will be generated below Binary Contract X at an interval 

of 0.0012 (e.g. X – 0.0012; X; X + 0.0012). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iii) INTRADAY 2-HOUR EUR/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 8 PM, 9 PM, 10 PM, 11 PM, 12 AM, 1 AM, 2 AM,

3 AM, 4 AM, 5 AM, 6 AM, 7 AM, 8 AM, 9 AM, 10 AM, 11 AM, 12 PM,

1 PM, 2 PM, 3 PM, 4 PM, 5 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0004.

(3) NUMBER OF STRIKE LEVELS LISTED – Nineteen (19) strike levels 

will be listed for each Intraday 2-Hour EUR/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that
146

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.0000, 0.0002, 0.0004, 0.0006, or 0.0008 as reported by the 

Source Agency. Nine (9) strike levels will be generated above Binary Contract Y at 

an interval of 0.0004, and nine (9) strike levels will be generated below Binary 

Contract Y at an interval of 0.0004 (e.g. Y – 0.0004; Y; Y + 0.0004). The Contract 

will have a Payout Criterion of greater than the strike level value.

(iv) INTRADAY 5-MINUTE EUR/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 5-Minute Binary Contracts will expire every 5 

minutes beginning Sunday at 6:05pm ET and ending Friday at 4:00pm ET.

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level

shall be 0.0002 for expirations occurring between 6:05pm ET and 8:05am ET and 

between 12:10pm ET and 5:00pm ET; the interval width shall be 0.0004 for 

expirations occurring between 8:10am ET and 12:05pm ET.

(3) NUMBER OF STRIKE LEVELS LISTED – Five (5) strike levels

will be listed for each Intraday 5-Minute EUR/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.0001, 0.0003, 0.0005, 0.0007, or 0.0009 as reported by the 

Source Agency. For expirations occurring between 6:05pm ET and 8:05am ET and 

between 12:10pm ET and 5:00pm ET, two (2) strike levels will be generated above 

Binary Contract Z at an interval of 0.0002, and two (2) strike levels will be generated 

below Binary Contract Z at an interval of 0.0002 (e.g. Z – 0.0002; Z; Z + 0.0002). The 

Contract will have a Payout Criterion of greater than the strike level value. For 

expirations occurring between 8:10am ET and 12:05pm ET, two (2) strike levels will 

be generated above Binary Contract Z at an interval of 0.0004, and two (2)strike levels 

will be generated below Binary Contract Z at an interval of 0.0004 (e.g. Z – 0.0004; 

Z; Z + 0.0004). The Contract will have a Payout Criterion of greater than the strike 

level value.

(5) Nadex may, in its discretion, temporarily refrain from the listing of any 5-Minute 

Binary Contract due to the unavailability of the underlying market upon

which the Contract is based, or any other condition Nadex determines may be 

detrimental to the listing of the Contract.
147

(v) Nadex may list additional EUR/USD Binary Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for EUR/USD Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for EUR/USD Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

EUR/USD Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same as the Expiration 

Date. No trading in the EUR/USD Binary Contracts shall occur after its Last Trading Date.

(j)SETTLEMENT DATE – The Settlement Date will be the date on which the EUR/USD number 

as reported by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

EUR/USD number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in 

the money Contract on the Settlement Date. The Settlement Value of an in the money EUR/USD Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of EUR/USD released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the EUR/USD Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set47, using the remaining EUR/USD Midpoints 

to calculate the Expiration Value. The calculation used is a simple average of the remaining EUR/USD 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the EUR/USD Binary Contract

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the

47 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
148

remaining four (4) EUR/USD Midpoints to calculate the Expiration Value. The calculation used is a 

simple average of all four (4) EUR/USD Midpoints, rounded to one decimal point past the precision of 

the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a 

delay, postponement or otherwise in such release announcement by the Source Agency, the Settlement 

Date will be delayed until the Underlying number is released for that Series.

RULE 12.30 CURRENCY EXCHANGE GBP/USD VARIABLE PAYOUT CONTRACTS

RULE 12.30.1 CURRENCY EXCHANGE GBP/USD “CALL SPREAD” VARIABLE

PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Currency Exchange 

GBP/USD (“GBP/USD”) Call Spread Variable Payout Contracts, referred to as a ‘Call Spread’, issued by 

Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the British Pound/ US dollar, 

herein referred to as “GBP/USD” as quoted in US dollars per British Pound obtained from the spot 

GBP/USD foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the GBP/USD Call Spreads, the Payout 

Criteria for the Contracts will be set as follows:

(i) WEEKLY GBP/USD CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly GBP/USD Call 

Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY GBP/USD CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0375. 

(bb) FLOOR – The Floor shall be X – 0.0375.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last GBP/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.
149

(ii) WEEKLY GBP/USD CALL SPREAD VARIABLE

PAYOUT CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a 

Weekly GBP/USD Call Spread, Nadex shall list five (5) Call Spread Contracts with 

overlapping ranges, which conforms to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X – 0.0125; The Floor shall be X – 0.0375.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 0.0250.

(3) CONTRACT 3: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.

(4) CONTRACT 4: The Ceiling shall be X + 0.0250; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 0.0375; The Floor shall be X – 0.0125.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(7) In each case, “X” equals the last GBP/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(iii) DAILY GBP/USD CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE SPREAD - At the commencement of trading in a Daily USD/USD 

Call Spread, Nadex shall list one (1) Call Spread Contract, which conforms to one of the Payout Criteria 

listed below:

(1) DAILY GBP/USD CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0250. 

(bb) FLOOR – The Floor shall be X – 0.0250.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last GBP/USD price, as reported by the Source Agency,

rounded to the nearest 0.0010.

(iv) DAILY GBP/USD CALL SPREAD CONTRACTS, 3:00 PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform 

to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 0.0250.

(2) CONTRACT 2: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.
150

(3) CONTRACT 3: The Ceiling shall be X + 0.0250; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last GBP/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(v) INTRADAY GBP/USD CALL SPREAD CONTRACTS, 6:00PM to

11:00PM, 11:00PM to 7:00AM, and 7:00AM to 3:00PM ET CLOSE - Nadex shall list a set of three (3) 

Call Spread Contracts with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0300.

(2) CONTRACT 2: The Ceiling shall be X + 0.0150; The Floor shall be X – 0.0150

(3) CONTRACT 3: The Ceiling shall be X + 0.0300; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last GBP/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(vi) INTRADAY 2-HOUR GBP/USD CALL SPREAD CONTRACTS, 

8:00PM, 9:00PM, 10:00PM, 11:00PM, 12:00AM, 1:00AM, 2:00AM, 3:00AM, 4:00AM, 5:00AM,

6:00AM, 7:00AM, 8:00AM, 9:00AM, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, and 3:00PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts that open 2 hours prior to the stated 

closing time(s) above with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0150.

(2) CONTRACT 2: The Ceiling shall be X + 0.0075; The Floor shall be X – 0.0075.

(3) CONTRACT 3: The Ceiling shall be X + 0.0150; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last GBP/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(vii) Nadex may list additional Call Spread Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for GBP/USD Call Spread Variable Payout

Contracts shall be 0.0001.
151

(g) POSITION LIMIT – The Position Limits for GBP/USD Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

GBP/USD Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series shall be the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the Expiration 

Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

GBP/USD Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of GBP/USD Index 

Value released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is 

calculated by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or 

less) occurring in the ten (10) seconds leading up to the close of trading of the GBP/USD Call Spread 

Contract, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing 

the highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data 

set48, using the remaining GBP/USD Midpoints to calculate the Expiration Value. The calculation used is

a simple average of the remaining GBP/USD Midpoints, rounded to one decimal point past the precision of

the underlying market. In the event the time it takes to collect at least ten (10) Midpoints (ten pips wide or

less) exceeds the ten (10) second time period, the Expiration Value is calculated by the Source Agency by 

taking the last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior to the close

of trading of the GBP/USD Call Spread Contract and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) GBP/USD Midpoints to calculate the Expiration

Value. The calculation used is a simple average of all four (4) GBP/USD Midpoints, rounded to one 

decimal point past the precision of the underlying market.

48 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
152

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.30.2 CURRENCY EXCHANGE GBP/USD “TOUCH BRACKET” VARIABLE 

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange GBP/USD (“GBP/USD”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the British Pound/ US dollar, 

herein referred to as “GBP/USD” as quoted in US dollars per British Pound obtained from the spot 

GBP/USD foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the GBP/USD Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY GBP/USD TOUCH BRACKET Variable Payout 

CONTRACTS, Expiration is the earlier of 3:00PM ET on the Last Trade Day of the contract listing, or 

when the GBP/USD Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.0080; The Floor shall be X- 0.0020.

(2) CONTRACT 2: The Ceiling shall be X + 0.0060; The Floor shall be X – 0.0040.

(3) CONTRACT 3: The Ceiling shall be X + 0.0040; The Floor shall be X – 0.0060.

(4) CONTRACT 4: The Ceiling shall be X + 0.0020; The Floor shall be X – 0.0080.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(6) In each case, “X” equals the last GBP/USD price, as reported by the Source Agency, 

rounded to the nearest 0.0001.
153

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.0080 (or 0.0020) and a Floor of X – 0.0020 (or 0.0080) where X 

equals the Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket 

will have the same Last Trade Day as originally established for the expired Touch Bracket and the same 

Dollar Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for GBP/USD Touch Bracket Variable Payout 

Contracts shall be 0.0001.

(g) POSITION LIMIT – The Position Limit for GBP/USD Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

GBP/USD Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Seriesisthe same date asthe Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

GBP/USD Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) GBP/USD INDEX VALUE – The Source Agency shall calculate and produce a GBP/USD 

Index Value once each second throughout the life of the GBP/USD Variable Payout contracts. That is, 

each second the Source Agency will calculate a GBP/USD Index Value by taking all Midpoints between 

the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing the 

highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set49, 

using the remaining GBP/USD Midpoints to calculate the GBP/USD Index Value for that second. The 

calculation used is a simple average of the remaining GBP/USD Midpoints, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least ten (10)

49 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
154

Midpoints (ten pips wide or less) exceeds the ten (10) second time period, the GBP/USD Index Value is 

calculated by the Source Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten

pips wide or less) just prior to the Calculation Time and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) GBP/USD Midpoints to calculate the GBP/USD 

Index Value. The calculation used is a simple average of all four (4) GBP/USD Midpoints, rounded to 

one decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the GBP/USD Index Value released by the 

Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.31 CURRENCY EXCHANGE GBP/USD BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange GBP/USD (“GBP/USD”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the British Pound/US dollar 

herein referred to as “GBP/USD” as quoted in US dollars per British Pound obtained from the spot 

GBP/USD foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the GBP/USD Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY GBP/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0050.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly GBP/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “W” is valued ‘at-the-money’ in relation to the Underlying
155

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0025 or 0.0075 as reported by the Source Agency. Six (6) 

strike levels will be generated above Binary Contract W at an interval of 

0.0050, and seven (7) strike levels will be generated below Binary Contract W 

at an interval of 0.0050 (e.g. W – 0.0050; W; W + 0.0050). The Contract will 

have a Payout Criterion of greater than the strike level value.

(ii) DAILY GBP/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 3 AM, 7 AM, 11 AM, 3 PM, 7 PM, 11 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0020.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily GBP/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0020 as reported by the Source Agency. Ten (10) strike 

levels will be generated above Binary Contract X at an interval of 0.0020, and 

ten (10) strike levels will be generated below Binary Contract X at an interval 

of 0.0020 (e.g. X – 0.0020; X; X + 0.0020). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iii) INTRADAY 2-HOUR GBP/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 8 PM, 9 PM, 10 PM, 11 PM, 12 AM, 1 AM, 2 AM,

3 AM, 4 AM, 5 AM, 6 AM, 7 AM, 8 AM, 9 AM, 10 AM, 11 AM, 12 PM,

1 PM , 2 PM, 3 PM, 4 PM, 5 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0010.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels

will be listed for each Intraday 2-Hour GBP/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that
156

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.0000, 0.0002, 0.0004, 0.0006, or 0.0008 as reported by the 

Source Agency. Four (4) strike levels will be generated above Binary Contract Y at 

an interval of 0.0010, and four (4) strike levels will be generated below Binary 

Contract Y at an interval of 0.0010 (e.g. Y – 0.0010; Y; Y + 0.0010). The Contract 

will have a Payout Criterion of greater than the strike level value.

(iv) INTRADAY 5-MINUTE GBP/USD BINARY CONTRACTS

(1) EXPIRATION TIME – 5-Minute Binary Contracts will expire every 5 

Minutes beginning Sunday at 6:05pm ET and ending Friday at 4:00pm ET.

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level

shall be 0.0002 for expirations occurring between 6:05pm ET and 8:05am ET and 

between 12:10pm ET and 5:00pm ET; the interval width shall be 0.0004 for 

expirations occurring between 8:10am ET and 12:05pm ET.

(3) NUMBER OF STRIKE LEVELS LISTED – Five (5) strike levels

will be listed for each Intraday 5-Minute GBP/USD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.0001, 0.0003, 0.0005, 0.0007, or 0.0009 as reported by the 

Source Agency. For expirations occurring between 6:05pm ET and 8:05am ET and 

between 12:10pm ET and 5:00pm ET, two (2) strike levels will be generated above 

Binary Contract Z at an interval of 0.0002, and two (2) strike levels will be generated 

below Binary Contract Z at an interval of 0.0002 (e.g. Z – 0.0002; Z; Z + 0.0002). The 

Contract will have a Payout Criterion of greater than the strike level value. For 

expirations occurring between 8:10am ET and 12:05pm ET, two (2) strike levels will 

be generated above Binary Contract Z at an interval of 0.0004, and two (2) strike levels 

will be generated below Binary Contract Z at an interval of 0.0004 (e.g. Z – 0.0004; Z; 

Z + 0.0004). The Contract will have a Payout Criterion of greater than the strike level 

value.

(5) Nadex may, in its discretion, temporarily refrain from the listing of any 5-Minute 

Binary Contract due to the unavailability of the underlying market upon

which the Contract is based, or any other condition Nadex determines may be 

detrimental to the listing of the Contract.
157

(v) Nadex may list additional GBP/USD Binary Contract with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for GBP/USD Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for GBP/USD Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

GBP/USD Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration 

Date. No trading in the GBP/USD Binary Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date the GBP/USD number is 

scheduled to be released.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

GBP/USD number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on the Settlement Date. The Settlement Value of an in the money GBP/USD Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of GBP/USD released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the GBP/USD Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set50, using the remaining GBP/USD Midpoints 

to calculate the Expiration Value. The calculation used is a simple average of the remaining GBP/USD 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the GBP/USD Binary Contract 

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the remaining four

(4) GBP/USD Midpoints to calculate the Expiration Value. The calculation used is a

50 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
158

simple average of all four (4) GBP/USD Midpoints, rounded to one decimal point past the precision of 

the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.32 CURRENCY EXCHANGE USD/CAD VARIABLE PAYOUT CONTRACTS

RULE 12.32.1 CURRENCY EXCHANGE USD/CAD “CALL SPREAD” VARIABLE

PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/CAD (“USD/CAD”) Call Spread Variable Payout Contracts, referred to as a “Call 

Spread”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the US the US Dollar/ 

Canadian Dollar, herein referred to as “USD/CAD” as quoted in US dollars per Canadian Dollar obtained 

from the spot USD/CAD foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at 

the time the Variable Payout Contracts are initially issued. For the USD/CAD Call Spread Variable Payout 

Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY USD/CAD CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly USD/CAD Call

Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY USD/CAD CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0375. 

(bb) FLOOR – The Floor shall be X – 0.0375.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last USD/CAD price, as reported by the Source 

Agency, rounded to the nearest 0.0010.
159

(ii) WEEKLY USD/CAD CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly USD/CAD Call 

Spread, Nadex shall list five (5) Call Spread Contracts with overlapping ranges, which conforms to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X – 0.0125; The Floor shall be X – 0.0375.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 0.0250.

(3) CONTRACT 3: The Ceiling shall be X + 0.0125; The Floorshall be X – 0.0125.

(4) CONTRACT 4: The Ceiling shall be X + 0.0250; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 0.0375; The Floorshall be X – 0.0125.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(7) In each case, “X” equals the last USD/CAD price, as reported by the Source

Agency, rounded to the nearest 0.0010.

(iii) DAILY USD/CAD CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE SPREAD - At the commencement of trading in a Daily USD/CAD 

Call Spread Variable Payout Contract, referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread 

Contract, which conforms to the Payout Criteria listed below:

(1) DAILY USD/CAD CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0250. 

(bb) FLOOR – The Floor shall be X – 0.0250.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last USD/CAD price, as reported by the Source 

Agency, rounded to the nearest 0.0010.

(iv) DAILY USD/CAD CALL SPREAD CONTRACTS, 3:00 PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform 

to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 0.0250.

(2) CONTRACT 2: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.
160

(3) CONTRACT 3: The Ceiling shall be X + 0.0250; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last USD/CAD price, as reported by the Source 

Agency, rounded to the nearest 0.0010.

(v) INTRADAY USD/CAD CALL SPREAD CONTRACTS, 6:00PM to

11:00PM, 11:00PM to 7:00AM, 7:00AM to 3:00PM ET CLOSE - Nadex shall list a set of three (3) Call 

Spread Contracts with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0200.

(2) CONTRACT 2: The Ceiling shall be X + 0.0100; The Floor shall be X – 0.0100

(3) CONTRACT 3: The Ceiling shall be X + 0.0200; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last USD/CAD price, as reported by the Source

Agency, rounded to the nearest 0.0010.

(vi) INTRADAY 2-HOUR USD/CAD CALL SPREAD CONTRACTS, 

8:00PM, 9:00PM, 10:00PM, 11:00PM, 12:00AM, 1:00AM, 2:00AM, 3:00AM, 4:00AM, 5:00AM,

6:00AM, 7:00AM, 8:00AM, 9:00AM, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, and 3:00PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts that open 2 hours prior to the stated 

closing time(s) above with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0100.

(2) CONTRACT 2: The Ceiling shall be X + 0.0050; The Floor shall be X – 0.0050

(3) CONTRACT 3: The Ceiling shall be X + 0.0100; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last USD/CAD price, as reported by the Source

Agency, rounded to the nearest 0.0010.

(vii) Nadex may list additional Call Spread Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for USD/CAD Call Spread Contracts shall 

be 0.0001.
161

(g) POSITION LIMIT – The Position Limits for USD/CAD Call Spread Contracts shall be 

250 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

USD/CAD Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

USD/CAD Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of USD/CAD Index 

Value released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is 

calculated by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or 

less) occurring in the ten (10) seconds leading up to the close of trading of the USD/CAD Call Spread 

Contract, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing 

the highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data 

set51, using the remaining USD/CAD Midpoints to calculate the Expiration Value. The calculation used 

is a simple average of the remaining USD/CAD Midpoints, rounded to one decimal point past the precision 

of the underlying market. In the event the time it takes to collect at least ten (10) Midpoints (ten pips wide 

or less) exceeds the ten (10) second time period, the Expiration Value is calculated by the Source Agency 

by taking the last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior to the 

close of trading of the USD/CAD Call Spread Contract and removing the highest three (3) Midpoints and 

the lowest three (3) Midpoints, using the remaining four (4) USD/CAD Midpoints to calculate the 

Expiration Value. The calculation used is a simple average of all four (4) USD/CAD Midpoints, rounded 

to one decimal point past the precision of the underlying market.

51 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
162

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a 

delay, postponement or otherwise in such release announcement by the Source Agency, the Settlement 

Date will be delayed until the Underlying number is released for that Series.

RULE 12.32.2 CURRENCY EXCHANGE USD/CAD “TOUCH BRACKET” VARIABLE

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/CAD (“USD/CAD”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(b) UNDERLYING – Underlying for this Class of Contracts is the US the US Dollar/ Canadian 

Dollar, herein referred to as “USD/CAD” as quoted in US dollars per Canadian Dollar obtained from the 

spot USD/CAD foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the USD/CAD Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY USD/CAD TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Expiration is the earlier of (a) 3:00PM ET on the Last Trade Day of the contract listing, 

or (b) when the USD/CAD Index Value is equal to or greater than the Ceiling, or equal to or less than the 

Floor. Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, each referred to as a 

‘Touch Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, 

which conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.0080; The Floor shall be X- 0.0020.

(2) CONTRACT 2: The Ceiling shall be X + 0.0060; The Floor shall be X – 0.0040.

(3) CONTRACT 3: The Ceiling shall be X + 0.0040; The Floor shall be X- 0.0060.

(4) CONTRACT 4: The Ceiling shall be X + 0.0020; The Floor shall be X – 0.0080.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(6) In each case, “X” equals the last USD/CAD price, as reported by the Source Agency, rounded to the 

nearest 0.0001.
163

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.0080 (or 0.0020) and a Floor of X – 0.0020 (or 0.0080) where X 

equals the Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket 

will have the same Last Trade Day as originally established for the expired Touch Bracket and the same 

Dollar Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK –The Minimum Tick size for the USD/CAD Touch Bracket Variable 

Payout Contracts shall be 0.0001.

(g) POSITION LIMIT –The Position Limit for USD/CAD Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

USD/CAD Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Seriesisthe same date asthe Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

USD/CAD Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) USD/CAD INDEX VALUE – The Source Agency shall calculate and produce a USD/CAD 

Index Value once each second throughout the life of the USD/CAD Variable Payout contracts. That is, 

each second the Source Agency will calculate a USD/CAD Index Value by taking all Midpoints 

between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the 

Calculation Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, 

removing the highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints 

from the data set52, using the remaining USD/CAD Midpoints to calculate the USD/CAD Index Value 

for that second. The calculation used is a simple average of the remaining USD/CAD Midpoints,

52 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
164

rounded to one decimal point past the precision of the underlying market. In the event the time it takes 

to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the USD/CAD Index Value is calculated by the Source Agency by taking the last ten (10) Midpoints 

between the bid/ask spread (ten pips wide or less) just prior to the Calculation Time and removing the 

highest three (3) Midpoints and the lowest three (3) Midpoints, using the remaining four (4) USD/CAD 

Midpoints to calculate the USD/CAD Index Value. The calculation used is a simple average of all four

(4) USD/CAD Midpoints, rounded to one decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the USD/CAD Index Value released by 

the Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date 

will be delayed until the Underlying number is released for that Series.

RULE 12.33 CURRENCY EXCHANGE USD/CAD BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/CAD (“USD/CAD”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the US Dollar/ Canadian 

Dollar herein referred to as “USD/CAD” as quoted in Canadian Dollars per US dollars obtained from the 

spot USD/CAD foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the USD/CAD Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY USD/CAD BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0050.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly USD/CAD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that
165

Binary Contract “W” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0025 or 0.0075 as reported by the Source Agency. Six (6) 

strike levels will be generated above Binary Contract W at an interval of 

0.0050, and seven (7) strike levels will be generated below Binary Contract W 

at an interval of 0.0050 (e.g. W – 0.0050; W; W + 0.0050). The Contract will 

have a Payout Criterion of greater than the strike level value.

(ii) DAILY USD/CAD BINARY CONTRACTS

(1) EXPIRATION TIME – 7 AM, 3 PM, 11 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0010.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily USD/CAD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in 0.000, 0.0020, 0.0040, 0.0060, or 0.0080 as reported by the Source 

Agency. Ten (10) strike levels will be generated above Binary Contract X at an 

interval of 0.0010, and ten (10) strike levels will be generated below Binary Contract 

X at an interval of 0.0010 (e.g. X – 0.0010; X; X + 0.0010). The Contract will have a 

Payout Criterion of greater than the strike level value.

(iii) INTRADAY USD/CAD BINARY CONTRACTS

(1) EXPIRATION TIME – 10 AM, 11 AM, 12 PM, 1PM, 2 PM, 3 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0010.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels 

will be listed for each Intraday USD/CAD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that
166

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.0002, 0.0004, 0.0007, or 0.0009 as reported by the Source 

Agency. Four (4) strike levels will be generated above Binary Contract Y at an interval 

of 0.0010, and four (4) strike levels will be generated below Binary Contract Y at an

interval of 0.0010 (e.g. Y – 0.0010; Y; Y + 0.0010). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iv) INTRADAY 5-MINUTE USD/CAD BINARY CONTRACTS

(1) EXPIRATION TIME – 5-Minute Binary Contracts will expire every 5 

minutes beginning Sunday at 6:05pm ET and ending Friday at 4:00pm ET.

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0005.

(3) NUMBER OF STRIKE LEVELS LISTED – Five (5) strike levels

will be listed for each Intraday 5-Minute USD/CAD Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.0001, 0.0006, 0.0003, or 0.0008 as reported by the Source 

Agency. Two (2) strike levels will be generated above Binary Contract Z at an interval 

of 0.0005, and two (2) strike levels will be generated below Binary Contract Z at an 

interval of 0.0005 (e.g. Z – 0.0005; Z; Z + 0.0005). The Contract will have a Payout 

Criterion of greater than the strike level value.

(5) Nadex may, in its discretion, temporarily refrain from the listing of any 5-Minute 

Binary Contract due to the unavailability of the underlying market upon

which the Contract is based, or any other condition Nadex determines may be 

detrimental to the listing of the Contract.

(v) Nadex may list additional USD/CAD Binary Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations

(f) MINIMUM TICK – The Minimum Tick size for the USD/CAD Binary Contracts shall be

$0.25.
167

(g) POSITION LIMIT – The Position Limits for USD/CAD Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the

USD/CAD Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration

Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date on which the USD/CAD

Settlement Price is released by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

USD/CAD Settlement Price is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on the Settlement Date. The Settlement Value for an in the money USD/CAD Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of USD/CAD released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the USD/CAD Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set53, using the remaining USD/CAD Midpoints 

to calculate the Expiration Value. The calculation used is a simple average of the remaining USD/CAD 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the USD/CAD Binary Contract 

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the remaining four 

(4) USD/CAD Midpoints to calculate the Expiration Value. The calculation used is a simple average of 

all four (4) USD/CAD Midpoints, rounded to one decimal point past the precision of the underlying 

market.

53 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
168

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.34 CURRENCY EXCHANGE USD/CHF VARIABLE PAYOUT CONTRACTS

RULE 12.34.1 CURRENCY EXCHANGE USD/CHF “CALL SPREAD” VARIABLE

PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/CHF (“USD/CHF”) Call Spread Variable Payout Contracts, referred to as a ‘Call Spread’, 

issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the US dollar/ Swiss Franc, 

herein referred to as “USD/CHF” as quoted in the Swiss Franc per US dollars obtained from the spot 

USD/CHF foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the USD/CHF Call Spreads, the Payout 

Criteria for the Contracts will be set as follows:

(i) WEEKLY USD/CHF CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE – At the commencement of trading in a Weekly USD/CHF Call Spread, Nadex shall 

list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY USD/CHF CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0375. 

(bb) FLOOR – The Floor shall be X – 0.0375.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last USD/CHF price, as reported by the Source Agency,

rounded to the nearest 0.0010.

(ii) WEEKLY USD/CHF CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly USD/CHF Call 

Spread, Nadex shall list five (5) Call Spread Contracts with overlapping ranges, which conforms to the 

Payout Criteria listed below:
169

(1) CONTRACT 1: The Ceiling shall be X – 0.0125; The Floor shall be X – 0.0375.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 0.0250.

(3) CONTRACT 3: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.

(4) CONTRACT 4: The Ceiling shall be X + 0.0250; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 0.0375; The Floor shall be X – 0.0125.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(7) In each case, “X” equals the last USD/CHF price, as reported by the Source Agency,

rounded to the nearest 0.0010.

(iii) DAILY USD/CHF CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE - At the commencement of trading in a Daily USD/CHF Call Spread, Nadex shall 

list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) DAILY USD/CHF CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0250. 

(bb) FLOOR – The Floor shall be X – 0.0250.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last USD/CHF price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(iv) DAILY USD/CHF CALL SPREAD CONTRACTS, 3:00 PM ET CLOSE -

Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 0.0250.

(2) CONTRACT 2: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.

(3) CONTRACT 3: The Ceiling shall be X + 0.0250; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last USD/CHF price, as reported by the Source Agency,

rounded to the nearest 0.0010.
170

(v) INTRADAY USD/CHF CALL SPREAD CONTRACTS, 6:00PM to 11:00PM,

11:00PM to 7:00AM, 7:00AM to 3:00PM ET CLOSE - Nadex shall list a set of three (3) Call Spread 

Contracts with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0200.

(2) CONTRACT 2: The Ceiling shall be X + 0.0100; The Floor shall be X – 0.0100

(3) CONTRACT 3: The Ceiling shall be X + 0.0200; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last USD/CHF price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(vi) INTRADAY 2-HOUR USD/CHF CALL SPREAD CONTRACTS, 8:00PM, 

9:00PM, 10:00PM, 11:00PM, 12:00AM, 1:00AM, 2:00AM, 3:00AM, 4:00AM, 5:00AM, 6:00AM,

7:00AM, 8:00AM, 9:00AM, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, and 3:00PM ET CLOSE

- Nadex shall list a set of three (3) Call Spread Contracts that open 2 hours prior to the stated closing 

time(s) above with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 0.0100.

(2) CONTRACT 2: The Ceiling shall be X + 0.0050; The Floor shall be X – 0.0050

(3) CONTRACT 3: The Ceiling shall be X + 0.0100; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last USD/CHF price, as reported by the Source Agency, 

rounded to the nearest 0.0010.

(vii) Nadex may list additional Call Spread Contracts with different ranges of

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for USD/CHF Call Spread Variable Payout 

Contracts shall be 0.0001.

(g) POSITION LIMIT – The Position Limits for USD/CHF Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

USD/CHF Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts 

per strike level.
171

Date.

(i) LAST TRADING DATE – The Last Trading Date in a Series isthe same date asthe Settlement

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

USD/CHF Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of USD/CHF Index 

Value released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is 

calculated by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or 

less) occurring in the ten (10) seconds leading up to the close of trading of the USD/CHF Call Spread 

Contract, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing 

the highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data 

set54, using the remaining USD/CHF Midpoints to calculate the Expiration Value. The calculation used is

a simple average of the remaining USD/CHF Midpoints, rounded to one decimal point past the precision of

the underlying market. In the event the time it takes to collect at least ten (10) Midpoints (ten pips wide or

less) exceeds the ten (10) second time period, the Expiration Value is calculated by the Source Agency by 

taking the last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior to the close

of trading of the USD/CHF Call Spread Contract and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) USD/CHF Midpoints to calculate the Expiration

Value. The calculation used is a simple average of all four (4) USD/CHF Midpoints, rounded to one 

decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.34.2 CURRENCY EXCHANGE USD/CHF “TOUCH BRACKET” VARIABLE 

PAYOUT CONTRACTS

54 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
172

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/CHF (“USD/CHF”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the US dollar/ Swiss Franc, 

herein referred to as “USD/CHF” as quoted in the Swiss Franc per US dollars obtained from the spot 

USD/CHF foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the USD/CHF Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY USD/CHF TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 3:00PM ET on the last Trade Day of the contract listing, or 

when the USD/CHF Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.0080; The Floor shall be X – 0.0020.

(2) CONTRACT 2: The Ceiling shall be X + 0.0060; The Floor shall be X – 0.0040.

(3) CONTRACT 3: The Ceiling shall be X + 0.0040; The Floor shall be X – 0.0060.

(4) CONTRACT 4: The Ceiling shall be X + 0.0020; The Floor shall be X – 0.0080.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(6) In each case, “X” equals the last USD/CHF price, as reported by the Source Agency, 

rounded to the nearest 0.0001.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.0080 (or 0.0020) and a Floor of X – 0.0020 (or 0.0080) where X 

equals the Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket 

will have the same Last Trade Day as originally established for the expired Touch Bracket and the same 

Dollar Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK –The Minimum Tick size for the USD/CHF Touch Bracket Variable 

Payout Contracts shall be 0.0001.
173

(g) POSITION LIMIT – The Position Limit for USD/CHF Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

USD/CHF Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Seriesisthe same date asthe Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

USD/CHF Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) USD/CHF INDEX VALUE – The Source Agency shall calculate and produce a USD/CHF 

Index Value once each second throughout the life of the USD/CHF Variable Payout contracts. That is, 

each second the Source Agency will calculate a USD/CHF Index Value by taking all Midpoints between 

the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing the 

highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set55, 

using the remaining USD/CHF Midpoints to calculate the USD/CHF Index Value for that second. The 

calculation used is a simple average of the remaining USD/CHF Midpoints, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least ten (10) 

Midpoints (ten pips wide or less) exceeds the ten (10) second time period, the USD/CHF Index Value is 

calculated by the Source Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten 

pips wide or less) just prior to the Calculation Time and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) USD/CHF Midpoints to calculate the USD/CHF 

Index Value. The calculation used is a simple average of all four (4) USD/CHF Midpoints, rounded to 

one decimal point past the precision of the underlying market.

55 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
174

(n) EXPIRATION VALUE – The Expiration Value is the USD/CHF Index Value released by the 

Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.35 CURRENCY EXCHANGE USD/CHF BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/CHF (“USD/CHF”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the US dollar/ Swiss Franc 

herein referred to as “USD/CHF” as quoted in the Swiss Franc per US dollar obtained from the spot 

USD/CHF foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the USD/CHF Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY USD/CHF BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0050.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly USD/CHF Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0025 or 0.0075 as reported by the Source Agency. Six (6) 

strike levels will be generated above Binary Contract X at an interval of 

0.0050, and seven (7) strike levels will be generated below Binary Contract X 

at an interval of 0.0050 (e.g. X – 0.0050; X; X + 0.0050). The Contract will 

have a Payout Criterion of greater than the strike level value.
175

(ii) DAILY USD/CHF BINARY CONTRACTS

(1) EXPIRATION TIME – 7 AM, 3 PM, 11 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0010.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily USD/CHF Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0020 as reported by the Source Agency. Ten (10) strike 

levels will be generated above Binary Contract Y at an interval of 0.0010, and 

ten (10) strike levels will be generated below Binary Contract Y at an interval 

of 0.0010 (e.g. Y – 0.0010; Y; Y + 0.0010). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iii) INTRADAY USD/CHF BINARY CONTRACTS

(1) EXPIRATION TIME – 10 AM, 11 AM, 12 PM, 1 PM, 2 PM, 3 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0004.

(3) NUMBER OF STRIKE LEVELS LISTED – Fifteen (15) strike levels 

will be listed for each Intraday USD/CHF Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0001 as reported by the Source Agency. Seven (7) strike 

levels will be generated above Binary Contract Z at an interval of 0.0004, and 

seven (7) strike levels will be generated below Binary Contract Z at an 

interval of 0.0004 (e.g. Z – 0.0004; Z; Z + 0.0004). The Contract will have a 

Payout Criterion of greater than the strike level value.
176

(ii) Nadex may list additional USD/CHF Binary Contract with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.

(f) MINIMUM TICK - The Minimum Tick size for USD/CHF Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for USD/CHF Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

USD/CHF Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration 

Date. No trading in the USD/CHF Binary Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date the USD/CHF number is 

released by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

USD/CHF number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money USD/CHF Binary Contract 

is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of USD/CHF released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the USD/CHF Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set56, using the remaining USD/CHF Midpoints 

to calculate the Expiration Value. The calculation used is a simple average of the remaining USD/CHF 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the USD/CHF Binary Contract

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the

56 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
177

remaining four (4) USD/CHF Midpoints to calculate the Expiration Value. The calculation used is a 

simple average of all four (4) USD/CHF Midpoints, rounded to one decimal point past the precision of 

the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.36 CURRENCY EXCHANGE USD/JPY VARIABLE PAYOUT CONTRACTS

RULE 12.36.1 CURRENCY EXCHANGE USD/JPY “CALL SPREAD” VARIABLE PAYOUT 

CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/JPY (“USD/JPY”) Call Spread Variable Payout Contracts, referred to as a ‘Call Spread’, 

issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the US dollar/ Japanese Yen, 

herein referred to as “USD/JPY” as quoted in the Japanese Yen per US dollars obtained from the spot 

USD/JPY foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the USD/JPY Call Spreads, the Payout Criteria 

for the Contracts will be set as follows:

(i) WEEKLY USD/JPY CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly USD/JPY Call 

Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY USD/JPY CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 3.75. 

(bb) FLOOR – The Floor shall be X – 3.75.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last USD/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.
178

(ii) WEEKLY USD/JPY CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly USD/JPY Call 

Spread, Nadex shall list five (5) Call Spread Contracts with overlapping ranges, which conforms to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X – 1.25; The Floor shall be X – 3.75.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 2.50.

(3) CONTRACT 3: The Ceiling shall be X + 1.25; The Floor shall be X – 1.25.

(4) CONTRACT 4: The Ceiling shall be X + 2.50; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 3.75; The Floor shall be X – 1.25.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(7) In each case, “X” equals the last USD/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(iii) DAILY USD/JPY CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE - At the commencement of trading in a Daily USD/JPY Call Spread, Nadex shall list 

one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) DAILY USD/JPY CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 2.50. 

(bb) FLOOR – The Floor shall be X – 2.50.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last USD/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(iv) DAILY USD/JPY CALL SPREAD CONTRACTS, 3:00 PM ET CLOSE

- Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 2.50.

(2) CONTRACT 2: The Ceiling shall be X + 1.25; The Floor shall be X – 1.25.

(3) CONTRACT 3: The Ceiling shall be X + 2.50; The Floor shall be X.
179

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last USD/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(v) INTRADAY USD/JPY CALL SPREAD CONTRACTS, 6:00PM to

11:00PM, 11:00PM to 7:00AM, and 7:00AM to 3:00PM ET CLOSE - Nadex shall list a set of three (3) 

Call Spread Contracts with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 1.50.

(2) CONTRACT 2: The Ceiling shall be X + 0.75; The Floor shall be X – 0.75.

(3) CONTRACT 3: The Ceiling shall be X + 1.50; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last USD/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(vi) INTRADAY 2-HOUR USD/JPY CALL SPREAD CONTRACTS, 

8:00PM, 9:00PM, 10:00PM, 11:00PM, 12:00AM, 1:00AM, 2:00AM, 3:00AM, 4:00AM, 5:00AM,

6:00AM, 7:00AM, 8:00AM, 9:00AM, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, and 3:00PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts that open 2 hours prior to the stated 

closing time(s) above with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 1.00.

(2) CONTRACT 2: The Ceiling shall be X + 0.50; The Floor shall be X – 0.50.

(3) CONTRACT 3: The Ceiling shall be X + 1.00; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last USD/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(vii) Nadex may list additional Call Spread Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for USD/JPY Call Spread Variable Payout 

Contracts shall be 0.01.
180

(g) POSITION LIMIT – The Position Limits for USD/JPY Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

USD/JPY Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series isthe same date asthe Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

USD/JPY Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value shall be the amount paid to the holder of 

either a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable 

Payout Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value isthe price or value of USD/JPY Index Value 

released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is calculated 

by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring 

in the ten (10) seconds leading up to the close of trading of the USD/JPY Call Spread Contract, provided 

at least ten (10) Midpoints are captured during the ten (10) second period, removing the highest thirty (30) 

percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set57, using the 

remaining USD/JPY Midpoints to calculate the Expiration Value. The calculation used is a simple average 

of the remaining USD/JPY Midpoints, rounded to one decimal point past the precision of the underlying 

market. In the event the time it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds 

the ten (10) second time period, the Expiration Value is calculated by the Source Agency by taking the 

last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior to the close of trading 

of the USD/JPY Call Spread Contract and removing the highest three (3) Midpoints and the lowest three

(3) Midpoints, using the remaining four (4) USD/JPY Midpoints to calculate the Expiration Value. The 

calculation used is a simple average of all four (4) USD/JPY Midpoints, rounded to one decimal point 

past the precision of the underlying market.

57 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
181

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.36.2 CURRENCY EXCHANGE USD/JPY “TOUCH BRACKET” VARIABLE

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/JPY (“USD/JPY”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the US dollar/ Japanese Yen, 

herein referred to as “USD/JPY” as quoted in the Japanese Yen per US dollars obtained from the spot 

USD/JPY foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the USD/JPY Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY USD/JPY TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 3:00PM ET on the last Trade Day of the contract listing, or 

when the USD/JPY Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.60; The Floor shall be X - 0.15.

(2) CONTRACT 2: The Ceiling shall be X + 0.45; The Floor shall be X – 0.30.

(3) CONTRACT 3: The Ceiling shall be X + 0.30; The Floor shall be X – 0.45.

(4) CONTRACT 4: The Ceiling shall be X + 0.15; The Floor shall be X – 0.60.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(6) In each case, “X” equals the last USD/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.01.
182

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.60 (or 0.15) and a Floor of X – 0.15 (or 0.60) where X equals the 

Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have the 

same Last Trade Day as originally established for the expired Touch Bracket and the same Dollar 

Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for USD/JPY Touch Bracket Variable Payout 

Contracts shall be 0.01.

(g) POSITION LIMIT –The Position Limit for USD/JPY Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

USD/JPY Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

USD/JPY Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value shall be the amount paid to the holder of 

either a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable 

Payout Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) USD/JPY INDEX VALUE – The Source Agency shall calculate and produce a USD/JPY 

Index Value once each second throughout the life of the USD/JPY Variable Payout contracts. That is, 

each second the Source Agency will calculate a USD/JPY Index Value by taking all Midpoints between 

the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing the 

highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set58, 

using the remaining USD/JPY Midpoints to calculate the USD/JPY Index Value for that second. The 

calculation used is a simple average of the remaining USD/JPY Midpoints, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least ten (10)

58 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
183

Midpoints (ten pips wide or less) exceeds the ten (10) second time period, the USD/JPY Index Value is 

calculated by the Source Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten 

pips wide or less) just prior to the Calculation Time and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) USD/JPY Midpoints to calculate the USD/JPY 

Index Value. The calculation used is a simple average of all four (4) USD/JPY Midpoints, rounded to one 

decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the USD/JPY Index Value released by the 

Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.37 CURRENCY EXCHANGE USD/JPY BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/JPY (“USD/JPY”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the US dollar/ Japanese Yen, 

herein referred to as “USD/JPY” as quoted in the Japanese Yen per US dollar obtained from the spot 

USD/JPY foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the USD/JPY Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY USD/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.50.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly USD/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “W” is valued ‘at-the-money’ in relation to the Underlying
184

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.25 or 0.75 as reported by the Source Agency. Six (6) strike 

levels will be generated above Binary Contract W at an interval of 0.50, and 

seven (7) strike levels will be generated below Binary Contract W at an 

interval of 0.50 (e.g. W – 0.50; W; W + 0.50). The Contract will have a Payout 

Criterion of greater than the strike level value.

(ii) DAILY USD/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 3 AM, 7 AM, 11 AM, 3 PM, 7 PM, 11 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.12.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily USD/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.20 as reported by the Source Agency. Ten (10) strike levels 

will be generated above Binary Contract X at an interval of 0.12, and ten (10) 

strike levels will be generated below Binary Contract X at an interval of 0.12 

(e.g. X – 0.12; X; X + 0.12). The Contract will have a Payout Criterion of 

greater than the strike level value.

(iii) INTRADAY 2-HOUR USD/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 8 PM, 9 PM, 10 PM, 11 PM, 12 AM, 1 AM, 2 AM,

3 AM, 4 AM, 5 AM, 6 AM, 7 AM, 8 AM, 9 AM, 10 AM, 11 AM, 12 PM,

1 PM , 2 PM, 3 PM, 4 PM, 5 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.04.

(3) NUMBER OF STRIKE LEVELS LISTED – Nineteen (19) strike levels 

will be listed for each Intraday 2-Hour USD/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that
185

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.00, 0.02, 0.04, 0.06, or 0.08 as reported by the Source Agency. 

Nine (9) strike levels will be generated above Binary Contract Y at an interval of 0.04, 

and nine (9) strike levels will be generated below Binary Contract Y at an interval of

0.04 (e.g. Y – 0.04; Y; Y + 0.04). The Contract will have a Payout Criterion of greater 

than the strike level value.

(iv) INTRADAY 5-MINUTE USD/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 5-Minute Binary Contracts will expire every 5 minutes 

beginning Sunday at 6:05pm ET and ending Friday at 4:00pm ET.

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level

shall be 0.02 for expirations occurring between 6:05pm ET and 8:05am ET and 

between 12:10pm ET and 5:00pm ET; the interval width shall be 0.04 for expirations 

occurring between 8:10am ET and 12:05pm ET.

(3) NUMBER OF STRIKE LEVELS LISTED – Five (5) strike levels

will be listed for each Intraday 5-Minute USD/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.01, 0.03, 0.05, 0.07, or 0.09 as reported by the Source Agency. 

For expirations occurring between 6:05pm ET and 8:05am ET and between 12:10pm 

ET and 5:00pm ET, two (2) strike levels will be generated above Binary Contract Z at 

an interval of 0.02, and two (2) strike levels will be generated below Binary Contract 

Z at an interval of 0.02 (e.g. Z – 0.02; Z; Z + 0.02). The Contract will have a Payout 

Criterion of greater than the strike level value. For expirations occurring between 

8:10am ET and 12:05pm ET, two (2) strike levels will be generated above Binary 

Contract Z at an interval of 0.04, and two (2) strike levels will be generated below 

Binary Contract Z at an interval of 0.04 (e.g. Z – 0.04; Z; Z + 0.04). The Contract will 

have a Payout Criterion of greater than the strike level value.

(5) Nadex may, in its discretion, temporarily refrain from the listing of any 5-Minute 

Binary Contract due to the unavailability of the underlying market upon which the 

Contract is based, or any other condition Nadex determines may be detrimental to the 

listing of the Contract.
186

(v) Nadex may list additional USD/JPY Binary Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for USD/JPY Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for USD/JPY Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

USD/JPY Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration 

Date. No trading in the USD/JPY Binary Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date the USD/JPY number isreleased 

by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

USD/JPY number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money USD/JPY Binary Contract 

is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of USD/JPY released by 

the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency by 

taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the USD/JPY Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set59, using the remaining USD/JPY Midpoints 

to calculate the Expiration Value. The calculation used is a simple average of the remaining USD/JPY 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the USD/JPY Binary Contract 

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the remaining four

(4) USD/JPY Midpointsto calculate the Expiration Value. The calculation used is a simple

59 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
187

average of all four (4) USD/JPY Midpoints, rounded to one decimal point past the precision of the 

underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.38 CURRENCY EXCHANGE EUR/JPY VARIABLE PAYOUT CONTRACTS

RULE 12.38.1 CURRENCY EXCHANGE EUR/JPY “CALL SPREAD” VARIABLE PAYOUT 

CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange EUR/JPY (“EUR/JPY”) Call Spread Variable Payout Contracts, referred to as a “Call Spread”, 

issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Euro/Japanese Yen, herein 

referred to as “EUR/JPY” as quoted in the Japanese Yen per Euro obtained from the spot EUR/JPY foreign 

currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the EUR/JPY Call Spread Variable Payout 

Contract, the Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY EUR/JPY CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly EUR/JPY Call 

Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY EUR/JPY CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 3.75. 

(bb) FLOOR – The Floor shall be X – 3.75.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last EUR/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.
188

(ii) WEEKLY EUR/JPY CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly EUR/JPY Call 

Spread, Nadex shall list five (5) Call Spread Contracts with overlapping ranges, which conforms to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X – 1.25; The Floor shall be X – 3.75.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 2.50.

(3) CONTRACT 3: The Ceiling shall be X + 1.25; The Floor shall be X – 1.25.

(4) CONTRACT 4: The Ceiling shall be X + 2.50; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 3.75; The Floor shall be X – 1.25.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(7) In each case, “X” equals the last EUR/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(iii) DAILY EUR/JPY CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE - At the commencement of trading in a Daily EUR/JPY Call Spread 

Variable Payout Contract, referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Contract, 

which conforms to the Payout Criteria listed below:

(1) DAILY EUR/JPY CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 2.50. 

(bb) FLOOR – The Floor shall be X – 2.50.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last EUR/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(iv) DAILY EUR/JPY CALL SPREAD CONTRACTS, 3:00 PM ET CLOSE

- Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 2.50.

(2) CONTRACT 2: The Ceiling shall be X + 1.25; The Floor shall be X – 1.25.
189

(3) CONTRACT 3: The Ceiling shall be X + 2.50; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last EUR/JPY price, as reported by the Source 

Agency, rounded to the nearest 0.10.

(v) INTRADAY EUR/JPY CALL SPREAD CONTRACTS, 6:00PM to

11:00PM, 11:00PM to 7:00AM, and 7:00AM to 3:00PM ET CLOSE - Nadex shall list a set of three (3) 

Call Spread Contracts with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 2.00.

(2) CONTRACT 2: The Ceiling shall be X + 1.00; The Floor shall be X – 1.00.

(3) CONTRACT 3: The Ceiling shall be X + 2.00; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last EUR/JPY price, as reported by the Source 

Agency, rounded to the nearest 0.10.

(vi) INTRADAY 2-HOUR EUR/JPY CALL SPREAD CONTRACTS, 

8:00PM, 9:00PM, 10:00PM, 11:00PM, 12:00AM, 1:00AM, 2:00AM, 3:00AM, 4:00AM, 5:00AM,

6:00AM, 7:00AM, 8:00AM, 9:00AM, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, and 3:00PM ET

CLOSE - Nadex shall list a set of three (3) Call Spread Contracts that open 2 hours prior to the stated 

closing time(s) above with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 1.00.

(2) CONTRACT 2: The Ceiling shall be X + 0.50; The Floor shall be X – 0.50.

(3) CONTRACT 3: The Ceiling shall be X + 1.00; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last EUR/JPY price, as reported by the Source

Agency, rounded to the nearest 0.10.

(vii) Nadex may list additional Call Spread Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for EUR/JPY Call Spread Contracts shall be 0.01.
190

(g) POSITION LIMIT – The Position Limits for EUR/JPY Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

EUR/JPY Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series isthe same date asthe Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

EUR/JPY Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value shall be the amount paid to the holder of 

either a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable 

Payout Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value isthe price or value of EUR/JPY Index Value 

released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is calculated 

by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring 

in the ten (10) seconds leading up to the close of trading of the EUR/JPY Call Spread Contract, provided 

at least ten (10) Midpoints are captured during the ten (10) second period, removing the highest thirty (30) 

percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set60, using the 

remaining EUR/JPY Midpoints to calculate the Expiration Value. The calculation used is a simple average 

of the remaining EUR/JPY Midpoints, rounded to one decimal point past the precision of the underlying 

market. In the event the time it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds 

the ten (10) second time period, the Expiration Value is calculated by the Source Agency by taking the 

last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior to the close of trading 

of the EUR/JPY Call Spread Contract and removing the highest three (3) Midpoints and the lowest three

(3) Midpoints, using the remaining four (4) EUR/JPY Midpoints to calculate the Expiration Value. The 

calculation used is a simple average of all four (4) EUR/JPY Midpoints, rounded to one decimal point 

past the precision of the underlying market.

60 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
191

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.38.2 CURRENCY EXCHANGE EUR/JPY “TOUCH BRACKET” VARIABLE

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange EUR/JPY (“EUR/JPY”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Euro/Japanese Yen, herein 

referred to as “EUR/JPY” as quoted in the Japanese Yen per Euro obtained from the spot EUR/JPY foreign 

currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the EUR/JPY Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY EUR/JPY TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 3:00PM ET on the last Trade Day of the contract listing, or 

when the EUR/JPY Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.600; The Floor shall be X - 0.150.

(2) CONTRACT 2: The Ceiling shall be X + 0.450; The Floor shall be X – 0.300.

(3) CONTRACT 3: The Ceiling shall be X + 0.300; The Floor shall be X – 0.450.

(4) CONTRACT 4: The Ceiling shall be X + 0.150; The Floor shall be X – 0.600.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(6) In each case, “X” equals the last EUR/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.01.
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(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.600 (or 0.150) and a Floor of X – 0.150 (or .600) where X equals 

the Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have 

the same Last Trade Day as originally established for the expired Touch Bracket and the same Dollar 

Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for EUR/JPY Touch Bracket Variable Payout 

Contracts shall be 0.01.

(g) POSITION LIMIT –The Position Limit for EUR/JPY Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

EUR/JPY Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

EUR/JPY Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value shall be the amount paid to the holder of 

either a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable 

Payout Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EUR/JPY INDEX VALUE – The Source Agency shall calculate and produce a EUR/JPY 

Index Value once each second throughout the life of the EUR/JPY Variable Payout contracts. That is, 

each second the Source Agency will calculate a EUR/JPY Index Value by taking all Midpoints between 

the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing the 

highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set61, 

using the remaining EUR/JPY Midpoints to calculate the EUR/JPY Index Value for that second. The 

calculation used is a simple average of the remaining EUR/JPY Midpoints, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least ten (10)

61 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
193

Midpoints (ten pips wide or less) exceeds the ten (10) second time period, the EUR/JPY Index Value is 

calculated by the Source Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten 

pips wide or less) just prior to the Calculation Time and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) EUR/JPY Midpoints to calculate the EUR/JPY 

Index Value. The calculation used is a simple average of all four (4) EUR/JPY Midpoints, rounded to one 

decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the EUR/JPY Index Value released by the 

Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.39 CURRENCY EXCHANGE EUR/JPY BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange EUR/JPY (“EUR/JPY”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Euro/Japanese Yen, herein 

referred to as “EUR/JPY” as quoted in the Japanese Yen per Euro obtained from the spot EUR/JPY foreign 

currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the EUR/JPY Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY EUR/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.50.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly EUR/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “W” is valued ‘at-the-money’ in relation to the Underlying
194

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.25 or 0.75 as reported by the Source Agency. Six (6) strike 

levels will be generated above Binary Contract W at an interval of 0.50, and 

seven (7) strike levels will be generated below Binary Contract W at an 

interval of 0.50 (e.g. W – 0.50; W; W + 0.50). The Contract will have a Payout 

Criterion of greater than the strike level value.

(ii) DAILY EUR/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 3 AM, 7 AM, 11 AM, 3 PM, 7 PM, 11 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.10.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily EUR/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in value ending in either 0.00, 0.20, 0.40, 0.60, or 0.80 as reported by the 

Source Agency. Ten (10) strike levels will be generated above Binary Contract X at 

an interval of 0.10, and ten (10) strike levels will be generated below Binary Contract 

X at an interval of 0.10 (e.g. X – 0.10; X; X + 0.10). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iii) INTRADAY EUR/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 8 PM, 9 PM, 10 PM, 11 PM, 12 AM, 1 AM, 2 AM,

3 AM, 4 AM, 5 AM, 6 AM, 7 AM, 8 AM, 9 AM, 10 AM, 11 AM, 12 PM,

1 PM , 2 PM, 3 PM, 4 PM, 5 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.10.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels 

will be listed for each Intraday EUR/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that
195

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.02, 0.04, 0.07, or 0.09 as reported by the Source Agency. Four

(4) strike levels will be generated above Binary Contract Y at an interval of 0.10, and 

four (4) strike levels will be generated below Binary Contract Y at an interval of 0.10 

(e.g. Y – 0.10; Y; Y + 0.10). The Contract will have a Payout Criterion of greater than 

the strike level value.

(iv) INTRADAY 5-MINUTE EUR/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 5-Minute Binary Contracts will expire every 5 

minutes beginning Sunday at 6:05pm ET and ending Friday at 4:00pm ET.

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.05.

(3) NUMBER OF STRIKE LEVELS LISTED – Five (5) strike levels

will be listed for each Intraday 5-Minute EUR/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.01, 0.06, 0.03, or 0.08 as reported by the Source Agency. Two

(2) strike levels will be generated above Binary Contract Z at an interval of 0.05, and 

two (2) strike levels will be generated below Binary Contract Z at an interval of 0.05 

(e.g. Z – 0.05; Z; Z + 0.05). The Contract will have a Payout Criterion of greater than 

the strike level value.

(5) Nadex may, in its discretion, temporarily refrain from the listing of any 5-Minute 

Binary Contract due to the unavailability of the underlying market upon

which the Contract is based, or any other condition Nadex determines may be 

detrimental to the listing of the Contract.

(v) Nadex may list additional EUR/JPY Binary Contract with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for EUR/JPY Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for EUR/JPY Binary Contracts shall be 2,500 

Contracts per Class.
196

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

EUR/JPY Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration 

Date. No trading in the EUR/JPY Binary Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date the EUR/JPY number is released 

by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

EUR/JPY number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money EUR/JPY Binary Contract 

is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of EUR/JPY released by 

the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency by 

taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the EUR/JPY Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set62, using the remaining EUR/JPY Midpoints 

to calculate the Expiration Value. The calculation used is a simple average of the remaining EUR/JPY 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the EUR/JPY Binary Contract 

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the remaining four

(4) EUR/JPY Midpoints to calculate the Expiration Value. The calculation used is a simple average of all 

four (4) EUR/JPY Midpoints, rounded to one decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

62 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
197

RULE 12.40 CURRENCY EXCHANGE GBP/JPY VARIABLE PAYOUT CONTRACTS

RULE 12.40.1 CURRENCY EXCHANGE GBP/JPY “CALL SPREAD” VARIABLE PAYOUT 

CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange GBP/JPY (“GBP/JPY”) Call Spread Variable Payout Contracts, referred to as a “Call Spread”, 

issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the British Pound/ Japanese 

Yen, herein referred to as “GBP/JPY” as quoted in the Japanese Yen per British Pounds obtained from 

the spot GBP/JPY foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the GBP/JPY Call Spread Variable Payout 

Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY GBP/JPY CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly GBP/JPY Call 

Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY GBP/JPY CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 3.75. 

(bb) FLOOR – The Floor shall be X – 3.75.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last GBP/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(ii) WEEKLY GBP/JPY CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE – At the commencement of trading in a Weekly GBP/JPY Call Spread, Nadex shall 

list five (5) Call Spread Contracts with overlapping ranges, which conforms to the Payout Criteria listed 

below:

(1) CONTRACT 1: The Ceiling shall be X – 1.25; The Floor shall be X – 3.75.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 2.50.
198

(3) CONTRACT 3: The Ceiling shall be X + 1.25; The Floor shall be X – 1.25.

(4) CONTRACT 4: The Ceiling shall be X + 2.50; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 3.75; The Floor shall be X – 1.25.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(7) In each case, “X” equals the last GBP/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(iii) DAILY GBP/JPY CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE - At the commencement of trading in a Daily GBP/JPY Call Spread Variable Payout 

Contract, referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Contract, which conforms to 

the Payout Criteria listed below:

(1) DAILY GBP/JPY CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 2.50. 

(bb) FLOOR – The Floor shall be X – 2.50.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last GBP/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(iv) DAILY GBP/JPY CALL SPREAD CONTRACTS, 3:00 PM ET CLOSE -

Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 2.50.

(2) CONTRACT 2: The Ceiling shall be X + 1.25; The Floor shall be X – 1.25.

(3) CONTRACT 3: The Ceiling shall be X + 2.50; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last GBP/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.
199

(v) INTRADAY GBP/JPY CALL SPREAD CONTRACTS, 6:00PM to 11:00PM,

11:00PM to 7:00AM, and 7:00AM to 3:00PM ET CLOSE - Nadex shall list a set of three (3) Call Spread 

Contracts with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 2.50.

(2) CONTRACT 2: The Ceiling shall be X + 1.25; The Floor shall be X – 1.25.

(3) CONTRACT 3: The Ceiling shall be X + 2.50; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last GBP/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(vi) INTRADAY 2-HOUR GBP/JPY CALL SPREAD CONTRACTS, 8:00PM, 

9:00PM, 10:00PM, 11:00PM, 12:00AM, 1:00AM, 2:00AM, 3:00AM, 4:00AM, 5:00AM, 6:00AM,

7:00AM, 8:00AM, 9:00AM, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, and 3:00PM ET CLOSE -

Nadex shall list a set of three (3) Call Spread Contracts that open 2 hours prior to the stated closing time(s) 

above with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X- 1.00.

(2) CONTRACT 2: The Ceiling shall be X + 0.50; The Floor shall be X – 0.50.

(3) CONTRACT 3: The Ceiling shall be X + 1.00; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last GBP/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(vii) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for GBP/JPY Call Spread Contracts shall be 0.01.

(g) POSITION LIMIT – The Position Limits for GBP/JPY Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

GBP/JPY Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts per 

strike level.
200

Date.

(i) LAST TRADING DATE – The Last Trading Date in a Series isthe same date asthe Settlement

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

GBP/JPY Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value shall be the amount paid to the holder of 

either a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable 

Payout Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of GBP/JPY Index Value 

released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is calculated 

by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring 

in the ten (10) seconds leading up to the close of trading of the GBP/JPY Call Spread Contract, provided 

at least ten (10) Midpoints are captured during the ten (10) second period, removing the highest thirty (30) 

percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set63, using the 

remaining GBP/JPY Midpoints to calculate the Expiration Value. The calculation used is a simple average 

of the remaining GBP/JPY Midpoints, rounded to one decimal point past the precision of the underlying 

market. In the event the time it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds 

the ten (10) second time period, the Expiration Value is calculated by the Source Agency by taking the 

last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior to the close of trading 

of the GBP/JPY Call Spread Contract and removing the highest three (3) Midpoints and the lowest three

(3) Midpoints, using the remaining four (4) GBP/JPY Midpoints to calculate the Expiration Value. The 

calculation used is a simple average of all four (4) GBP/JPY Midpoints, rounded to one decimal point past 

the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.40.2 CURRENCY EXCHANGE GBP/JPY “TOUCH BRACKET” VARIABLE

PAYOUT CONTRACTS

63 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
201

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange GBP/JPY (“GBP/JPY”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the British Pound/ Japanese 

Yen, herein referred to as “GBP/JPY” as quoted in the Japanese Yen per British Pounds obtained from 

the spot GBP/JPY foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the GBP/JPY Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY GBP/JPY TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 3:00PM ET on the last Trade Day of the contract listing, or 

when the GBP/JPY Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.80; The Floor shall be X - 0.20.

(2) CONTRACT 2: The Ceiling shall be X + 0.60; The Floor shall be X – 0.40.

(3) CONTRACT 3: The Ceiling shall be X + 0.40; The Floor shall be X – 0.60.

(4) CONTRACT 4: The Ceiling shall be X + 0.20; The Floor shall be X – 0.80.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(6) In each case, “X” equals the last GBP/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.01.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.80 (or 0.20) and a Floor of X – 0.20 (or 0.80) where X equals the 

Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have the 

same Last Trade Day as originally established for the expired Touch Bracket and the same Dollar 

Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for GBP/JPY Touch Bracket Variable Payout 

Contracts shall be 0.01.
202

(g) POSITION LIMIT –The Position Limit for GBP/JPY Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

GBP/JPY Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

GBP/JPY Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value shall be the amount paid to the holder of 

either a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable 

Payout Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) GBP/JPY INDEX VALUE – The Source Agency shall calculate and produce a GBP/JPY 

Index Value once each second throughout the life of the GBP/JPY Variable Payout contracts. That is, 

each second the Source Agency will calculate a GBP/JPY Index Value by taking all Midpoints between 

the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing the 

highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set64, 

using the remaining GBP/JPY Midpoints to calculate the GBP/JPY Index Value for that second. The 

calculation used is a simple average of the remaining GBP/JPY Midpoints, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least ten (10) 

Midpoints (ten pips wide or less) exceeds the ten (10) second time period, the GBP/JPY Index Value is 

calculated by the Source Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten 

pips wide or less) just prior to the Calculation Time and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) GBP/JPY Midpoints to calculate the GBP/JPY 

Index Value. The calculation used is a simple average of all four (4) GBP/JPY Midpoints, rounded to one 

decimal point past the precision of the underlying market.

64 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
203

(n) EXPIRATION VALUE – The Expiration Value is the GBP/JPY Index Value released by the 

Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.41 CURRENCY EXCHANGE GBP/JPY BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange GBP/JPY (“GBP/JPY”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the British Pound/ Japanese 

Yen, herein referred to as “GBP/JPY” as quoted in the Japanese Yen per British Pounds obtained from 

the spot GBP/JPY foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the GBP/JPY Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY GBP/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.50.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly GBP/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “W” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.25 or 0.75 as reported by the Source Agency. Six (6) strike 

levels will be generated above Binary Contract W at an interval of 0.50, and 

seven (7) strike levels will be generated below Binary Contract W at an 

interval of 0.50 (e.g. W – 0.50; W; W + 0.50). The Contract will have a Payout 

Criterion of greater than the strike level value.
204

(ii) DAILY GBP/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 7 AM, 3 PM, 11 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.20.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily GBP/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.0, 0.20, 0.40, 0.60, or 0.80 as reported by the Source Agency. 

Ten (10) strike levels will be generated above Binary Contract X at an interval of 0.20, 

and ten (10) strike levels will be generated below Binary Contract X at an interval of

0.20 (e.g. X – 0.20; X; X + 0.20). The Contract will have a Payout Criterion of greater 

than the strike level value.

(iii) INTRADAY GBP/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 10 AM, 11 AM, 12 PM, 1 PM, 2 PM, 3 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.10.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels 

will be listed for each Intraday GBP/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.02, 0.04, 0.07, or 0.09 as reported by the Source Agency. Four

(4) strike levels will be generated above Binary Contract Y at an interval of 0.10, and 

four (4) strike levels will be generated below Binary Contract Y at an interval of 0.10 

(e.g. Y – 0.10; Y; Y + 0.10). The Contract will have a Payout Criterion of greater than 

the strike level value.
205

(iv) INTRADAY 5-MINUTE GBP/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 5-Minute Binary Contracts will expire every 5 

minutes beginning Sunday at 6:05pm ET and ending Friday at 4:00pm ET.

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.05.

(3) NUMBER OF STRIKE LEVELS LISTED – Five (5) strike levels

will be listed for each Intraday 5-Minute GBP/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.01, 0.06, 0.03, or 0.08 as reported by the Source Agency. Two

(2) strike levels will be generated above Binary Contract Z at an interval of 0.05, and 

two (2) strike levels will be generated below Binary Contract Z at an interval of 0.05 

(e.g. Z – 0.05; Z; Z + 0.05). The Contract will have a Payout Criterion of greater than 

the strike level value.

(5) Nadex may, in its discretion, temporarily refrain from the listing of any 5-Minute 

Binary Contract due to the unavailability of the underlying market upon

which the Contract is based, or any other condition Nadex determines may be 

detrimental to the listing of the Contract.

(v) Nadex may list additional GBP/JPY Binary Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for GBP/JPY Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for GBP/JPY Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the

GBP/JPY Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration 

Date. No trading in the GBP/JPY Binary Contracts shall occur after its Last Trading Date.
206

(j) SETTLEMENT DATE – The Settlement Date will be the date the GBP/JPY number is released 

by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

GBP/JPY number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money GBP/JPY Binary Contract 

is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of GBP/JPY released by 

the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency by 

taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the GBP/JPY Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set65, using the remaining GBP/JPY Midpoints 

to calculate the Expiration Value. The calculation used is a simple average of the remaining GBP/JPY 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the GBP/JPY Binary Contract 

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the remaining four

(4) GBP/JPY Midpoints to calculate the Expiration Value. The calculation used is a simple average of all 

four (4) GBP/JPY Midpoints, rounded to one decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.42 CURRENCY EXCHANGE EUR/GBP VARIABLE PAYOUT CONTRACTS

RULE 12.42.1 CURRENCY EXCHANGE EUR/GBP “CALL SPREAD” VARIABLE

PAYOUT CONTRACTS

65 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
207

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange EUR/GBP (“EUR/GBP”) Call Spread Variable Payout Contracts, referred to as a “Call Spread”, 

issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Euro/British Pound, herein 

referred to as “EUR/GBP” as quoted in the British Pounds per Euro obtained from the spot EUR/GBP 

foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the EUR/GBP Call Spread Variable Payout 

Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY EUR/GBP CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly EUR/GBP Call 

Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY EUR/GBP CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0375. 

(bb) FLOOR – The Floor shall be X – 0.0375.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last EUR/GBP price, as reported by the Source

Agency, rounded to the nearest 0.0010.

(ii) WEEKLY EUR/GBP CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly EUR/GBP Call 

Spread, Nadex shall list five (5) Call Spread Contracts with overlapping ranges, which conforms to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X – 0.0125; The Floor shall be X – 0.0375.

(2) CONTRACT 2: The Ceiling shall be X; The floor shall be X – 0.0250.

(3) CONTRACT 3: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.

(4) CONTRACT 4: The Ceiling shall be X + 0.0250; The Floor shall be X.
208

(5) CONTRACT 5: The Ceiling shall be X + 0.0375; The Floor shall be X – 0.0125.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(7) In each case, “X” equals the last EUR/GBP price, as reported by the Source Agency,

rounded to the nearest 0.0010.

(iii) DAILY EUR/GBP CALL SPREAD VARIABLE CONTRACTS, 3:00 PM

ET CLOSE - At the commencement of trading in a Daily EUR/GBP Call Spread Variable Payout Contract, 

referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout 

Criteria listed below:

(1) DAILY EUR/GBP CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 0.0250. 

(bb) FLOOR – The Floor shall be X – 0.0250.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(2) In each case, “X” equals the last EUR/GBP price, as reported by the Source

Agency, rounded to the nearest 0.0010.

(iv) DAILY EUR/GBP CALL SPREAD CONTRACTS, 3:00 PM ET CLOSE

- Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 0.0250.

(2) CONTRACT 2: The Ceiling shall be X + 0.0125; The Floor shall be X – 0.0125.

(3) CONTRACT 3: The Ceiling shall be X + 0.0250; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(5) In each case, “X” equals the last EUR/GBP price, as reported by the Source

Agency, rounded to the nearest 0.0010.

(v) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for EUR/GBP Call Spread Contracts shall be

0.0001.
209

(g) POSITION LIMIT – The Position Limits for EUR/GBP Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

EUR/GBP Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Seriesisthe same date asthe Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

EUR/GBP Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value shall be the amount paid to the holder of 

either a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable 

Payout Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of EUR/GBP Index 

Value released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is 

calculated by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or 

less) occurring in the ten (10) seconds leading up to the close of trading of the EUR/GBP Call Spread 

Contract, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing 

the highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data 

set66, using the remaining EUR/GBP Midpoints to calculate the Expiration Value. The calculation used 

is a simple average of the remaining EUR/GBP Midpoints, rounded to one decimal point past the precision 

of the underlying market. In the event the time it takes to collect at least ten (10) Midpoints (ten pips wide 

or less) exceeds the ten (10) second time period, the Expiration Value is calculated by the Source Agency 

by taking the last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior to the 

close of trading of the EUR/GBP Call Spread Contract and removing the highest three (3) Midpoints and 

the lowest three (3) Midpoints, using the remaining four (4) EUR/GBP Midpoints to calculate the 

Expiration Value. The calculation used is a simple average of all four (4) EUR/GBP Midpoints, rounded 

to one decimal point past the precision of the underlying market.

66 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
210

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.42.2 CURRENCY EXCHANGE EUR/GBP “TOUCH BRACKET” VARIABLE 

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange EUR/GBP (“EUR/GBP”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Euro/British Pound, herein 

referred to as “EUR/GBP” as quoted in the British Pounds per Euro obtained from the spot EUR/GBP 

foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the EUR/GBP Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY EUR/GBP TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 3:00PM ET on the last Trade Day of the contract listing, or 

when the EUR/GBP Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.0060; The Floor shall be X – 0.0015.

(2) CONTRACT 2: The Ceiling shall be X + 0.0045; The Floor shall be X – 0.0030.

(3) CONTRACT 3: The Ceiling shall be X + 0.0030; The Floor shall be X – 0.0045.

(4) CONTRACT 4: The Ceiling shall be X + 0.0015; The Floor shall be X – 0.0060.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10,000.

(6) In each case, “X” equals the last EUR/GBP price, as reported by the Source Agency, 

rounded to the nearest 0.0001.
211

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.0060 (or 0.0015) and a Floor of X – 0.0015 (or 0.0060) where X 

equals the Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket 

will have the same Last Trade Day as originally established for the expired Touch Bracket and the same 

Dollar Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK –The Minimum Tick size for the EUR/GBP Touch Bracket Variable Payout 

Contracts shall be 0.0001.

(g) POSITION LIMIT – The Position Limit for EUR/GBP Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

EUR/GBP Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

EUR/GBP Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EUR/GBP INDEX VALUE – The Source Agency shall calculate and produce a EUR/GBP 

Index Value once each second throughout the life of the EUR/GBP Variable Payout contracts. That is, 

each second the Source Agency will calculate a EUR/GBP Index Value by taking all Midpoints between 

the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing the 

highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set67, 

using the remaining EUR/GBP Midpoints to calculate the EUR/GBP Index Value for that second. The 

calculation used is a simple average of the remaining EUR/GBP Midpoints, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least ten (10)

67 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
212

Midpoints (ten pips wide or less) exceeds the ten (10) second time period, the EUR/GBP Index Value is 

calculated by the Source Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten 

pips wide or less) just prior to the Calculation Time and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) EUR/GBP Midpoints to calculate the EUR/GBP 

Index Value. The calculation used is a simple average of all four (4) EUR/GBP Midpoints, rounded to 

one decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the EUR/GBP Index Value released by 

the Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.43 CURRENCY EXCHANGE EUR/GBP BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange EUR/GBP (“EUR/GBP”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Euro/British Pound herein 

referred to as “EUR/GBP” as quoted in British Pounds per Euro obtained from the spot EUR/GBP foreign 

currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the EUR/GBP Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY EUR/GBP BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0050.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly EUR/GBP Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying
213

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0025 or 0.0075 as reported by the Source Agency. Six (6) 

strike levels will be generated above Binary Contract X at an interval of 

0.0050, and seven (7) strike levels will be generated below Binary Contract X 

at an interval of 0.0050 (e.g. X – 0.0050; X; X + 0.0050). The Contract will 

have a Payout Criterion of greater than the strike level value.

(ii) DAILY EUR/GBP BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0010.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily EUR/GBP Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0020 as reported by the Source Agency. Ten (10) strike 

levels will be generated above Binary Contract Y at an interval of 0.0010, and 

ten (10) strike levels will be generated below Binary Contract Y at an interval 

of 0.0010 (e.g. Y – 0.0010; Y; Y + 0.0010). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iii) INTRADAY EUR/GBP BINARY CONTRACTS

(1) EXPIRATION TIME – 10 AM, 11 AM, 12 PM,1 PM , 2 PM, 3 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.0010.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels 

will be listed for each Intraday EUR/GBP Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying
214

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.0001 as reported by the Source Agency. Four (4) strike 

levels will be generated above Binary Contract Z at an interval of 0.0010, and 

four (4) strike levels will be generated below Binary Contract Z at an interval 

of 0.0010 (e.g. Z – 0.0010; Z; Z + 0.0010). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iv) Nadex may list additional EUR/GBP Binary Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for EUR/GBP Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for EUR/GBP Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

EUR/GBP Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same as the Expiration 

Date. No trading in the EUR/GBP Binary Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date on which the EUR/GBP number 

as reported by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

EUR/GBP number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on the Settlement Date. The Settlement Value of an in the money EUR/GBP Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of EUR/GBP released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the EUR/GBP Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set68, using the remaining EUR/GBP Midpoints

68 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of
215

to calculate the Expiration Value. The calculation used is a simple average of the remaining EUR/GBP 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the EUR/GBP Binary Contract 

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the remaining four 

(4) EUR/GBP Midpoints to calculate the Expiration Value. The calculation used is a simple average of 

all four (4) EUR/GBP Midpoints, rounded to one decimal point past the precision of the underlying 

market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.44 CURRENCY EXCHANGE AUD/JPY VARIABLE PAYOUT CONTRACTS

RULE 12.44.1 CURRENCY EXCHANGE AUD/JPY “CALL SPREAD” VARIABLE PAYOUT 

CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange AUD/JPY (“AUD/JPY”) Call Spread Variable Payout Contracts, referred to as a “Call Spread”, 

issued by Nadex. Variable Payout Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Australian Dollar/Japanese 

Yen, herein referred to as “AUD/JPY” as quoted in the Japanese Yen per Australian Dollar obtained from 

the spot AUD/JPY foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the AUD/JPY Call Spread Variable Payout 

Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY AUD/JPY CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly AUD/JPY Call 

Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) WEEKLY AUD/JPY CALL SPREAD CONTRACT

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
216

(aa) CEILING – The Ceiling shall be X + 3.75. 

(bb) FLOOR – The Floor shall be X – 3.75.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last AUD/JPY price, as reported by the Source

Agency, rounded to the nearest 0.10.

(ii) WEEKLY AUD/JPY CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 3:00 PM ET CLOSE – At the commencement of trading in a Weekly AUD/JPY Call 

Spread, Nadex shall list five (5) Call Spread Contracts with overlapping ranges, which conforms to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X – 1.25; The Floor shall be X – 3.75.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 2.50.

(3) CONTRACT 3: The Ceiling shall be X + 1.25; The Floor shall be X – 1.25.

(4) CONTRACT 4: The Ceiling shall be X + 2.50; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 3.75; The Floor shall be X – 1.25.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(7) In each case, “X” equals the last AUD/JPY price, as reported by the Source

Agency, rounded to the nearest 0.10.

(iii) DAILY AUD/JPY CALL SPREAD VARIABLE PAYOUT CONTRACTS,

3:00 PM ET CLOSE - At the commencement of trading in a Daily AUD/JPY Call Spread Variable Payout 

Contract, referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Contract, which conforms to 

the Payout Criteria listed below:

(1) DAILY AUD/JPY CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 2.50. 

(bb) FLOOR – The Floor shall be X – 2.50.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(2) In each case, “X” equals the last AUD/JPY price, as reported by the Source Agency,

rounded to the nearest 0.10.
217

(iv) DAILY AUD/JPY CALL SPREAD CONTRACTS, 3:00 PM ET CLOSE -

Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 2.50.

(2) CONTRACT 2: The Ceiling shall be X + 1.25; The Floor shall be X – 1.25.

(3) CONTRACT 3: The Ceiling shall be X + 2.50; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(5) In each case, “X” equals the last AUD/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.10.

(v) Nadex may list additional Call Spread Contracts with different ranges of Payout 

Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for AUD/JPY Call Spread Contracts shall be

0.01.

(g) POSITION LIMIT – The Position Limits for AUD/JPY Call Spread Contracts shall be 250

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

AUD/JPY Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Seriesisthe same date asthe Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

AUD/JPY Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value shall be the amount paid to the holder of 

either a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable 

Payout Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of AUD/JPY Index 

Value released by the Source Agency at Expiration on the Expiration Date. The Expiration Value is 

calculated by the Source Agency by taking all Midpoints between the bid/ask spread (ten pips wide or
218

less) occurring in the ten (10) seconds leading up to the close of trading of the AUD/JPY Call Spread 

Contract, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing 

the highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data 

set69, using the remaining AUD/JPY Midpoints to calculate the Expiration Value. The calculation used is 

a simple average of the remaining AUD/JPY Midpoints, rounded to one decimal point past the precision 

of the underlying market. In the event the time it takes to collect at least ten (10) Midpoints (ten pips wide 

or less) exceeds the ten (10) second time period, the Expiration Value is calculated by the Source Agency 

by taking the last ten (10) Midpoints between the bid/ask spread (ten pips wide or less) just prior to the 

close of trading of the AUD/JPY Call Spread Contract and removing the highest three (3) Midpoints and 

the lowest three (3) Midpoints, using the remaining four (4) AUD/JPY Midpoints to calculate the 

Expiration Value. The calculation used is a simple average of all four (4) AUD/JPY Midpoints, rounded 

to one decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.44.2 CURRENCY EXCHANGE AUD/JPY “TOUCH BRACKET” VARIABLE 

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange AUD/JPY (“AUD/JPY”) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Australian Dollar/Japanese 

Yen, herein referred to as “AUD/JPY” as quoted in the Japanese Yen per Australian Dollar obtained from 

the spot AUD/JPY foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the AUD/JPY Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY AUD/JPY TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 3:00PM ET on the last Trade Day of the contract listing, or

69 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
219

when the AUD/JPY Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch 

Bracket’, that open at 6:00PM ET on the first Trade Day of the week, with overlapping ranges, which 

conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 0.600; The Floor shall be X - 0.150.

(2) CONTRACT 2: The Ceiling shall be X + 0.450; The Floor shall be X – 0.300.

(3) CONTRACT 3: The Ceiling shall be X + 0.300; The Floor shall be X – 0.450.

(4) CONTRACT 4: The Ceiling shall be X + 0.150; The Floor shall be X – 0.600.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 100.

(6) In each case, “X” equals the last AUD/JPY price, as reported by the Source Agency, 

rounded to the nearest 0.01.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 0.600 (or 0.150) and a Floor of X – 0.150 (or 0.600) where X equals 

the Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have 

the same Last Trade Day as originally established for the expired Touch Bracket and the same Dollar 

Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for AUD/JPY Touch Bracket Variable Payout 

Contracts shall be 0.01.

(g) POSITION LIMIT –The Position Limit for AUD/JPY Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

AUD/JPY Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Settlement

Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

AUD/JPY Expiration Value is released by the Source Agency.
220

(l) SETTLEMENT VALUE – The Settlement Value shall be the amount paid to the holder of either 

a Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) AUD/JPY INDEX VALUE – The Source Agency shall calculate and produce a AUD/JPY 

Index Value once each second throughout the life of the AUD/JPY Variable Payout contracts. That is, 

each second the Source Agency will calculate a AUD/JPY Index Value by taking all Midpoints between 

the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least ten (10) Midpoints are captured during the ten (10) second period, removing the 

highest thirty (30) percent of Midpoints and the lowest thirty (30) percent of Midpoints from the data set70, 

using the remaining AUD/JPY Midpoints to calculate the AUD/JPY Index Value for that second. The 

calculation used is a simple average of the remaining AUD/JPY Midpoints, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least ten (10) 

Midpoints (ten pips wide or less) exceeds the ten (10) second time period, the AUD/JPY Index Value is 

calculated by the Source Agency by taking the last ten (10) Midpoints between the bid/ask spread (ten 

pips wide or less) just prior to the Calculation Time and removing the highest three (3) Midpoints and the 

lowest three (3) Midpoints, using the remaining four (4) AUD/JPY Midpoints to calculate the AUD/JPY 

Index Value. The calculation used is a simple average of all four (4) AUD/JPY Midpoints, rounded to 

one decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the AUD/JPY Index Value released by the 

Source Agency at Expiration on the Expiration Date.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.45 CURRENCY EXCHANGE AUD/JPY BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange AUD/JPY (“AUD/JPY”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts isthe Australian dollar/Japanese 

Yen, herein referred to as “AUD/JPY” as quoted in the Japanese Yen per Australian dollar obtained from 

the spot AUD/JPY foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

70 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
221

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the AUD/JPY Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY AUD/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.50.

(3) NUMBER OF STRIKE LEVELS LISTED - Fourteen (14) strike levels will 

be listed for each Weekly AUD/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.25 or 0.75 as reported by the Source Agency. Six (6) strike 

levels will be generated above Binary Contract X at an interval of 0.50, and 

seven (7) strike levels will be generated below Binary Contract X at an 

interval of 0.50 (e.g. X – 0.50; X; X + 0.50). The Contract will have a Payout 

Criterion of greater than the strike level value.

(ii) DAILY AUD/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 7 AM, 3 PM, 11 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.10.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily AUD/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.20 as reported by the Source Agency. Ten (10) strike levels
222

will be generated above Binary Contract Y at an interval of 0.10, and ten (10) 

strike levels will be generated below Binary Contract Y at an interval of 0.10 

(e.g. Y – 0.10; Y; Y + 0.10). The Contract will have a Payout Criterion of 

greater than the strike level value.

(iii) INTRADAY AUD/JPY BINARY CONTRACTS

(1) EXPIRATION TIME – 10 AM, 11 AM, 12 PM, 1 PM, 2 PM, 3 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.05.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels 

will be listed for each Intraday AUD/JPY Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Z” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.01 as reported by the Source Agency. Four (4) strike levels 

will be generated above Binary Contract Z at an interval of 0.05, and four (4) 

strike levels will be generated below Binary Contract Z at an interval of 0.05 

(e.g. Z – 0.05; Z; Z + 0.05). The Contract will have a Payout Criterion of 

greater than the strike level value.

(iv) Nadex may list additional AUD/JPY Binary Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for AUD/JPY Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for AUD/JPY Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the

EUR/USD Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration 

Date. No trading in the AUD/JPY Binary Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date the AUD/JPY number is 

released by the Source Agency.
223

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

AUD/JPY number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money AUD/JPY Binary Contract 

is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of AUD/JPY released 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all Midpoints between the bid/ask spread (ten pips wide or less) occurring in the ten (10) seconds 

leading up to the close of trading of the AUD/JPY Binary Contract, provided at least ten (10) Midpoints 

are captured during the ten (10) second period, removing the highest thirty (30) percent of Midpoints and 

the lowest thirty (30) percent of Midpoints from the data set71, using the remaining AUD/JPY Midpoints 

to calculate the Expiration Value. The calculation used is a simple average of the remaining AUD/JPY 

Midpoints, rounded to one decimal point past the precision of the underlying market. In the event the time

it takes to collect at least ten (10) Midpoints (ten pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between

the bid/ask spread (ten pips wide or less) just prior to the close of trading of the AUD/JPY Binary Contract 

and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the remaining four 

(4) AUD/JPY Midpoints to calculate the Expiration Value. The calculation used is a simple average of all

four (4) AUD/JPY Midpoints, rounded to one decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.46 CURRENCY EXCHANGE USD/MXN BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Currency 

Exchange USD/MXN (“USD/MXN”) Binary Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the US dollar/Mexican peso 

herein referred to as “USD/MXN” as quoted in Mexican pesos per US dollar obtained from the spot 

USD/MXN foreign currency market.

(c) SOURCE AGENCY – The Source Agency is Nadex.

71 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.
224

(d) TYPE – The type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the USD/MXN Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

(i) WEEKLY USD/MXN BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.1.

(3) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will 

be listed for each Weekly USD/MXN Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “W” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in either 0.025 or 0.075 as reported by the Source Agency.

Six (6) strike levels will be generated above Binary Contract W at an interval 

of 0.1, and six (6) strike levels will be generated below Binary

Contract W at an interval of 0.1 (e.g. W – 0.1; W; W + 0.1). The

Contract will have a Payout Criterion of greater than the strike level value.

(ii) DAILY USD/MXN BINARY CONTRACTS

(1) EXPIRATION TIME – 3 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.04.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

will be listed for each Daily USD/MXN Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 0.02 as reported by the Source Agency. Ten (10) strike

levels will be generated above Binary Contract X at an interval of 0.04, and
225

ten (10) strike levels will be generated below Binary Contract X at an interval 

of 0.04 (e.g. X – 0.04; X; X + 0.04). The Contract will have a Payout 

Criterion of greater than the strike level value.

(iii) INTRADAY 2-HOUR USD/MXN BINARY CONTRACTS

(1) EXPIRATION TIME – 10 AM, 11 AM, 12 PM, PM , 2 PM, 3 PM ET 

CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 0.016.

(3) NUMBER OF STRIKE LEVELS LISTED – Fifteen (15) strike levels

will be listed for each Intraday 2-Hour USD/MXN Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “Y” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest

value ending in either 0.000, 0.002, 0.004, 0.006 or 0.008 as reported by the Source 

Agency. Seven (7) strike levels will be generated above Binary Contract Y at an 

interval of 0.016, and seven (7) strike levels will be generated below Binary Contract 

Y at an interval of 0.016 (e.g. Y – 0.016; Y; Y + 0.016). The Contract will have a 

Payout Criterion of greater than the strike level value.

(iv) Nadex may list additional USD/MXN Binary Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for USD/MXN Binary Contracts shall be 0.25.

(g) POSITION LIMIT – The Position Limits for USD/MXN Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the

USD/MXN Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same as the Expiration

Date. No trading in the USD/MXN Binary Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date on which the USD/MXN number 

as reported by the Source Agency.
226

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

USD/MXN number is scheduled to be released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in 

the money Contract on the Settlement Date. The Settlement Value of an in the money USD/MXN Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of USD/MXN 

released by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source 

Agency by taking all Midpoints between the bid/ask spread (250 pips wide or less) occurring in the ten

(10) seconds leading up to the close of trading of the USD/MXN Binary Contract, provided at least ten

(10) Midpoints are captured during the ten (10) second period, removing the highest thirty (30) percent of 

Midpoints and the lowest thirty (30) percent of Midpoints from the data set72, using the remaining 

USD/MXN Midpoints to calculate the Expiration Value. The calculation used is a simple average of the 

remaining USD/MXN Midpoints, rounded to the fourth decimal precision point. In the event the time it 

takes to collect at least ten (10) Midpoints (250 pips wide or less) exceeds the ten (10) second time period, 

the Expiration Value is calculated by the Source Agency by taking the last ten (10) Midpoints between 

the bid/ask spread (250 pips wide or less) just prior to the close of trading of the USD/MXN Binary 

Contract and removing the highest three (3) Midpoints and the lowest three (3) Midpoints, using the 

remaining four (4) USD/MXN Midpoints to calculate the Expiration Value. The calculation used is a 

simple average of all four (4) USD/MXN Midpoints, rounded to the fourth decimal precision point.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a 

delay, postponement or otherwise in such release announcement by the Source Agency, the Settlement 

Date will be delayed until the Underlying number is released for that Series.

RULES 12.47 - 12.53 [RESERVED]

RULE 12.54 JAPAN 225 VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Japan 225 

Variable Payout Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the SGX® Nikkei 

225 Index Futures contracts (“NKFC”) traded on the Singapore Exchange (SGX)73. The NKFC trade

72 If 30% of the data set would result in a non-integer number of Midpoints, the number of Midpoints to be removed from the 

set will be rounded down. For example, if the number of Midpoints collected during the last 10 seconds prior to the close of 

trading was 14, 30% of the data set would be 4.2 Midpoints. As 4.2 is a non-integer number, the value will be rounded down, 

and the 4 highest and 4 lowest Midpoints will be removed from the data set.

73 SGX® is a registered service mark of the Singapore Exchange Limited (“SGX”). Nikkei is a registered mark of Nikkei,

Inc. All rights in the Trademarks and Futures Trading Data of SGX vest in Singapore Exchange Limited (“SGX”). The Japan 

225 Variable Payout Contract is not sponsored, endorsed, sold or promoted by SGX. SGX makes no representation or 

warranty, express or implied to the investors in the Japan 225 Variable Payout Contract or any member of the public in any
227

prices that will be used to calculate the Underlying will be taken from four (4) NKFC delivery months: 

March, June, September, or December (each a “NKFC Delivery Month”). The date on which a new 

delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day 

after the End Date for the previous delivery month contract. The last day on which a delivery month will 

be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Monday of the week of the 

Underlying futures contracts Expiration Date. For example, the SGX Nikkei 225 December 2014 futures 

have an Expiration Date of December 11, 2014. The last day on which the Nikkei 225 December 2014 

futures prices will be used as the Underlying for Nadex contracts and to calculate the Expiration Value on 

the Expiration Date for the relevant Nikkei 225 contracts will be the Monday of the week of the SGX 

Nikkei 225 December 2014 futures contracts Expiration Date (i.e. December 11, 2014). Therefore, the 

End Date for using SGX Nikkei 225 December 2014 futures will be December 8, 2014 and the Start Date 

for the next delivery month, SGX Nikkei 225 March 2015 futures, will be December 9, 2014.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Japan 225 Variable Payout Contract, the 

Payout Criteria for the Contracts will be set as follows:

(i) DAILY JAPAN 225 CALL SPREAD VARIABLE PAYOUT CONTRACTS,

1:25 AM ET74 CLOSE SPREAD - At the commencement of trading in a Daily Japan 225 Call Spread 

Variable Payout Contract, referred to as a ‘Call Spread’, Nadex shall list one (1) Call Spread Contract, 

which conforms to the Payout Criteria listed below:

(1) DAILY JAPAN 225 CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 400. 

(bb) FLOOR – The Floor shall be X – 400.

manner whatsoever regarding the advisability of investing in any financial product generally or in particularly the Japan 225 

Variable Payout Contract. The relationship of SGX towards Nadex is in respect of licensing the use of the SGX Nikkei 225 

Index Futures Trading Data. SGX has no obligation to take the needs of the investors of the Japan 225 Variable Payout 

Contract into consideration in determining, composing or calculating the SGX Nikkei 225 Index Futures Trading Data. SGX 

is neither responsible for nor has participated in the structure of the Japan 225 Variable Payout Contract. SGX has no 

obligation or liability in connection with the administration, marketing or trading of the Japan 225 Variable Payout Contract. 

You are strongly advised to independently verify the accuracy, timeliness and reliability of the Japan 225 Variable Payout 

Contract and to consult with your investment advisor before investing. Nadex is not affiliated with Nikkei, Inc. and neither 

Nikkei, Inc., nor its affiliates, sponsor or endorse Nadex or its products in any way. In particular, the Nadex Japan 225 

Contracts are not sponsored, endorsed, sold or promoted by Nikkei, Inc.

74 During the period when the US observes daylight savings time, all Variable payout Japan 225 contracts will open and 

close 1 hour later than their regular defined times.
228

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

(2) In each case, “X” equals the last NKFC price, as reported by the Source Agency, rounded 

to the nearest 100.

(ii) DAILY JAPAN 225 NARROW CALL SPREAD CONTRACTS, 1:25 AM

ET75 CLOSE – At the commencement of trading in a Daily Japan 225 Narrow Call Spread Variable Payout 

Contract, Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges which conform 

to the Payout Criteria listed below:

(1) DAILY JAPAN 225 NARROW CALL SPREAD CONTRACT

(aa) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 400.

(bb) CONTRACT 2; The Ceiling shall be X + 200; The Floor shall be X – 200. 

(cc) CONTRACT 3: The Ceiling shall be X + 400; The Floor shall be X.

(dd) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

(2) In each case, “X” equals the last NKFC price, as reported by the Source Agency rounded 

to the nearest 100.

(iii) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Japan 225 Call Spread Contracts shall be 1.

(a) POSITION LIMIT – The Position Limits for Japan 225 Call Spread Contracts shall be 250 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Japan 

225 Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts per strike 

level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

75 During the period when the US observes daylight savings time, all Variable payout Japan 225 contracts will open and 

close 1 hour later than their regular defined times.
229

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Japan 225 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of Japan 225 calculated 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all NKFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the 

Japan 225 Call Spread Contract, provided at least twenty-five (25) trade prices are captured during the ten

(10)second period, removing the highest twenty (20) percent of NKFC trade prices and the lowest twenty

(20) percent of NKFC trade prices from the data set76, and using the remaining NKFC trade prices to 

calculate the Expiration Value. The calculation used is a simple average of the remaining NKFC trade 

prices in the data set, rounded to one decimal point past the precision of the underlying market. In the 

event the time it takes to collect at least twenty-five (25) NKFC trade prices exceeds the ten (10) seconds 

just prior to the close of trading of the Japan 225 Call Spread Contract, the Expiration Value is calculated 

by the Source Agency by taking the last twenty-five (25) NKFC trade prices just prior to the close of 

trading of the Japan 225 Call Spread Contract removing the highest five (5) NKFC trade prices and the 

lowest five (5) NKFC trade prices, and using the remaining fifteen (15) NKFC trade prices to calculate 

the Expiration Value. The calculation used is a simple average of all fifteen (15) NKFC trade prices, 

rounded to one decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.55 JAPAN 225 BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Japan 225 Binary 

Contracts issued by Nadex.

76 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
230

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the SGX® Nikkei 

225 Futures contracts (“NKFC”) traded on the Singapore Exchange (SGX)77. The NKFC trade prices that 

will be used to calculate the Underlying will be taken from four (4) NKFC delivery months: March, June, 

September, or December (each a “NKFC Delivery Month”). The date on which a new delivery month 

will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day after the End 

Date for the previous delivery month contract. The last day on which a delivery month will be used as 

the Underlying for Nadex contracts (i.e. “End Date”) is the Monday of the week of the Underlying futures 

contracts Expiration Date. For example, the SGX Nikkei 225 December 2014 futures have an Expiration 

Date of December 11, 2014. The last day on which the Nikkei 225 December 2014 futures prices will be 

used as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date 

for the relevant Nikkei 225 contracts will be the Monday of the week of the SGX Nikkei 225 December 

2014 futures contracts Expiration Date (i.e. December 11, 2014). Therefore, the End Date for using SGX 

Nikkei 225 December 2014 futures will be December 8, 2014 and the Start Date for the next delivery 

month, SGX Nikkei 225 March 2015 futures, will be December 9, 201478.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the Japan 225 Binary Contract, the Payout Criteria for 

the Contracts will be set as follows:

77 SGX® is a registered service mark of the Singapore Exchange Limited (“SGX”). Nikkei is a registered mark of Nikkei,

Inc. All rights in the Trademarks and Futures Trading Data of SGX vest in Singapore Exchange Limited (“SGX”). The Japan 

225 Binary Contract is not sponsored, endorsed, sold or promoted by SGX. SGX makes no representation or warranty, 

express or implied to the investors in the Japan 225 Binary Contract or any member of the public in any manner whatsoever 

regarding the advisability of investing in any financial product generally or in particularly the Japan 225 Binary Contract.

The relationship of SGX towards Nadex is in respect of licensing the use of the SGX Nikkei 225 Index Futures Trading Data. 

SGX has no obligation to take the needs of the investors of the Japan 225 Binary Contract into consideration in determining, 

composing or calculating the SGX Nikkei 225 Index Futures Trading Data. SGX is neither responsible for nor has 

participated in the structure of the Japan 225 Binary Contract. SGX has no obligation or liability in connection with the 

administration, marketing or trading of the Japan 225 Binary Contract. You are strongly advised to independently verify the 

accuracy, timeliness and reliability of the Japan 225 Binary Contract and to consult with your investment advisor before 

investing. Nadex is not affiliated with Nikkei, Inc. and neither Nikkei, Inc., nor its affiliates, sponsor or endorse Nadex or its 

products in any way. In particular, the Nadex Japan 225 Contracts are not sponsored, endorsed, sold or promoted by Nikkei, 

Inc.

78 Weekly contracts listed on a Monday during a week containing an Underlying futures rollover date will be listed using the 

Underlying futures month scheduled to be used to determine the settlement value on the day the contract expires. For 

example, the End Date for the SGX Nikkei 225 December 2014 Underlying futures is December 11, 2014. December 11, 

2014 is a Thursday, however, and any Nadex weekly contracts listed during this week and expiring on Friday, December 12, 

2014, will be listed using the SGX Nikkei March 2015 futures as its Underlying, as March is the futures month scheduled to 

be used to determine the Settlement Value of the Nadex weekly contract on its expiration date. Therefore, the Start Date for 

the SGX Nikkei March 2015 futures will be Monday, December 8, 2014 for any Nadex weekly contracts listed on this date.
231

(i) WEEKLY JAPAN 225 BINARY CONTRACTS

(1) EXPIRATION TIME – 1:25 AM ET CLOSE79

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 200.

(3) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will 

be listed for each Weekly Japan 225 Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “W” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 25 or 75 as reported by the Source Agency. Six (6) strike 

levels will be generated above Binary Contract W at an interval of 200, and 

six (6) strike levels will be generated below Binary Contract W at an interval 

of 200 (e.g. W – 200; W; W + 200). The Contract will have a Payout Criterion 

of greater than the strike level value.

(ii) DAILY JAPAN 225 BINARY CONTRACTS

(1) EXPIRATION TIME – 1:25 AM ET CLOSE80

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 80.

(3) NUMBER OF STRIKE LEVELS LISTED – Fifteen (15) strike levels 

will be listed for each Daily Japan 225 Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Binary Contract “X” is valued ‘at-the-money’ in relation to the Underlying 

market as determined by the Source Agency, immediately before the issuance 

of these Contracts, and shall be measured in U.S. cents rounded to the nearest 

value ending in 10 as reported by the Source Agency. Seven (7) strike levels 

will be generated above Binary Contract X at an interval of 80, and seven (7) 

strike levels will be generated below Binary Contract X at an interval of 80

79 During the period when the US observes daylight savings time, Weekly Japan 225 Binary Contracts will open and close 1 

hour later than their regular defined times.

80 During the period when the US observes daylight savings time, Daily Japan 225 Binary Contracts will open and close 1 

hour later than their regular defined times.
232

(e.g. X – 80; X; X + 80). The Contract will have a Payout Criterion of greater 

than the strike level value.

(iii) Nadex may list additional Japan 225 Binary Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the Japan 225 Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for the Japan 225 Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Japan 

225 Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration

Date. 

Date.

(j) SETTLEMENT DATE – The Settlement Date in a Series is the same date as the Expiration

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the

Japan 225 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the inthe-money Contract on the Settlement Date. The Settlement Value of an in-the-money Japan 225 Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of Japan 225 calculated 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all NKFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the 

Japan 225 Binary Contract, provided at least twenty-five (25) trade prices are captured during the ten (10) 

second period, removing the highest twenty (20) percent of NKFC trade prices and the lowest twenty (20) 

percent of NKFC trade prices from the data set81, and using the remaining NKFC trade prices to calculate 

the Expiration Value. The calculation used is a simple average of the remaining NKFC trade prices in the 

data set, rounded to one decimal point past the precision of the underlying market. In the event the time 

it takes to collect at least twenty-five (25) NKFC trade prices exceeds the ten (10) seconds just prior to the 

close of trading of the Japan 225 Binary Contract, the Expiration Value is calculated by the Source Agency

by taking the last twenty-five (25) NKFC trade prices just prior to the close of trading of the Japan

81 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
233

225 Binary Contract removing the highest five (5) NKFC trade prices and the lowest five (5) NKFC trade 

prices, and using the remaining fifteen (15) NKFC trade prices to calculate the Expiration Value. The 

calculation used is a simple average of all fifteen (15) NKFC trade prices, rounded to one decimal point 

past the precision of the underlying market.

(n) CONTINGENCIES – If no daily settlement price of the relevant NKFC is announced by the 

Source Agency, the Settlement Date will be delayed until such daily settlement price for that Series is 

released and publicly available.

RULES 12.56 – 12.57 [RESERVED]

RULE 12.58 US 500 VARIABLE PAYOUT CONTRACTS

RULE 12.58.1 US 500 “CALL SPREAD” VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the US 500 Call 

Spread Variable Payout Contracts, referred to as a ‘Call Spread’, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini S&P 

500® Futures contracts (“SPFC”) traded on the Chicago Mercantile Exchange® (CME®)82. The SPFC 

trade prices that will be used for the Underlying will be taken from four (4) SPFC delivery months: March, 

June, September, or December (each a “SPFC Delivery Month”). The date on which a new delivery month

will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day after the End

Date for the previous delivery month contract. The last day on which a delivery month will be used asthe

Underlying for Nadex contracts(i.e. “End Date”)isthe Friday of the week preceding the Underlying futures 

contracts Expiration Date. For example, the CME e-mini S&P 500 March 2012 futures have an Expiration

Date of March 16, 2012. The last day on which the e-mini S&P 500 March 2012 futures prices will be used

as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date for the 

relevant e-mini S&P 500 contracts will be the Friday of the preceding week. Therefore, the End Date for 

using CME e-mini S&P 500 March 2012 futures will be March 9, 2012 and the Start Date for the next 

delivery month, CME e-mini S&P 500 June 2012 futures, will be March 10, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

82 CME® is a registered mark of the Chicago Mercantile Exchange. S&P 500 is a registered mark of the McGraw-Hill 

Companies, Inc. Nadex is not affiliated with the Chicago Mercantile Exchange or the McGraw-Hill Companies and neither 

the Chicago Mercantile Exchange, the McGraw-Hill Companies, nor its affiliates, sponsor or endorse Nadex or its products 

in any way. In particular, the Nadex US 500 Contracts are not sponsored, endorsed, sold or promoted by CME or the 

McGraw-Hill Companies.
234

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the US 500 Call Spreads, the Payout Criteria 

for the Contracts will be set as follows:

(i) DAILY US 500 CALL SPREAD VARIABLE PAYOUT CONTRACTS,

4:15 PM ET CLOSE - At the commencement of trading in a Daily US 500 Call Spread, Nadex shall list 

one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) DAILY US 500 CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 40. 

(bb) FLOOR – The Floor shall be X – 40.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(1) In each case, “X” equals the last SPFC price, as reported by the Source Agency, rounded 

to the nearest 10.

(ii) DAILY US 500 CALL SPREAD CONTRACTS, 4:15 PM ET CLOSE -

Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 40.

(2) CONTRACT 2: The Ceiling shall be X + 20; The Floor shall be X – 20.

(3) CONTRACT 3: The Ceiling shall be X + 40; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(5) In each case, “X” equals the last SPFC price, as reported by the Source Agency, 

rounded to the nearest 10.

(iii) INTRADAY US 500 CALL SPREAD CONTRACTS, 8AM ET to 4:15

PM ET CLOSE - Nadex shall list a set of five (5) Call Spread Contracts with overlapping ranges, which 

conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X – 15; The Floor shall be X – 45.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 30.

(3) CONTRACT 3: The Ceiling shall be X + 15; The Floor shall be X – 15.
235

(4) CONTRACT 4: The Ceiling shall be X + 30; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 45; The Floor shall be X + 15.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(7) In each case, “X” equals the last SPFC price, as reported by the Source Agency, 

rounded to the nearest 5.

(iv) INTRADAY 2-HOUR US 500 CALL SPREAD CONTRACTS,

10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, 3:00PM, 4:00PM ET CLOSE - Nadex shall list a set

of five (5) Call Spread Contracts that open 2 hours prior to the stated closing time(s) above with 

overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X - 5; The Floor shall be X - 15.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 10.

(3) CONTRACT 3: The Ceiling shall be X + 5; The Floor shall be X – 5.

(4) CONTRACT 4: The Ceiling shall be X + 10; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 15; The Floor shall be X + 5.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(7) In each case, “X” equals the last SPFC price, as reported by the Source Agency, 

rounded to the nearest 5.

(v) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for US 500 Call Spread Variable Payout Contracts 

shall be 0.1.

(g) POSITION LIMIT – The Position Limits for US 500 Call Spread Variable Payout Contracts 

shall be 250 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the US 500 

Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts per strike 

level.
236

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

US 500 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE - The Expiration Value is the US 500 Index Value as calculated by 

the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency by 

taking all SPFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the US 

500 Call Spread Contract, provided at least twenty-five (25) trade prices are captured during the ten (10) 

second period, removing the highest twenty (20) percent of SPFC trade prices and the lowest twenty (20) 

percent of SPFC trade prices from the data set83, and using the remaining SPFC trade prices to calculate 

the Expiration Value. The calculation used is a simple average of the remaining SPFC trade prices in the 

data set, rounded to one decimal point past the precision of the underlying market. In the event the time 

it takes to collect at least twenty-five (25) SPFC trade prices exceeds the ten (10) seconds just prior to the 

close of trading of the US 500 Call Spread Contract, the Expiration Value is calculated by the Source 

Agency by taking the last twenty-five (25) SPFC trade prices just prior to the close of trading of the US 

500 Call Spread Contract removing the highest five (5) SPFC trade prices and the lowest five (5) SPFC 

trade prices, and using the remaining fifteen (15) SPFC trade prices to calculate the Expiration Value. The 

calculation used is a simple average of all fifteen (15) SPFC trade prices, rounded to one decimal point 

past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.58.2 US 500 “TOUCH BRACKET” VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the US 500 Touch 

Bracket Variable Payout Contracts, referred to as a ‘Touch Bracket’, issued by Nadex.

83 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
237

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini S&P 

500® Futures contracts (“SPFC”) traded on the Chicago Mercantile Exchange® (CME®)84. The SPFC 

trade prices that will be used for the Underlying will be taken from four (4) SPFC delivery months: March, 

June, September, or December (each a “SPFC Delivery Month”). The date on which a new delivery month

will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day after the End

Date for the previous delivery month contract. The last day on which a delivery month will be used asthe

Underlying for Nadex contracts(i.e. “End Date”)isthe Friday of the week preceding the Underlying futures 

contracts Expiration Date. For example, the CME e-mini S&P 500 March 2012 futures have an Expiration

Date of March 16, 2012. The last day on which the e-mini S&P 500 March 2012 futures prices will be used

as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date for the 

relevant e-mini S&P 500 contracts will be the Friday of the preceding week. Therefore, the End Date for 

using CME e-mini S&P 500 March 2012 futures will be March 9, 2012 and the Start Date for the next 

delivery month, CME e-mini S&P 500 June 2012 futures, will be March 10, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the US 500 Touch Bracket Contracts, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY US 500 TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 4:15PM ET on the last Trade Day of the contract listing, or 

when the US 500 Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch Bracket’, 

that open at 3:00AM ET on the first Trade Day of the week, with overlapping ranges, which conform to 

the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 40; The Floor shall be X - 10.

(2) CONTRACT 2: The Ceiling shall be X + 30; The Floor shall be X – 20.

(3) CONTRACT 3: The Ceiling shall be X + 20; The Floor shall be X - 30.

(4) CONTRACT 4: The Ceiling shall be X + 10; The Floor shall be X - 40.

84 CME® is a registered mark of the Chicago Mercantile Exchange. S&P 500 is a registered mark of the McGraw-Hill 

Companies, Inc. Nadex is not affiliated with the Chicago Mercantile Exchange or the McGraw-Hill Companies and neither 

the Chicago Mercantile Exchange, the McGraw-Hill Companies, nor its affiliates, sponsor or endorse Nadex or its products 

in any way. In particular, the Nadex US 500 Contracts are not sponsored, endorsed, sold or promoted by CME or the 

McGraw-Hill Companies.
238

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(6) In each case, “X” equals the last US 500 price, as reported by the Source 

Agency, rounded to the nearest 1.

(ii) Upon the early Expiration of a , Nadex may list a new with a Ceiling of 

X + 40 (or 10) and a Floor of X – 10 (or 40) where X equals the Ceiling (or Floor) of the that expired 

early. The newly listed will have the same Last Trade Day as originally established for the expired Touch 

Bracket and the same Dollar Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for US 500 Touch Bracket Variable Payout 

Contracts shall be 0.1.

(g) POSITION LIMIT – The Position Limit for US 500 Touch Bracket Variable Payout Contracts 

shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the US 500 

Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 Contracts per 

strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

US 500 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) US 500 INDEX VALUE – The Source Agency shall calculate and produce a US 500 Index 

Value once each second throughout the life of the US 500 Variable Payout contracts. That is, each second 

the Source Agency will calculate a US 500 Index Value by taking by taking all SPFC trade prices 

occurring in the ten (10) seconds leading up to the Calculation Time, provided at least twenty-five (25) 

trade prices are captured during the ten (10) second period, removing the highest twenty (20) percent of 

SPFC trade prices and the lowest twenty (20) percent of SPFC trade prices from the data set85, and using

85 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the
239

the remaining SPFC trade prices to calculate the US 500 Index Value for that second. The calculation 

used is a simple average of the remaining SPFC trade prices in the data set, rounded to one decimal point 

past the precision of the underlying market. In the event the time it takes to collect at least twenty-five

(25) SPFC trade prices exceeds the ten (10) second period, the US 500 Index Value will be calculated by 

the Source Agency by taking the last twenty-five (25) SPFC trade prices just prior to the Calculation Time, 

removing the highest five (5) SPFC trade prices and the lowest five (5) SPFC trade prices, and using the 

remaining fifteen (15) SPFC trade prices to calculate the US 500 Index Value. The calculation used is a 

simple average of all fifteen (15) SPFC trade prices, rounded to one decimal point past the precision of 

the underlying market.

(n) EXPIRATION VALUE - The Expiration Value is the US 500 Index Value released by the 

Source Agency at Expiration on the Expiration Date.

(a) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.59 US 500 BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the US 500 Binary 

Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Binary Contracts is the price of the E-mini 

S&P 500® Futures contracts (“SPFC”) traded on the Chicago Mercantile Exchange® (CME®)86. The 

SPFC trade prices that will be used to calculate the Underlying will be taken from four (4) SPFC delivery 

months: March, June, September, or December (each a “SPFC Delivery Month”). The date on which a 

new delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar 

day after the End Date for the previous delivery month contract. The last day on which a delivery month 

will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday of the week preceding 

the Underlying futures contracts Expiration Date. For example, the CME e-mini S&P 500 March 2012 

futures have an Expiration Date of March 16, 2012. The last day on which the e-mini S&P 500 March 

2012 futures prices will be used as the Underlying for Nadex contracts and to calculate the Expiration 

Value on the Expiration Date for the relevant e-mini S&P 500 contracts will be the Friday of the preceding 

week. Therefore, the End Date for using CME e-mini S&P 500 March 2012 futures will be March 9, 2012

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.

86 CME® is a registered mark of the Chicago Mercantile Exchange. S&P 500 is a registered mark of the McGraw-Hill 

Companies, Inc. Nadex is not affiliated with the Chicago Mercantile Exchange or the McGraw-Hill Companies and neither 

the Chicago Mercantile Exchange, the McGraw-Hill Companies, nor its affiliates, sponsor or endorse Nadex or its products 

in any way. In particular, the Nadex US 500 Contracts are not sponsored, endorsed, sold or promoted by CME or the 

McGraw-Hill Companies.
240

and the Start Date for the next delivery month, CME e-mini S&P 500 June 2012 futures, will be March 

10, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the US 500Binary Contract, the Payout Criteria for the 

Contracts will be set as follows:

(i) WEEKLY US 500 BINARY CONTRACTS

(1) EXPIRATION TIME – 4:15PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall 

be 24.

(3) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will be 

listed for the Weekly US 500 Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “W” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these 

Contracts, and shall be measured in U.S. cents rounded to the nearest value ending 

in .50. Six (6)strike levels will be generated above Binary Contract W at an interval 

of 24, and six (6) strike levels will be generated below Binary Contract W at an 

interval of 24 (e.g. W – 24; W; W + 24). The Contract will have a Payout Criterion 

of greater than the strike level value.

(iii) DAILY US 500 BINARY CONTRACTS

(1) EXPIRATION TIME – 4:15PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 6.

(3) NUMBER OF STRIKE LEVELS LISTED - Twenty-one (21) strike levels will be listed 

for the Daily US 500 Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “X” is valued ‘at-the-money’ in relation to the Underlying market as determined by 

the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest one (1). Ten (10) strike levels will be generated

above Binary Contract X at an interval of 6, and ten (10) strike levels will be
241

generated below Binary Contract X at an interval of 6 (e.g. X – 6; X; X + 6). The Contract 

will have a Payout Criterion of greater than the strike level value.

(iii) INTRADAY US 500 2-HOUR BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, 3:00PM,

4:00PM, 5:00PM ET CLOSE (5:00PM only Monday – Thursday)

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 3.

(3) NUMBER OF STRIKE LEVELS LISTED - Fifteen (15) strike levels will be listed for 

each Intraday US 500 2-Hour Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Y” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in .10. Seven (7) strike levels 

will be generated above Binary Contract Y at an interval of 3, and seven (7) strike levels 

will be generated below Binary Contract Y at an interval of 3 (e.g. Y – 3; Y; Y + 3). The 

Contract will have a Payout Criterion of greater than the strike level value.

(iv) INTRADAY US 500 20-MINUTE BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 10:20AM, 10:40AM, 11:00AM, 11:20AM, 2:40PM, 

3:00PM, 3:20PM, 3:40PM 4:00PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

1.5.

(3) NUMBER OF STRIKE LEVELS LISTED – Fifteen (15) strike levels will be listed for 

each Intraday US 500 20-Minute Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in .05. Seven (7) strike levels 

will be generated above Binary Contract Z at an interval of 1.5, and seven (7) strike levels 

will be generated below Binary Contract Z at an interval of 1.5 (e.g. Z – 1.5; Z; Z + 1.5). 

The Contract will have a Payout Criterion of greater than the strike level value.

(v) INTRADAY US 500 20-MINUTE BINARY CONTRACTS
242

(1) EXPIRATION TIME – 11:40AM, 12:00PM, 12:20PM, 12:40PM, 1:00PM, 1:20PM, 

1:40PM, 2:00PM, 2:20PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 1.

(3) NUMBER OF STRIKE LEVELS LISTED - Fifteen (15) strike levels will be listed for 

each Intraday US 500 20-Minute Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in .05. Seven (7) strike levels 

will be generated above Binary Contract Z at an interval of 1, and seven (7) strike levels 

will be generated below Binary Contract Z at an interval of 1 (e.g. Z – 1; Z; Z + 1). The 

Contract will have a Payout Criterion of greater than the strike level value.

(vi) Nadex may list additional US 500 Binary Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the US 500 Binary Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for the US 500 Binary Contracts shall be 2,500 

Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the US 500 

Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i)LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration

Date. 

Date.

(j) SETTLEMENT DATE – The Settlement Date in a Series is the same date as the Expiration

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 500

Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the inthe-money Contract on the Settlement Date. The Settlement Value of an in-the-money US 500 Binary 

Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the price or value of US 500 as calculated 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all SPFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the
243

US 500 Binary Contract, provided at least twenty-five (25) trade prices are captured during the ten (10) 

second period, removing the highest twenty (20) percent of SPFC trade prices and the lowest twenty (20) 

percent of SPFC trade prices from the data set87, and using the remaining SPFC trade prices to calculate 

the Expiration Value. The calculation used is a simple average of the remaining SPFC trade prices in the 

data set, rounded to one decimal point past the precision of the underlying market. In the event the time 

it takes to collect at least twenty-five (25) SPFC trade prices exceeds the ten (10) seconds just prior to the 

close of trading of the US 500 Binary Contract, the Expiration Value is calculated by the Source Agency 

by taking the last twenty-five (25) SPFC trade prices just prior to the close of trading of the US 500 Binary 

Contract removing the highest five (5) SPFC trade prices and the lowest five (5) SPFC trade prices, and 

using the remaining fifteen (15) SPFC trade prices to calculate the Expiration Value. The calculation used 

is a simple average of all fifteen (15) SPFC trade prices, rounded to one decimal point past the precision 

of the underlying market.

(n) CONTINGENCIES – If no daily settlement price of the relevant SPFC is announced by the 

Source Agency, the Settlement Date will be delayed until such daily settlement price for that Series is 

released and publicly available.

RULE 12.60 US SMALLCAP 2000 VARIABLE PAYOUT CONTRACTS

RULE 12.60.1 US SMALLCAP 2000 “CALL SPREAD” VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the US SmallCap 

2000 Call Spread Variable Payout Contracts, referred to as a ‘Call Spread’, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini Russell 

2000®88 Index Futures contracts (“RUFC”) traded on the Chicago Mercantile Exchange (CME®)

89

. The 

RUFC trade prices that will be used for the Underlying will be taken from four (4) RUFC delivery months: 

March, June, September, or December (each a “RUFC Delivery Month”). The date on which a new 

delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day 

after the End Date for the previous delivery month contract. The last day on which a delivery month will 

be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday of the week preceding the 

Underlying futures contracts Expiration Date. For example, the CME E-mini Russell 2000 Index 

September 2017 Futures has an Expiration Date of September 15, 2017. The last day on which the CME 

E-mini Russell 2000 Index September 2017 Futures prices will be used as the Underlying for Nadex 

contracts and to calculate the Expiration Value on the Expiration Date for the relevant CME E-mini

87 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.

88 Russell 2000® is a registered mark of Frank Russell Company.

89 CME® is a registered mark of the Chicago Mercantile Exchange. Nadex is not affiliated with the Chicago Mercantile Exchange

(“CME”), nor its affiliates, and CME does not sponsor or endorse Nadex or its products in any way. In particular, the Nadex US SmallCap 

2000 Contracts are not sponsored, endorsed, sold or promoted by CME.
244

Russell 2000 Index Futures contracts will be the Friday of the preceding week. Therefore, the End Date 

for using CME E-mini Russell 2000 Index September 2017 Futures will be September 8, 2017 and the 

Start Date for the next delivery month, CME E-mini Russell 2000 Index December 2017 Futures, will be 

September 9, 2017.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the US SmallCap 2000 Call Spread Contract, 

the Payout Criteria for the Contracts will be set as follows:

(i) DAILY US SMALLCAP 2000 CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 4:15 PM ET CLOSE - At the commencement of trading in a Daily US SmallCap 2000 

Call Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed 

below:

(1) DAILY US SMALLCAP 2000 CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 30. 

(bb) FLOOR – The Floor shall be X – 30.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(2) In each case, “X” equals the last RUFC price, as reported by the Source Agency, rounded 

to the nearest 5.

(ii) DAILY US SMALLCAP 2000 CALL SPREAD CONTRACTS, 4:15

PM ET CLOSE - Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which 

conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 30.

(2) CONTRACT 2: The Ceiling shall be X + 15; The Floor shall be X – 15.

(3) CONTRACT 3: The Ceiling shall be X + 30; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(5) In each case, “X” equalsthe last RUFC price, asreported by the Source Agency, 

rounded to the nearest 5.
245

(iii) INTRADAY US SMALLCAP 2000 CALL SPREAD CONTRACTS,

8AM ET to 4:15 PM ET CLOSE - Nadex shall list a set of five (5) Call Spread Contracts with overlapping 

ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X - 10; The Floor shall be X – 30.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 20.

(3) CONTRACT 3: The Ceiling shall be X + 10; The Floor shall be X – 10.

(4) CONTRACT 4: The Ceiling shall be X + 20; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 30; The Floor shall be X + 10.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(7) In each case, “X” equalsthe last RUFC price, asreported by the Source Agency, 

rounded to the nearest 5.

(iv) INTRADAY 2-HOUR US SMALLCAP 2000 CALL SPREAD

CONTRACTS, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, 3:00PM, 4:00PM ET CLOSE - Nadex

shall list a set of five (5) Call Spread Contracts that open 2 hours prior to the stated closing time(s) above 

with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X – 3.5; The Floor shall be X – 10.5.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 7.

(3) CONTRACT 3: The Ceiling shall be X + 3.5; The Floor shall be X – 3.5.

(4) CONTRACT 4: The Ceiling shall be X + 7; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 10.5; The Floor shall be X + 3.5.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(7) In each case, “X” equalsthe last RUFC price, asreported by the Source Agency, 

rounded to the nearest 1.

(v) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for US SmallCap 2000 Call Spread Variable

Payout Contracts shall be 0.1.
246

(g) POSITION LIMIT – The Position Limits for US SmallCap 2000 Call Spread Variable Payout 

Contracts shall be 250 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the US 

SmallCap 2000 Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

US SmallCap 2000 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the US SmallCap 2000 Index Value as 

calculated by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source 

Agency by taking all RUFC trade prices occurring in the ten (10) seconds leading up to the close of trading 

of the US SmallCap 2000 Call Spread Contract, provided at least twenty-five (25) trade prices are captured 

during the ten (10) second period, removing the highest twenty (20) percent of RUFC trade prices and the 

lowest twenty (20) percent of RUFC trade prices from the data set90, and using the remaining RUFC trade 

prices to calculate the Expiration Value. The calculation used is a simple average of the remaining RUFC 

trade prices in the data set, rounded to one decimal point past the precision of the underlying market. In 

the event the time it takes to collect at least twenty-five (25) RUFC trade prices exceeds the ten (10) 

seconds just prior to the close of trading of the US SmallCap 2000 Call Spread Contract, the Expiration 

Value is calculated by the Source Agency by taking the last twenty-five (25) RUFC trade prices just prior 

to the close of trading of the US SmallCap 2000 Call Spread Contract removing the highest five (5) RUFC 

trade prices and the lowest five (5) RUFC trade prices, and using the remaining fifteen (15) RUFC trade 

prices to calculate the Expiration Value. The calculation used is a simple average of all fifteen (15) RUFC 

trade prices, rounded to one decimal point past the precision of the underlying market.

90 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
247

(n) CONTINGENCIES – If no daily settlement price of the relevant RUFC is announced by the 

Source Agency, the Settlement Date will be delayed until such daily settlement price for that Series is 

released and publicly available.

RULE 12.60.2 US SMALLCAP 2000 “TOUCH BRACKET” VARIABLE PAYOUT 

CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the US SmallCap 

2000 Touch Bracket Variable Payout Contracts, referred to as a ‘Touch Bracket’, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini Russell 

2000®91 Index Futures contracts (“RUFC”) traded on the Chicago Mercantile Exchange (CME®)

92

. The 

RUFC trade prices that will be used for the Underlying will be taken from four (4) RUFC delivery months: 

March, June, September, or December (each a “RUFC Delivery Month”). The date on which a new 

delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day 

after the End Date for the previous delivery month contract. The last day on which a delivery month will 

be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday of the week preceding the 

Underlying futures contracts Expiration Date. For example, the CME E-mini Russell 2000 Index 

September 2017 Futures has an Expiration Date of September 15, 2017. The last day on which the CME 

E-mini Russell 2000 Index September 2017 Futures prices will be used as the Underlying for Nadex 

contracts and to calculate the Expiration Value on the Expiration Date for the relevant CME E-mini 

Russell 2000 Index Futures contracts will be the Friday of the preceding week. Therefore, the End Date 

for using CME E-mini Russell 2000 Index September 2017 Futures will be September 8, 2017 and the 

Start Date for the next delivery month, CME E-mini Russell 2000 Index December 2017 Futures, will be 

September 9, 2017.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the US SmallCap 2000 Touch Bracket 

Contracts, the Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY US SMALLCAP 2000 TOUCH BRACKET VARIABLE

PAYOUT CONTRACTS, Close Time is the earlier of 4:15PM ET on the last Trade Day of the contract 

listing, or when the US SmallCap 2000 Index Value is equal to or greater than the Ceiling, or equal to or 

less than the Floor. Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred

91 Russell 2000® is a registered mark of Frank Russell Company.

92 CME® is a registered mark of the Chicago Mercantile Exchange. Nadex is not affiliated with the Chicago Mercantile Exchange

(“CME”), nor its affiliates, and CME does not sponsor or endorse Nadex or its products in any way. In particular, the Nadex US SmallCap 

2000 Contracts are not sponsored, endorsed, sold or promoted by CME.
248

to as a ‘Touch Bracket’, that open at 3:00AM ET on the first Trade Day of the week, with overlapping

ranges, which conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 40; The Floor shall be X- 10.

(2) CONTRACT 2: The Ceiling shall be X + 30; The Floor shall be X – 20.

(3) CONTRACT 3: The Ceiling shall be X + 20; The Floor shall be X - 30.

(4) CONTRACT 4: The Ceiling shall be X + 10; The Floor shall be X - 40.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 10.

(6) In each case, “X” equals the last US SmallCap 2000 price, as reported by the 

Source Agency, rounded to the nearest 1.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 40 (or 10) and a Floor of X – 10 (or 40) where X equals the Ceiling 

(or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have the same 

Last Trade Day as originally established for the expired Touch Bracket and the same Dollar Multiplier as 

the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for US SmallCap 2000 Touch Bracket Variable 

Payout Contracts shall be 0.1.

(g) POSITION LIMIT – The Position Limit for US SmallCap 2000 Touch Bracket Variable 

Payout Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the US 

SmallCap 2000 Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

US SmallCap 2000 Expiration Value is released by the Source Agency.
249

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) US SMALLCAP 2000 INDEX VALUE – The Source Agency shall calculate and produce a 

US SmallCap 2000 Index Value once each second throughout the life of the US SmallCap 2000 Variable 

Payout contracts. That is, each second the Source Agency will calculate a US SmallCap 2000 Index Value 

by taking by taking all RUFC trade prices occurring in the ten (10) seconds leading up to the Calculation 

Time, provided at least twenty-five (25) trade prices are captured during the ten (10) second period, 

removing the highest twenty (20) percent of RUFC trade prices and the lowest twenty (20) percent of 

RUFC trade prices from the data set93, and using the remaining RUFC trade prices to calculate the US 

SmallCap 2000 Index Value for that second. The calculation used is a simple average of the remaining 

RUFC trade prices in the data set, rounded to one decimal point past the precision of the underlying market.

In the event the time it takes to collect at least twenty-five (25) RUFC trade prices exceeds the ten (10) 

second period, the US SmallCap 2000 Index Value will be calculated by the Source Agency by taking the

last twenty-five (25) RUFC trade prices just prior to the Calculation Time, removing the highest five (5)

RUFC trade prices and the lowest five (5) RUFC trade prices, and using the remaining fifteen (15) RUFC 

trade prices to calculate the US SmallCap 2000 Index Value. The calculation used is a simple average of 

all fifteen (15) RUFC trade prices, rounded to one decimal point past the precision of the underlying 

market.

(n) EXPIRATION VALUE – The Expiration Value is the US SmallCap 2000 Index Value as 

released by the Source Agency at Expiration

(o) CONTINGENCIES – If no daily settlement price of the relevant RUFC is announced by the 

Source Agency, the Settlement Date will be delayed until such daily settlement price for that Series is 

released and publicly available.

RULE 12.61 US SMALLCAP 2000 BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the US SmallCap 

2000 Binary Contracts issued by Nadex.

93 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
250

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini Russell 

2000®94 Index Futures contracts (“RUFC”) traded on the Chicago Mercantile Exchange (CME®)

95

. The 

RUFC trade prices that will be used for the Underlying will be taken from four (4) RUFC delivery months: 

March, June, September, or December (each a “RUFC Delivery Month”). The date on which a new 

delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day 

after the End Date for the previous delivery month contract. The last day on which a delivery month will 

be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday of the week preceding the 

Underlying futures contracts Expiration Date. For example, the CME E-mini Russell 2000 Index 

September 2017 Futures has an Expiration Date of September 15, 2017. The last day on which the CME 

E-mini Russell 2000 Index September 2017 Futures prices will be used as the Underlying for Nadex 

contracts and to calculate the Expiration Value on the Expiration Date for the relevant CME E-mini 

Russell 2000 Index Futures contracts will be the Friday of the preceding week. Therefore, the End Date 

for using CME E-mini Russell 2000 Index September 2017 Futures will be September 8, 2017 and the 

Start Date for the next delivery month, CME E-mini Russell 2000 Index December 2017 Futures, will be 

September 9, 2017.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the US SmallCap 2000 Binary Contract, the Payout 

Criteria for the Contracts will be set as follows:

(i) WEEKLY US SMALLCAP 2000 BINARY CONTRACTS

(1) EXPIRATION TIME – 4:15PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

24.

(3) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will be listed 

for the Weekly US SmallCap 2000 Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “W” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest one (1). Six (6)strike levels

94 Russell 2000® is a registered mark of Frank Russell Company.

95 CME® is a registered mark of the Chicago Mercantile Exchange. Nadex is not affiliated with the Chicago Mercantile Exchange

(“CME”), nor its affiliates, and CME does not sponsor or endorse Nadex or its products in any way. In particular, the Nadex US SmallCap 

2000 Contracts are not sponsored, endorsed, sold or promoted by CME.
251

will be generated above Binary Contract W at an interval of 24, and six (6) strike levels 

will be generated below Binary Contract W at an interval of 24 (e.g. W – 24; W; W + 

24). The Contract will have a Payout Criterion of greater than the strike level value.

(ii) DAILY US SMALLCAP 2000 BINARY CONTRACTS

(1) EXPIRATION TIME – 4:15PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

4.

(3) NUMBER OF STRIKE LEVELS LISTED - Twenty-one (21) strike levels will be 

listed for the Daily US SmallCap 2000 Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “X” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest one (1). Ten (10) strike 

levels will be generated above Binary Contract X at an interval of 4, and ten (10) strike 

levels will be generated below Binary Contract X at an interval of 4 (e.g. X – 4; X; X

+ 4). The Contract will have a Payout Criterion of greater than the strike level value.

(iii) INTRADAY US SMALLCAP 2000 2-HOUR BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, 3:00PM,

4:00PM, 5:00PM ET CLOSE (5:00PM only Monday – Thursday)

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

2.8.

(3) NUMBER OF STRIKE LEVELS LISTED - Fifteen (15) strike levels will be listed for 

each Intraday US SmallCap 2000 2-Hour Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Y” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in .10. Seven

(7) strike levels will be generated above Binary Contract Y at an interval of 2.8, and 

seven (7) strike levels will be generated below Binary Contract Y at an interval of 2.8 

(e.g. Y – 2.8; Y; Y + 2.8). The Contract will have a Payout Criterion of greater than 

the strike level value.

(iv) INTRADAY US SMALLCAP 2000 20-MINUTE BINARY CONTRACTS
252

(1) EXPIRATION TIME – 10:00AM, 10:20AM, 10:40AM, 11:00AM, 11:20AM, 

2:40PM, 3:00PM, 3:20PM, 3:40PM 4:00PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

1.4.

(3) NUMBER OF STRIKE LEVELS LISTED – Fifteen (15) strike levels will be listed for 

each Intraday US SmallCap 2000 20-Minute Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in .10. Seven

(7) strike levels will be generated above Binary Contract Z at an interval of 1.4, and 

seven (7) strike levels will be generated below Binary Contract Z at an interval of 1.4 

(e.g. Z – 1.4; Z; Z + 1.4). The Contract will have a Payout Criterion of greater than the 

strike level value.

(v) INTRADAY US SMALLCAP 2000 20-MINUTE BINARY CONTRACTS

(1) EXPIRATION TIME – 11:40AM, 12:00PM, 12:20PM, 12:40PM, 1:00PM, 1:20PM, 

1:40PM, 2:00PM, 2:20PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

1.2.

(3) NUMBER OF STRIKE LEVELS LISTED - Fifteen (15) strike levels will be listed for 

each Intraday US SmallCap 2000 20-Minute Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in .10. Seven

(7) strike levels will be generated above Binary Contract Z at an interval of 1.2, and 

seven (7) strike levels will be generated below Binary Contract Z at an interval of 1.2 

(e.g. Z – 1.2; Z; Z + 1.2). The Contract will have a Payout Criterion of greater than the 

strike level value.

(vi) Nadex may list additional US SmallCap 2000 Binary Contracts with different 

ranges of Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.
253

(f) MINIMUM TICK – The Minimum Tick size for the US SmallCap 2000 Binary Contracts shall 

be $0.25.

(g) POSITION LIMIT – The Position Limits for the US SmallCap 2000 Binary Contracts shall 

be 2,500 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the US 

SmallCap 2000 Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the Expiration

Date. 

Date.

(j) SETTLEMENT DATE – The Settlement Date in a Series is the same date as the Expiration

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 500

Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the inthe-money Contract on the Settlement Date. The Settlement Value of an in-the-money US SmallCap 2000 

Binary Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the level of US SmallCap 2000 as 

calculated by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source 

Agency by taking all RUFC trade prices occurring in the ten (10) seconds leading up to the close of trading 

of the US SmallCap 2000 Binary Contract, provided at least twenty-five (25) trade prices are captured 

during the ten (10) second period, removing the highest twenty (20) percent of RUFC trade prices and the 

lowest twenty (20) percent of RUFC trade prices from the data set96, and using the remaining RUFC trade 

prices to calculate the Expiration Value. The calculation used is a simple average of the remaining RUFC 

trade prices in the data set, rounded to one decimal point past the precision of the underlying market. In 

the event the time it takes to collect at least twenty-five (25) RUFC trade prices exceeds the ten (10) 

seconds just prior to the close of trading of the US SmallCap 2000 Binary Contract, the Expiration Value 

is calculated by the Source Agency by taking the last twenty-five (25) RUFC trade prices just prior to the 

close of trading of the US SmallCap 2000 Binary Contract removing the highest five (5) RUFC trade 

prices and the lowest five (5) RUFC trade prices, and using the remaining fifteen (15) RUFC trade prices 

to calculate the Expiration Value. The calculation used is a simple average of all fifteen (15) RUFC trade 

prices, rounded to one decimal point past the precision of the underlying market.

96 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
254

(n) CONTINGENCIES – If no daily settlement price of the relevant RUFC is announced by the 

Source Agency, the Settlement Date will be delayed until such daily settlement price for that Series is 

released and publicly available.

RULE 12.62 US TECH 100 VARIABLE PAYOUT CONTRACTS

RULE 12.62.1 US TECH 100 “CALL SPREAD” VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the US Tech 100 

Call Spread Variable Payout Contracts, referred to as a ‘Call Spread’, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini 

NASDAQ 100® Futures contracts (“NQFC”) traded on the Chicago Mercantile Exchange (CME®)97. The 

NQFC trade prices that will be used to calculate the Underlying will be taken from four (4) NQFC delivery

months: March, June, September, or December (each a “NQFC Delivery Month”). The date on which a

new delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar

day after the End Date for the previous delivery month contract. The last day on which a delivery month 

will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday of the week preceding 

the Underlying futures contracts Expiration Date. For example, the CME e-mini NASDAQ 100 March 

2012 futures have an Expiration Date of March 16, 2012. The last day on which the e-mini NASDAQ 

100 March 2012 futures prices will be used as the Underlying for Nadex contracts and to calculate the

Expiration Value on the Expiration Date for the relevant e-mini NASDAQ 100 contracts will be the Friday

of the preceding week. Therefore, the End Date for using CME e-mini NASDAQ 100 March 2012 futures

will be March 9, 2012 and the Start Date forthe next delivery month,CME e-mini NASDAQ 100 June 2012 

futures, will be March 10, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the US Tech 100 Call Spreads, the Payout 

Criteria for the Contracts will be set as follows:

(i) DAILY US TECH 100 CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 4:15 PM ET CLOSE - At the commencement of trading in a Daily Spread US Tech 100

97 CME® is a registered mark of the Chicago Mercantile Exchange. NASDAQ-100 are registered marks of the Nasdaq Stock 

Market, Inc. Nadex is not affiliated with the Chicago Mercantile Exchange or Nasdaq Stock Market and neither the Chicago 

Mercantile Exchange, the Nasdaq Market, nor its affiliates, sponsor or endorse Nadex or its products in any way. In 

particular, the Nadex US Tech 100 Contracts are not sponsored, endorsed, sold or promoted by CME or the Nasdaq Stock 

Market.
255

Call Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed 

below:

(1) DAILY US TECH 100 CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 100 

(bb) FLOOR – The Floor shall be X – 100.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 4.

(2) In each case, “X” equals the last NQFC price, as reported by the Source Agency, rounded 

to the nearest 10.

(ii) DAILY US TECH 100 CALL SPREAD CONTRACTS, 4:15 PM ET CLOSE

- Nadex shall list a set of three (3) Call Spread Contracts with overlapping ranges, which conform to the 

Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 100.

(2) CONTRACT 2: The Ceiling shall be X + 50; The Floor shall be X – 50.

(3) CONTRACT 3: The Ceiling shall be X + 100; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 4.

(5) In each case, “X” equalsthe last NQFC price, asreported by the Source Agency, 

rounded to the nearest 10.

(iii) INTRADAY US TECH 100 CALL SPREAD CONTRACTS, 8AM ET

to 4:15 PM ET CLOSE - Nadex shall list a set of five (5) Call Spread Contracts with overlapping ranges, 

which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X - 45; The Floor shall be X – 135.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 90.

(3) CONTRACT 3: The Ceiling shall be X + 45; The Floor shall be X – 45.

(4) CONTRACT 4: The Ceiling shall be X + 90; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 135; The Floor shall be X + 45.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 4.
256

(7) In each case, “X” equalsthe last NQFC price, asreported by the Source Agency, 

rounded to the nearest 10.

(iv) INTRADAY 2-HOUR US TECH 100 CALL SPREAD CONTRACTS, 

10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, 3:00PM, 4:00PM ET CLOSE - Nadex shall list a set

of five (5) Call Spread Contracts that open 2 hours prior to the stated closing time(s) above with 

overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X - 25; The Floor shall be X – 75.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 50.

(3) CONTRACT 3: The Ceiling shall be X + 25; The Floor shall be X – 25.

(4) CONTRACT 4: The Ceiling shall be X + 50; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 75; The Floor shall be X + 25.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 4.

(7) In each case, “X” equalsthe last NQFC price, asreported by the Source Agency, 

rounded to the nearest 5.

(v) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for US Tech 100 Call Spread Variable Payout 

Contracts shall be 0.25.

(g) POSITION LIMIT – The Position Limits for US Tech 100 Call Spread Variable Payout 

Contracts shall be 250 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the US Tech 

100 Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts per strike 

level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.
257

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

US Tech 100 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the US Tech 100 Index Value as calculated 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all NQFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the 

US Tech 100 Call Spread Contract, provided at least twenty-five (25) trade prices are captured during the 

ten (10) second period, removing the highest twenty (20) percent of NQFC trade prices and the lowest 

twenty (20) percent of NQFC trade prices from the data set98, and using the remaining NQFC trade prices 

to calculate the Expiration Value. The calculation used is a simple average of the remaining NQFC trade 

prices in the data set, rounded to one decimal point past the precision of the underlying market. In the 

event the time it takes to collect at least twenty-five (25) NQFC trade prices exceeds the ten (10) seconds 

just prior to the close of trading of the US Tech 100 Call Spread Contract, the Expiration Value is 

calculated by the Source Agency by taking the last twenty-five (25) NQFC trade prices just prior to the 

close of trading of the US Tech 100 Call Spread Contract removing the highest five (5) NQFC trade prices 

and the lowest five (5) NQFC trade prices, and using the remaining fifteen (15) NQFC trade prices to 

calculate the Expiration Value. The calculation used is a simple average of all fifteen (15) NQFC trade 

prices, rounded to one decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.62.2 US TECH 100 “TOUCH BRACKET” VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the US Tech 100 

Touch Bracket Variable Payout Contracts, referred to as a ‘Touch Bracket’, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini 

NASDAQ 100® Futures contracts (“NQFC”) traded on the Chicago Mercantile Exchange (CME®)99.

98 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.

99 CME® is a registered mark of the Chicago Mercantile Exchange. NASDAQ-100 are registered marks of the Nasdaq Stock

Market, Inc. Nadex is not affiliated with the Chicago Mercantile Exchange or Nasdaq Stock Market and neither the Chicago 

Mercantile Exchange, the Nasdaq Market, nor its affiliates, sponsor or endorse Nadex or its products in any way. In
258

The NQFC trade prices that will be used to calculate the Underlying will be taken from four (4) NQFC 

delivery months: March, June, September, or December (each a “NQFC Delivery Month”). The date on 

which a new delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one 

calendar day after the End Date for the previous delivery month contract. The last day on which a delivery 

month will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday of the week 

preceding the Underlying futures contracts Expiration Date. For example, the CME e-mini NASDAQ 100 

March 2012 futures have an Expiration Date of March 16, 2012. The last day on which the e-mini 

NASDAQ 100 March 2012 futures prices will be used as the Underlying for Nadex contracts and to 

calculate the Expiration Value on the Expiration Date for the relevant e-mini NASDAQ 100 contracts will 

be the Friday of the preceding week. Therefore, the End Date for using CME e-mini NASDAQ 100 March 

2012 futures will be March 9, 2012 and the Start Date for the next delivery month, CME e-mini NASDAQ 

100 June 2012 futures, will be March 10, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the US Tech 100 Touch Bracket Contracts, 

the Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY US TECH 100 TOUCH BRACKET VARIABLE PAYOUT

CONTRACTS, Close Time is the earlier of 4:15PM ET on the last Trade Day of the contract listing, or 

when the US Tech 100 Index Value is equal to or greater than the Ceiling, or equal to or less than the Floor. 

Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a ‘Touch Bracket’, 

that open at 3:00AM ET on the first Trade Day of the week, with overlapping ranges, which conform to 

the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 120; The Floor shall be X- 30.

(2) CONTRACT 2: The Ceiling shall be X + 90; The Floor shall be X – 60.

(3) CONTRACT 3: The Ceiling shall be X + 60; The Floor shall be X - 90.

(4) CONTRACT 4: The Ceiling shall be X + 30; The Floor shall be X - 120.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 4.

(6) In each case, “X” equals the last US Tech 100 price, as reported by the Source 

Agency, rounded to the nearest 1.

particular, the Nadex US Tech 100 Contracts are not sponsored, endorsed, sold or promoted by CME or the Nasdaq Stock 

Market.
259

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 120 (or 30) and a Floor of X – 30 (or 120) where X equals the Ceiling 

(or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have the same 

Last Trade Day as originally established for the expired Touch Bracket and the same Dollar Multiplier as 

the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for the US Tech 100 Touch Bracket Variable 

Payout Contracts shall be 0.25.

(g) POSITION LIMIT – The Position Limit for US Tech 100 Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the US Tech 

100 Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 Contracts 

per strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

US Tech 100 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) US TECH 100 INDEX VALUE – The Source Agency shall calculate and produce a US Tech 

100 Index Value once each second throughout the life of the US Tech 100 Variable Payout contracts. That

is, each second the Source Agency will calculate a US Tech 100 Index Value by taking by taking all NQFC

trade prices occurring in the ten (10) seconds leading up to the Calculation Time, provided at least twentyfive (25) trade prices are captured during the ten (10) second period, removing the highest twenty

(20) percent of NQFC trade prices and the lowest twenty (20) percent of NQFC trade prices from the data 

set100, and using the remaining NQFC trade prices to calculate the US Tech 100 Index Value for that 

second. The calculation used is a simple average of the remaining NQFC trade prices in the data set,

100 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
260

rounded to one decimal point past the precision of the underlying market. In the event the time it takes to 

collect at least twenty-five (25) NQFC trade prices exceeds the ten (10) second period, the US Tech 100 

Index Value will be calculated by the Source Agency by taking the last twenty-five (25) NQFC trade 

prices just prior to the Calculation Time, removing the highest five (5) NQFC trade prices and the lowest 

five (5) NQFC trade prices, and using the remaining fifteen (15) NQFC trade prices to calculate the US 

Tech 100 Index Value. The calculation used is a simple average of all fifteen (15) NQFC trade prices, 

rounded to one decimal point past the precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the US Tech 100 Index Value as released 

by the Source Agency at Expiration.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.63 US TECH 100 BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the US Tech 100 

Binary Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Binary Contracts is the price of the E-mini 

NASDAQ 100® Futures contracts (“NQFC”) traded on the Chicago Mercantile Exchange® (CME®)101. 

The NQFC trade prices that will be used to calculate the Underlying will be taken from four (4) NQFC 

delivery months: March, June, September, or December (each a “NQFC Delivery Month”). The date on 

which a new delivery month will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one 

calendar day after the End Date for the previous delivery month contract. The last day on which a delivery 

month will be used as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday of the week 

preceding the Underlying futures contracts Expiration Date. For example, the CME e-mini NASDAQ 100 

March 2012 futures have an Expiration Date of March 16, 2012. The last day on which the e-mini 

NASDAQ 100 March 2012 futures prices will be used as the Underlying for Nadex contracts and to 

calculate the Expiration Value on the Expiration Date for the relevant e-mini NASDAQ 100 contracts will 

be the Friday of the preceding week. Therefore, the End Date for using CME e-mini NASDAQ 100 March 

2012 futures will be March 9, 2012 and the Start Date for the next delivery month, CME e-mini NASDAQ 

100 June 2012 futures, will be March 10, 2012.

101 CME® is a registered mark of the Chicago Mercantile Exchange. NASDAQ-100 are registered marks of the Nasdaq 

Stock Market, Inc. Nadex is not affiliated with the Chicago Mercantile Exchange or Nasdaq Stock Market and neither the 

Chicago Mercantile Exchange, the Nasdaq Market, nor its affiliates, sponsor or endorse Nadex or its products in any way. In 

particular, the Nadex US Tech 100 Contracts are not sponsored, endorsed, sold or promoted by CME or the Nasdaq Stock 

Market.
261

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the US Tech 100 Binary Contract, the Payout Criteria 

for the Contracts will be set as follows:

(i) WEEKLY US TECH 100 BINARY CONTRACTS

(1) EXPIRATION TIME – 4:15PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

144.

(3) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will be listed 

for the Weekly US Tech 100 Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “W” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest one (1). Six (6) strike levels 

will be generated above Binary Contract W at an interval of 144, and six (6) strike 

levels will be generated below Binary Contract W at an interval of 144 (e.g. W – 144; 

W; W + 144). The Contract will have a Payout Criterion of greater than the strike level 

value.

(ii) DAILY US TECH 100 BINARY CONTRACTS

(1) EXPIRATION TIME – 4:15PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

24.

(3) NUMBER OF STRIKE LEVELS LISTED - Twenty-one (21) strike levels will be 

listed for the Daily US Tech 100 Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “X” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest one (1). Ten (10) strike 

levels will be generated above Binary Contract X at an interval of 24, and ten (10)strike 

levels will be generated below Binary Contract X at an interval of 24 (e.g. X – 24; X;
262

X + 24). The Contract will have a Payout Criterion of greater than the strike level 

value.

(iii) INTRADAY US TECH 100 2-HOUR BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, 3:00PM,

4:00PM, 5:00PM ET CLOSE (5:00PM only Monday – Thursday)

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

12.

(3) NUMBER OF STRIKE LEVELS LISTED - Fifteen (15) strike levels will be listed for 

each Intraday US Tech 100 2-Hour Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Y” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest one (1). Seven (7) strike 

levels will be generated above Binary Contract Y at an interval of 12, and seven (7) 

strike levels will be generated below Binary Contract Y at an interval of 12 (e.g. Y –

12; Y; Y + 12). The Contract will have a Payout Criterion of greater than the strike 

level value.

(iv) INTRADAY US TECH 100 20-MINUTE BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 10:20AM, 10:40AM, 11:00AM, 11:20AM, 

2:40PM, 3:00PM, 3:20PM, 3:40PM 4:00PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

4.

(3) NUMBER OF STRIKE LEVELS LISTED – Fifteen (15) strike levels will be listed for 

each Intraday US Tech 100 20-Minute Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest 0.5. Seven (7) strike levels 

will be generated above Binary Contract Z at an interval of 4, and seven (7) strike levels 

will be generated below Binary Contract Z at an interval of 4 (e.g. Z - 4; Z; Z + 4). The 

Contract will have a Payout Criterion of greater than the strike level value.

(v) INTRADAY US TECH 100 20-MINUTE BINARY CONTRACTS
263

(1) EXPIRATION TIME – 11:40AM, 12:00PM, 12:20PM, 12:40PM, 1:00PM, 1:20PM, 

1:40PM, 2:00PM, 2:20PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

3.

(3) NUMBER OF STRIKE LEVELS LISTED – Fifteen (15) strike levels will be listed for 

each Intraday US Tech 100 20-Minute Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest 0.5. Seven (7) strike levels 

will be generated above Binary Contract Z at an interval of 3, and seven (7) strike levels 

will be generated below Binary Contract Z at an interval of 3 (e.g. Z – 3; Z; Z + 3). The 

Contract will have a Payout Criterion of greater than the strike level value.

(vi) Nadex may list additional US Tech 100 Binary Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the US Tech 100 Binary Contracts shall be

$0.25.

(g) POSITION LIMIT – The Position Limits for the US Tech 100 Binary Contracts shall be

2,500 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the US 

Tech 100 Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the 

Expiration Date.

(j) SETTLEMENT DATE – The Settlement Date in a Series is the same date as the Expiration

Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the

US Tech 100 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the inthe-money Contract on the Settlement Date. The Settlement Value of an in-the-money US Tech 100 

Binary Contract is $100.
264

(m) EXPIRATION VALUE – The Expiration Value is the level of US Tech 100 as calculated 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all NQFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the 

US Tech 100 Binary Contract, provided at least twenty-five (25) trade prices are captured during the ten

(10)second period, removing the highest twenty (20) percent of NQFC trade prices and the lowest twenty

(20) percent of NQFC trade prices from the data set102, and using the remaining NQFC trade prices to 

calculate the Expiration Value. The calculation used is a simple average of the remaining NQFC trade 

prices in the data set, rounded to one decimal point past the precision of the underlying market. In the 

event the time it takes to collect at least twenty-five (25) NQFC trade prices exceeds the ten (10) seconds 

just prior to the close of trading of the US Tech 100 Binary Contract, the Expiration Value is calculated 

by the Source Agency by taking the last twenty-five (25) NQFC trade prices just prior to the close of 

trading of the US Tech 100 Binary Contract removing the highest five (5) NQFC trade prices and the 

lowest five (5) NQFC trade prices, and using the remaining fifteen (15) NQFC trade prices to calculate 

the Expiration Value. The calculation used is a simple average of all fifteen (15) NQFC trade prices, 

rounded to one decimal point past the precision of the underlying market.

(n) CONTINGENCIES – If no daily settlement price of the relevant NQFC is announced by 

the Source Agency, the Settlement Date will be delayed until such daily settlement price for that Series is 

released and publicly available.

RULE 12.64 WALL STREET 30 VARIABLE PAYOUT CONTRACTS

RULE 12.64.1 WALL STREET 30 “CALL SPREAD” VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Wall Street 30 

Call Spread Variable Payout Contracts, referred to as a ‘Call Spread’, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini Dow® 

Futures contracts (“DJFC”) traded on the Chicago Board of Trade (CBOT®)103. The DJFC trade prices 

that will be used to calculate the Underlying will be taken from four (4) DJFC delivery months: March, 

June, September, or December (each a “DJFC Delivery Month”). The date on which a new delivery month

will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day after the End 

Date for the previous delivery month contract. The last day on which a delivery month will be used

102 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.

103 CBOT® is a registered service mark of the Board of Trade of the City of Chicago, “Dow Jones,” “DJIA,” and “The Dow” 

are registered trademarks of Dow Jones & Company, Inc. Nadex is not affiliated with the Board of Trade of the City of 

Chicago or Dow Jones and neither the Board of Trade of the City of Chicago, Dow Jones, nor its affiliates, sponsor or 

endorse Nadex or its products in any way. In particular, the Nadex Wall Street 30 Contracts are not sponsored, endorsed, 

sold or promoted by CBOT or Dow Jones.
265

as the Underlying for Nadex contracts (i.e. “End Date”) is the Friday of the week preceding the Underlying 

futures contracts Expiration Date. For example, the CME e-mini Dow March 2012 futures have an 

Expiration Date of March 16, 2012. The last day on which the e-mini Dow March 2012 futures prices 

will be used as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration 

Date for the relevant e-mini Dow contracts will be the Friday of the preceding week. Therefore, the End 

Date for using CME e-mini Dow March 2012 futures will be March 9, 2012 and the Start Date for the 

next delivery month, CME e-mini Dow June 2012 futures, will be March 10, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Wall Street 30 Call Spreads, the Payout 

Criteria for the Contracts will be set as follows:

(i) DAILY WALL STREET 30 CALL SPREAD VARIABLE PAYOUT

CONTRACTS, 4:15 PM ET CLOSE - At the commencement of trading in a Daily Wall Street 30 Call 

Spread, Nadex shall list one (1) Call Spread Contract, which conforms to the Payout Criteria listed below:

(1) DAILY WALL STREET 30 CALL SPREAD CONTRACT

(aa) CEILING – The Ceiling shall be X + 400. 

(bb) FLOOR – The Floor shall be X – 400.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

(2) In each case, “X” equals the last DJFC price, as reported by the Source Agency, rounded 

to the nearest 100.

(ii) DAILY WALL STREET 30 CALL SPREAD CONTRACTS, 4:15 PM

ET CLOSE - Nadex shall list a set of three (3) Call Spread Payout Contracts with overlapping ranges,

which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 400.

(2) CONTRACT 2: The Ceiling shall be X + 200; The Floor shall be X – 200.

(3) CONTRACT 3: The Ceiling shall be X + 400; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.
266

(5) In each case, “X” equals the last DJFC price, as reported by the Source Agency, 

rounded to the nearest 100.

(iii) INTRADAY WALL STREET 30 CALL SPREAD CONTRACTS,

8AM ET to 4:15 PM ET CLOSE - Nadex shall list a set of five (5) Call Spread Contracts with overlapping 

ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X - 150; The Floor shall be X – 450.

(2) CONTRACT 2: The Ceiling shall be X; The Floor shall be X – 300.

(3) CONTRACT 3: The Ceiling shall be X + 150; The Floor shall be X – 150.

(4) CONTRACT 4: The Ceiling shall be X + 300; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 450; The Floor shall be X + 150.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

(7) In each case, “X” equals the last DJFC price, as reported by the Source Agency, 

rounded to the nearest 50.

(iv) INTRADAY 2-HOUR WALL STREET 30 CALL SPREAD 

CONTRACTS, 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, 3:00PM, 4:00PM ET CLOSE - Nadex

shall list a set of five (5) Call Spread Contracts that open 2 hours prior to the stated closing time(s) above 

with overlapping ranges, which conform to the Payout Criteria listed below:

(1) CONTRACT 1: The Ceiling shall be X - 50; The Floor shall be X – 150.

(2) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 100.

(3) CONTRACT 2: The Ceiling shall be X + 50; The Floor shall be X – 50.

(4) CONTRACT 3: The Ceiling shall be X + 100; The Floor shall be X.

(5) CONTRACT 5: The Ceiling shall be X + 150; The Floor shall be X + 50.

(6) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

(7) In each case, “X” equals the last DJFC price, as reported by the Source Agency, 

rounded to the nearest 5.

(v) Nadex may list additional Call Spread Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the CEA and Commission Regulations.
267

(f) MINIMUM TICK – The Minimum Tick size for Wall Street 30 Call Spread Variable Payout 

Contracts shall be 1.

(g) POSITION LIMIT – The Position Limits for Wall Street 30 Call Spread Variable Payout 

Contracts shall be 250 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Wall 

Street 30 Call Spread Variable Payout Contracts for contracted Market Makers shall be 500 Contracts per 

strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Wall Street 30 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) EXPIRATION VALUE – The Expiration Value is the Wall Street 30 Index Value as 

calculated by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source 

Agency by taking all DJFC trade prices occurring in the ten (10) seconds leading up to the close of trading 

of the Wall Street 30 Call Spread Contract, provided at least twenty-five (25) trade prices are captured 

during the ten (10) second period, removing the highest twenty (20) percent of DJFC trade prices and the 

lowest twenty (20) percent of DJFC trade prices from the data set104, and using the remaining DJFC trade 

prices to calculate the Expiration Value. The calculation used is a simple average of the remaining DJFC 

trade prices in the data set, rounded to the precision of the underlying market. In the event the time it takes 

to collect at least twenty-five (25) DJFC trade prices exceeds the ten (10) seconds just prior to the close 

of trading of the Wall Street 30 Call Spread Contract, the Expiration Value is calculated by the Source 

Agency by taking the last twenty-five (25) DJFC trade prices just prior to the close of trading of the Wall 

Street 30 Call Spread Contract removing the highest five (5) DJFC trade prices and the lowest five (5)

DJFC trade prices, and using the remaining fifteen (15) DJFC trade prices to calculate the

104 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
268

Expiration Value. The calculation used is a simple average of all fifteen (15) DJFC trade prices, rounded 

to the precision of the underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.64.2 WALL STREET 30 “TOUCH BRACKET” VARIABLE PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Wall Street 30 

Touch Bracket Variable Payout Contracts, referred to as a ‘Touch Bracket’, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini Dow® 

Futures contracts (“DJFC”) traded on the Chicago Board of Trade (CBOT®)105. The DJFC trade prices 

that will be used to calculate the Underlying will be taken from four (4) DJFC delivery months: March, 

June, September, or December (each a “DJFC Delivery Month”). The date on which a new delivery month

will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day after the End

Date for the previous delivery month contract. The last day on which a delivery month will be used asthe

Underlying for Nadex contracts(i.e. “End Date”)isthe Friday of the week preceding the Underlying futures 

contracts Expiration Date. For example, the CME e-mini Dow March 2012 futures have an Expiration 

Date of March 16, 2012. The last day on which the e-mini Dow March 2012 futures prices will be used

as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date for the

relevant e-mini Dow contracts will be the Friday of the preceding week. Therefore, the End Date for using 

CME e-mini Dow March 2012 futures will be March 9, 2012 and the Start Date for the next delivery 

month, CME e-mini Dow June 2012 futures, will be March 10, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Variable Payout Contracts are initially issued. For the Wall Street 30 Touch Bracket Contracts 

the Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY WALL STREET 30 TOUCH BRACKET VARIABLE

PAYOUT CONTRACTS, Close Time is the earlier of 4:15PM ET on the last Trade Day of the contract 

listing, or when the Wall Street 30 Index Value is equal to or greater than the Ceiling, or equal to or less 

than the Floor. Nadex shall list a set of four (4) Touch Bracket Variable Payout Contracts, referred to as a

105 CBOT® is a registered service mark of the Board of Trade of the City of Chicago, “Dow Jones,” “DJIA,” and “The Dow” 

are registered trademarks of Dow Jones & Company, Inc. Nadex is not affiliated with the Board of Trade of the City of 

Chicago or Dow Jones and neither the Board of Trade of the City of Chicago, Dow Jones, nor its affiliates, sponsor or 

endorse Nadex or its products in any way. In particular, the Nadex Wall Street 30 Contracts are not sponsored, endorsed, 

sold or promoted by CBOT or Dow Jones.
269

‘Touch Bracket’, that open at 3:00AM ET on the first Trade Day of the week, with overlapping ranges,

which conform to the Payout Criteria listed below.

(1) CONTRACT 1: The Ceiling shall be X + 400; The Floor shall be X- 100.

(2) CONTRACT 2: The Ceiling shall be X + 300; The Floor shall be X – 200.

(3) CONTRACT 3: The Ceiling shall be X + 200; The Floor shall be X - 300.

(4) CONTRACT 4: The Ceiling shall be X + 100; The Floor shall be X - 400.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

(6) In each case, “X” equals the last Wall Street 30 price, as reported by the Source 

Agency, rounded to the nearest 10.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 400 (or 100) and a Floor of X – 100 (or 400) where X equals the 

Ceiling (or Floor) of the Touch Bracket that expired early. The newly listed Touch Bracket will have the 

same Last Trade Day as originally established for the expired Touch Bracket and the same Dollar 

Multiplier as the expired Touch Bracket.

(f) MINIMUM TICK – The Minimum Tick size for Wall Street 30 Touch Bracket Variable Payout 

Contracts shall be 1.

(g) POSITION LIMIT – The Position Limit for Wall Street 30 Touch Bracket Variable Payout 

Contracts shall be 100 Contracts per Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Wall 

Street 30 Touch Bracket Variable Payout Contracts for contracted Market Makers shall be 100,000 

Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date of the Contract is the same date as the 

Settlement Date.

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the same date as the 

Expiration Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date on which the 

Wall Street 30 Expiration Value is released by the Source Agency.
270

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of either a 

Short or Long Variable Payout Contract on Settlement Date. The Settlement Value of a Variable Payout 

Contract is determined as described in the definition for Long and Short Variable Payout Contracts.

(m) WALL STREET 30 INDEX VALUE – The Source Agency shall calculate and produce a 

Wall Street 30 Index Value once each second throughout the life of the Wall Street 30 Variable Payout 

contracts. That is, each second the Source Agency will calculate a Wall Street 30 Index Value by taking 

by taking all DJFC trade prices occurring in the ten (10) seconds leading up to the Calculation Time, 

provided at least twenty-five (25) trade prices are captured during the ten (10) second period, removing 

the highest twenty (20) percent of DJFC trade prices and the lowest twenty (20) percent of DJFC trade 

prices from the data set106, and using the remaining DJFC trade prices to calculate the Wall Street 30 Index 

Value for that second. The calculation used is a simple average of the remaining DJFC trade prices in the 

data set, rounded to the precision of the underlying market. In the event the time it takes to collect at least 

twenty-five (25) DJFC trade prices exceeds the ten (10) second period, the Wall Street 30 Index Value 

will be calculated by the Source Agency by taking the last twenty-five (25) DJFC trade prices just prior 

to the Calculation Time, removing the highest five (5) DJFC trade prices and the lowest five (5) DJFC 

trade prices, and using the remaining fifteen (15) DJFC trade prices to calculate the Wall Street 30 Index 

Value. The calculation used is a simple average of all fifteen (15) DJFC trade prices, rounded to the 

precision of the underlying market.

(n) EXPIRATION VALUE – The Expiration Value is the Wall Street 30 Index Value as released 

by the Source Agency at Expiration.

(o) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source agency, the Settlement Date will 

be delayed until the Underlying number is released for the Series.

RULE 12.65 WALL STREET 30 BINARY CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Wall Street 30 

Binary Contracts issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the price of the E-mini Dow® 

Futures contracts (“DJFC”) traded on the Chicago Board of Trade (CBOT®)107. The DJFC trade prices

106 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.

107 CBOT® is a registered service mark of the Board of Trade of the City of Chicago, “Dow Jones,” “DJIA,” and “The Dow”

are registered trademarks of Dow Jones & Company, Inc. Nadex is not affiliated with the Board of Trade of the City of 

Chicago or Dow Jones and neither the Board of Trade of the City of Chicago, Dow Jones, nor its affiliates, sponsor or
271

that will be used to calculate the Underlying will be taken from four (4) DJFC delivery months: March, 

June, September, or December (each a “DJFC Delivery Month”). The date on which a new delivery month

will be used as the Underlying for Nadex contracts (i.e. “Start Date”) is one calendar day after the End

Date for the previous delivery month contract. The last day on which a delivery month will be used asthe

Underlying for Nadex contracts(i.e. “End Date”) isthe Friday ofthe week preceding the Underlying futures 

contracts Expiration Date. For example, the CME e-mini Dow March 2012 futures have an Expiration 

Date of March 16, 2012. The last day on which the e-mini Dow March 2012 futures prices will be used

as the Underlying for Nadex contracts and to calculate the Expiration Value on the Expiration Date for the

relevant e-mini Dow contracts will be the Friday of the preceding week. Therefore, the End Date for using 

CME e-mini Dow March 2012 futures will be March 9, 2012 and the Start Date for the next delivery 

month, CME e-mini Dow June 2012 futures, will be March 10, 2012.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Binary Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Binary Contracts are initially issued. For the Wall Street 30 Binary Contract, the Payout Criteria 

for the Contracts will be set as follows:

(i) WEEKLY WALL STREET 30 BINARY CONTRACTS

(1) EXPIRATION TIME – 4:15PM ET CLOSE

(1) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

200.

(2) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will be listed for 

the Weekly Wall Street 30 Binary Contract Series.

(3) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “W” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest one (1). Six (6) strike levels will be generated 

above Binary Contract W at an interval of 200, and six (6) strike levels will be generated 

below Binary Contract W at an interval of 200 (e.g. W – 200; W; W + 200). The Contract 

will have a Payout Criterion of greater than the strike level value.

(ii) DAILY WALL STREET 30 BINARY CONTRACTS

endorse Nadex or its products in any way. In particular, the Nadex Wall Street 30 Contracts are not sponsored, endorsed, 

sold or promoted by CBOT or Dow Jones.
272

(1) EXPIRATION TIME – 4:15PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be

40.

(3) NUMBER OF STRIKE LEVELS LISTED - Twenty-one (21) strike levels will be listed

for the Daily Wall Street 30 Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “X” is valued ‘at-the-money’ in relation to the Underlying market as determined by the Source 

Agency, immediately before the issuance of these Contracts, and shall be measured in U.S. cents rounded 

to the nearest one (1). Ten (10) strike levels will be generated above Binary Contract X at an interval of 

40, and ten (10) strike levels will be generated below Binary Contract X at an interval of 40 (e.g. X – 40; 

X; X + 40). The Contract will have a Payout Criterion of greater than the strike level value.

(iii) INTRADAY WALL STREET 30 2-HOUR BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 11:00AM, 12:00PM, 1:00PM, 2:00PM, 3:00PM,

4:00PM, 5:00PM ET CLOSE (5:00PM only Monday – Thursday)

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

24.

(3) NUMBER OF STRIKE LEVELS LISTED - Fifteen (15) strike levels will be listed for 

each Intraday Wall Street 30 2-Hour Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Y” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest one value ending in 1, 3, 5, 

7, or 9 as reported by the Source Agency. Seven (7) strike levels will be generated 

above Binary Contract Y at an interval of 24, and seven (7) strike levels will be 

generated below Binary Contract Y at an interval of 24 (e.g. Y – 24; Y; Y + 24). The 

Contract will have a Payout Criterion of greater than the strike level value.

(iv) INTRADAY WALL STREET 30 20-MINUTE BINARY CONTRACTS

(1) EXPIRATION TIME – 10:00AM, 10:20AM, 10:40AM, 11:00AM, 11:20AM, 

2:40PM, 3:00PM, 3:20PM, 3:40PM 4:00PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

8.
273

(3) NUMBER OF STRIKE LEVELS LISTED - Fifteen (15) strike levels will be listed for 

each Intraday Wall Street 30 20-Minute Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in either 0, 2, 

4, 6, or 8. Seven (7) strike levels will be generated above Binary Contract Z at an 

interval of 8, and seven (7) strike levels will be generated below Binary Contract Z at 

an interval of 8 (e.g. Z - 8; Z; Z + 8). The Contract will have a Payout Criterion of 

greater than the strike level value.

(v) INTRADAY WALL STREET 30 20-MINUTE BINARY CONTRACTS

(1) EXPIRATION TIME – 11:40AM, 12:00PM, 12:20PM, 12:40PM, 1:00PM, 1:20PM, 

1:40PM, 2:00PM, 2:20PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level shall be 

6.

(3) NUMBER OF STRIKE LEVELS LISTED - Fifteen (15) strike levels will be listed for 

each Intraday Wall Street 30 20-Minute Binary Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that Binary 

Contract “Z” is valued ‘at-the-money’ in relation to the Underlying market as 

determined by the Source Agency, immediately before the issuance of these Contracts, 

and shall be measured in U.S. cents rounded to the nearest value ending in either 0, 2, 

4, 6, or 8. Seven (7) strike levels will be generated above Binary Contract Z at an

interval of 6, and seven (7) strike levels will be generated below Binary Contract Z at 

an interval of 6 (e.g. Z – 6; Z; Z + 6). The Contract will have a Payout Criterion of 

greater than the strike level value.

(vi) Nadex may list additional Wall Street 30 Binary Contracts with different 

ranges of Payout Criteria on a discretionary basis in accordance with the CEA and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the Wall Street 30 Binary Contracts shall

be $0.25.

(g) POSITION LIMIT – The Position Limits for the Wall Street 30 Binary Contracts shall be

2,500 Contracts per Class.
274

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Wall 

Street 30 Binary Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the 

Expiration Date.

(j) SETTLEMENT DATE – The Settlement Date in a Series is the same date as the Expiration

Date.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the

Wall Street 30 Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the inthe-money Contract on the Settlement Date. The Settlement Value of an in-the-money Wall Street 30 

Binary Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the level of Wall Street 30 as calculated 

by the Source Agency on the Expiration Date. The Expiration Value is calculated by the Source Agency 

by taking all DJFC trade prices occurring in the ten (10) seconds leading up to the close of trading of the 

Wall Street 30 Binary Contract, provided at least twenty-five (25) trade prices are captured during the ten

(10) second period, removing the highest twenty (20) percent of DJFC trade prices and the lowest twenty

(20) percent of DJFC trade prices from the data set108, and using the remaining DJFC trade prices to 

calculate the Expiration Value. The calculation used is a simple average of the remaining DJFC trade 

prices in the data set, rounded to the precision of the underlying market. In the event the time it takes to 

collect at least twenty-five (25) DJFC trade prices exceeds the ten (10) seconds just prior to the close of 

trading of the Wall Street 30 Binary Contract, the Expiration Value is calculated by the Source Agency 

by taking the last twenty-five (25) DJFC trade prices just prior to the close of trading of the Wall Street 

30 Binary Contract removing the highest five (5) DJFC trade prices and the lowest five (5) DJFC trade 

prices, and using the remaining fifteen (15) DJFC trade prices to calculate the Expiration Value. The 

calculation used is a simple average of all fifteen (15) DJFC trade prices, rounded to the precision of the 

underlying market.

(n) CONTINGENCIES – If no daily settlement price of the relevant DJFC is announced by the 

Source Agency, the Settlement Date will be delayed until such daily settlement price for that Series is 

released and publicly available.

RULES 12.66 – 12.75 [RESERVED]

RULE 12.76 CORN YIELDS EVENT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Corn Yields Event Contract 

issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Projected Corn Yields per Harvested 

Acre (bushels) for the current month and marketing year last reported by the Source Agency in the World 

Agricultural Supply and Demand Estimates Report. The Start Date for the Corn Yields Event Contracts 

will be at least two business days prior to the next Expiration Date. The End Date will be the Last Trading 

Date. 
275

(c) SOURCE AGENCY – The Source Agency is the United States Department of Agriculture, World 

Agricultural Outlook Board (“WAOB”).

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the time the 

Event Contracts are initially issued. For the Corn Yields Event Contract, the Payout Criteria for the 

Contracts will be set as follows: 

(i) WEEKLY CORN YIELDS EVENT CONTRACTS

(1) At the commencement of trading in a Corn Yields Event Contract, Nadex shall 

list all eligible Payout Criteria in a range of five (5) consecutive increments between 0 and 

1,000.1 as determined by Nadex, with contract Payout Criteria of greater than (>) the 

Expiration Value. For example, Nadex may list the following range of Payout Criteria (using 

the 0.3 increment): 170.1, 170.4, 170.7, 171.0, 171.3. For the next issuance, Nadex may list the 

following range of Payout Criteria (using a 1.5 increment): 170.0, 171.5, 173.0, 174.5, 176.0. 

(2) In each case above, “X” equals the first Payout Criteria listed. In the first 

example above, this is 170.1; in the second example above, this is 170.0.

(ii) Nadex may list additional Corn Yields Event Contracts with different ranges of Payout 

Criteria on a discretionary basis in accordance with the Department of Agriculture and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the Corn Yields Event Contracts shall be $0.25. 

(g) POSITION LIMIT – There are currently no Position Limits for the Corn Yields Event Contract. 

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The Corn Yields Event Contracts will stop trading on the Last Trading Date at 11:55 AM ET. 

(i) SETTLEMENT DATE – The Settlement Date will be the date the Corn Yields number is 

released by the Source Agency. 

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the Corn 

Yields number, as reported in the World Agricultural Supply and Demand Estimates Report, is scheduled 

to be released. 

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money Corn Yields Event Contract 

is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the Corn Yields release number 

on the Expiration Date. The Expiration Value is released by the Source Agency at 12:00 PM ET on the 

Expiration Date.
276

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.77 SOYBEANS YIELDS EVENT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Soybeans Yields 

Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Projected Soybeans Yields 

per Harvested Acre (bushels) for the current month and marketing year last reported by the Source Agency 

in the World Agricultural Supply and Demand Estimates Report. The Start Date for the Soybeans Yields 

Event Contracts will be at least two business days prior to the next Expiration Date. The End Date will be 

the Last Trading Date. 

(c) SOURCE AGENCY – The Source Agency is the United States Department of Agriculture, 

World Agricultural Outlook Board (“WAOB”).

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the Soybeans Yields Event Contract, the Payout Criteria 

for the Contracts will be set as follows:

(i) WEEKLY SOYBEANS YIELDS Event CONTRACTS

(1) At the commencement of trading in a Soybeans Yields Event Contract, Nadex shall 

list all eligible Payout Criteria in a range of five (5) consecutive increments between 0 and 

1,000.1 as determined by Nadex, with contract Payout Criteria of greater than (>) the Expiration 

Value. For example, Nadex may list the following range of Payout Criteria (using the 0.3 

increment): 50.1, 50.4, 50.7, 60.0, 60.3. For the next issuance, Nadex may list the following 

range of Payout Criteria (using a 1.5 increment): 61.0, 62.5, 64.0, 65.5, 67.0. 

(2) In each case above, “X” equals the first Payout Criteria listed. In the first example 

above, this is 50.1; in the second example above, this is 61.0.

(ii) Nadex may list additional Soybeans Yields Event Contracts with different ranges of Payout 

Criteria on a discretionary basis in accordance with the Department of Agriculture and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the Soybeans Yields Event Contracts shall be 

$0.25.

(g) POSITION LIMIT – There are currently no Position Limits for the Soybeans Yields Event

Contract. 

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The Soybeans Yields Event Contracts will stop trading on the Last Trading Date at 11:55 AM ET. 
277

(i) SETTLEMENT DATE – The Settlement Date will be the date the Soybeans Yields number is 

released by the Source Agency. 

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

Soybeans Yields number, as reported in the World Agricultural Supply and Demand Estimates Report, is 

scheduled to be released. 

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money Soybeans Yields Event

Contract is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the Soybeans Yields release 

number on the Expiration Date. The Expiration Value is released by the Source Agency at 12:00 PM ET 

on the Expiration Date.

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.78 CRUDE OIL INVENTORIES CHANGE EVENT CONTRACTS 

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Crude Oil 

Inventories Change Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the weekly increase or decrease 

in Crude Oil Inventories last reported by the Source Agency. The Start Date for the Crude Oil Inventories 

Change Event Contracts will be at least two business days prior to the next Expiration Date. The End Date 

will be the Last Trading Date. 

(c) SOURCE AGENCY – The Source Agency is the United States Energy Information 

Administration.

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the Crude Oil Inventories Change Event Contract, the 

Payout Criteria for the Contracts will be set as follows: 

(i) WEEKLY CRUDE OIL INVENTORIES CHANGE EVENT CONTRACTS

(1) At the commencement of trading in a Crude Oil Inventories Change Event Contract, 

Nadex shall list all eligible Payout Criteria in a range of five (5) consecutive increments between 

-10,000,000 and 10,000,000, as determined by Nadex, with contract Payout Criteria of greater 

than (>) the Expiration Value. For example, Nadex may list the following range of Payout 

Criteria (using the 1,000,000 increment): 1,000,000, 2,000,000, 3,000,000, 4,000,000, and 

5,000,000. For the next issuance, Nadex may list the following range of Payout Criteria (using 

a 2,000,000 increment): -2,000,000, 0, 2,000,000, 4,000,000, and 6,000,000. 
278

(2) In each case above, “X” equals the first Payout Criteria listed. In the first example 

above, this is 1,000,000; in the second example above, this is -2,000,000.

(ii) Nadex may list additional Crude Oil Inventories Change Event Contracts with different 

ranges of Payout Criteria on a discretionary basis in accordance with the Energy Information Administration 

and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the Crude Oil Inventories Change Event

Contracts shall be $0.25. 

(g) POSITION LIMIT – There are currently no Position Limits for the Crude Oil Inventories 

Change Event Contract. 

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The Crude Oil Inventories Change Event Contracts will stop trading on the Last Trading Date at 

10:25 AM ET. 

(i) SETTLEMENT DATE – The Settlement Date will be the date the Crude Oil Inventories Change 

number is released by the Source Agency. 

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the Crude 

Oil Inventories Change number, as reported in the Weekly Petroleum Status Report, is scheduled to be 

released.

 

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money Crude Oil Inventories 

Change Event Contract is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the Crude Oil Inventories Change 

release number on the Expiration Date. The Expiration Value is released by the Source Agency at 10:30 

AM ET on the Expiration Date. 

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.79 NATURAL GAS NET CHANGE (BCF) EVENT CONTRACTS 

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Natural Gas Net 

Change (bcf) Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the weekly Natural Gas Net 

Change (bcf) last reported by the Source Agency. The Start Date for the Natural Gas Net Change (bcf) 

Event Contracts will be at least two business days prior to the next Expiration Date. The End Date will be 

the Last Trading Date. 

(c) SOURCE AGENCY – The Source Agency is the United States Energy Information 
279

Administration.

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the Natural Gas Net Change Event Contract, the Payout 

Criteria for the Contracts will be set as follows:

 

(i) WEEKLY NATURAL GAS NET CHANGE BINARY CONTRACTS

(1) At the commencement of trading in a Natural Gas Net Change Event Contract, 

Nadex shall list all eligible Payout Criteria in a range of five (5) consecutive increments between 

-500 and 500, as determined by Nadex, with contract Payout Criteria of greater than (>) the 

Expiration Value. For example, Nadex may list the following range of Payout Criteria (using 

the 10 increment): 40, 50, 60, 70, and 80. For the next issuance, Nadex may list the following 

range of Payout Criteria (using a 20 increment): 65,85,105,125, and 145. 

(2) In each case above, “X” equals the first Payout Criteria listed. In the first example 

above, this is 40; in the second example above, this is 65.

(ii) Nadex may list additional Natural Gas Net Change Event Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the Energy Information Administration and 

Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the Natural Gas Net Change Event Contracts 

shall be $0.25. 

(g) POSITION LIMIT – There are currently no Position Limits for the Natural Gas Net Change 

Event Contract.

 

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The Natural Gas Net Change Event Contracts will stop trading on the Last Trading Date at 10:25 

AM ET.

 

(i) SETTLEMENT DATE – The Settlement Date will be the date the Natural Gas Net Change 

number is released by the Source Agency. 

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

Natural Gas Net Change number, as reported in the Weekly Natural Gas Storage Report, is scheduled to be 

released. 

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money Natural Gas Net Change 

Event Contract is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the Natural Gas Net Change 

release number on the Expiration Date. The Expiration Value is released by the Source Agency at 10:30 

AM ET on the Expiration Date.
280

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.80 CONSUMER PRICE INDEX – ALL ITEMS LESS FOOD AND ENERGY EVENT

CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Consumer Price 

Index - All Items less Food and Energy "Core CPI" Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the monthly percentage increase 

or decrease in the Consumer Price Index – All Items Less Food and Energy last reported by the Source 

Agency. The Start Date for the CPI Less Food/Energy Event Contracts will be at least two business days 

prior to the next Expiration Date. The End Date will be the Last Trading Date. 

(c) SOURCE AGENCY – The Source Agency is the United States Department of Labor, Bureau 

of Labor Statistics (“BLS”).

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the CPI Less Food/Energy Event Contract, the Payout 

Criteria for the Contracts will be set as follows: 

(i) WEEKLY CPI LESS FOOD/ENERGY EVENT CONTRACTS

(1) At the commencement of trading in a CPI Less Food/Energy Event Contract, Nadex

shall list all eligible Payout Criteria in a range of five (5) consecutive increments between -5.0% 

and 5.0%, as determined by Nadex, with contract Payout Criteria of greater than (>) the 

Expiration Value. For example, Nadex may list the following range of Payout Criteria (using 

the 0.1% increment): 2.2%, 2.3%, 2.4%, 2.5%, and 2.6%. For the next issuance, Nadex may list 

the following range of Payout Criteria (using a 0.5% increment): 1.5%, 2.0%, 2.5%, 3.0%, and 

3.5%. 

(2) In each case above, “X” equals the first Payout Criteria listed. In the first example 

above, this is 2.2%; in the second example above, this is 1.5%.

(ii) Nadex may list additional CPI Less Food/Energy Event Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the Department of Labor and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the CPI Less Food/Energy Event Contracts 

shall be $0.25. 

(g) POSITION LIMIT – There are currently no Position Limits for the CPI Less Food/Energy Event

Contract. 
281

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The CPI Less Food/Energy Event Contracts will stop trading on the Last Trading Date at 8:25 AM 

ET. 

(i) SETTLEMENT DATE – The Settlement Date will be the date the CPI Less Food/Energy 

number is released by the Source Agency. 

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the CPI 

Less Food/Energy, as reported in the CPI Report, is scheduled to be released.

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money CPI Less Food/Energy 

Event Contract is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the CPI Less Food/Energy release 

number on the Expiration Date. The Expiration Value is released by the Source Agency at 8:30 AM ET on 

the Expiration Date.

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.81 CONSUMER PRICE INDEX – FOOD AT HOME EVENT CONTRACTS 

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Consumer Price 

Index – Food at Home "CPI Food at Home" Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the monthly percentage increase 

or decrease in the Consumer Price Index – Food at Home last reported by the Source Agency. The Start 

Date for the CPI Food at Home Event Contracts will be at least two business days prior to the next 

Expiration Date. The End Date will be the Last Trading Date. 

(c) SOURCE AGENCY – The Source Agency is the United States Department of Labor, Bureau 

of Labor Statistics (“BLS”).

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the CPI Food at Home Event Contract, the Payout Criteria 

for the Contracts will be set as follows: 

(i) WEEKLY CPI FOOD AT HOME EVENT CONTRACTS

(1) At the commencement of trading in a CPI Food at Home Event Contract, 

Nadex shall list all eligible Payout Criteria in a range of five (5) consecutive increments 

between -5.0% and 5.0%, as determined by Nadex, with contract Payout Criteria of greater 

than (>) the Expiration Value. For example, Nadex may list the following range of Payout 

Criteria (using the 0.1% increment): 2.2%, 2.3%, 2.4%, 2.5%, and 2.6%. For the next issuance, 
282

Nadex may list the following range of Payout Criteria (using a 0.5% increment): 1.5%, 2.0%, 

2.5%, 3.0%, and 3.5%. 

(2) In each case above, “X” equals the first Payout Criteria listed. In the first 

example above, this is 2.2%; in the second example above, this is 1.5%.

(ii) Nadex may list additional CPI Food at Home Event Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the Department of Labor and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the CPI Food at Home Event Contracts shall 

be $0.25. 

 

(g) POSITION LIMIT – There are currently no Position Limits for the CPI Food at Home Event

Contract.

 

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The CPI Food at Home Event Contracts will stop trading on the Last Trading Date at 8:25 AM ET. 

(i) SETTLEMENT DATE – The Settlement Date will be the date the CPI Food at Home number 

is released by the Source Agency. 

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the CPI 

Food at Home, as reported in the CPI Report, is scheduled to be released. 

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money CPI Food at Home Event

Contract is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the CPI Food at Home release 

number on the Expiration Date. The Expiration Value is released by the Source Agency at 8:30 AM ET 

on the Expiration Date.

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.82 CONSUMER PRICE INDEX – FOOD AWAY FROM HOME EVENT CONTRACTS 

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Consumer Price 

Index – Food Away From Home "CPI Food Away From Home" Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the monthly percentage increase 

or decrease in the Consumer Price Index – Food Away From Home last reported by the Source Agency. 

The Start Date for the CPI Food Away From Home Event Contracts will be at least two business days prior 

to the next Expiration Date. The End Date will be the Last Trading Date. 

(c) SOURCE AGENCY – The Source Agency is the United States Department of Labor, Bureau 
283

of Labor Statistics (“BLS”).

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the CPI Food Away From Home Event Contract, the 

Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY CPI FOOD AWAY FROM HOME EVENT CONTRACTS

(1) At the commencement of trading in a CPI Food Away From Home Event

Contract, Nadex shall list all eligible Payout Criteria in a range of five (5) consecutive 

increments between -5.0% and 5.0%, as determined by Nadex, with contract Payout Criteria of 

greater than (>) the Expiration Value. For example, Nadex may list the following range of 

Payout Criteria (using the 0.1% increment): 2.2%, 2.3%, 2.4%, 2.5%, and 2.6%. For the next 

issuance, Nadex may list the following range of Payout Criteria (using a 0.5% increment): 1.5%, 

2.0%, 2.5%, 3.0%, and 3.5%

(2) In each case above, “X” equals the first Payout Criteria listed. In the first 

example above, this is 2.2%; in the second example above, this is 1.5%.

(ii) Nadex may list additional CPI Food Away From Home Event Contracts with different ranges 

of Payout Criteria on a discretionary basis in accordance with the Department of Labor and 

Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the CPI Food Away From Home Event

Contracts shall be $0.25. 

(g) POSITION LIMIT – There are currently no Position Limits for the CPI Food Away From Home 

Event Contract. 

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The CPI Food Away From Home Event Contracts will stop trading on the Last Trading Date at 8:25 

AM ET. 

(i) SETTLEMENT DATE – The Settlement Date will be the date the CPI Food Away From Home 

number is released by the Source Agency. 

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the CPI 

Food Away From Home, as reported in the CPI Report, is scheduled to be released. 

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money CPI Food Away From Home 

Event Contract is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the CPI Food Away From Home 

release number on the Expiration Date. The Expiration Value is released by the Source Agency at 8:30 

AM ET on the Expiration Date.
284

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.83 CONSUMER PRICE INDEX EVENT CONTRACTS 

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Consumer Price 

Index "Overall CPI" Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the monthly percentage increase 

or decrease in the Consumer Price Index last reported by the Source Agency. The Start Date for the CPI 

Event Contracts will be at least two business days prior to the next Expiration Date. The End Date will be 

the Last Trading Date. 

(c) SOURCE AGENCY – The Source Agency is the United States Department of Labor, Bureau 

of Labor Statistics (“BLS”).

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the CPI Event Contract, the Payout Criteria for the 

Contracts will be set as follows: 

(i) WEEKLY CPI EVENT CONTRACTS

(1) At the commencement of trading in a CPI Event Contract, Nadex shall list all eligible 

Payout Criteria in a range of five (5) consecutive increments between -5.0% and 5.0%, as 

determined by Nadex, with contract Payout Criteria of greater than (>) the Expiration Value. 

For example, Nadex may list the following range of Payout Criteria (using the 0.1% increment): 

2.2%, 2.3%, 2.4%, 2.5%, and 2.6%. For the next issuance, Nadex may list the following range 

of Payout Criteria (using a 0.5% increment): 1.5%, 2.0%, 2.5%, 3.0%, and 3.5%. 

(2) In each case above, “X” equals the first Payout Criteria listed. In the first example 

above, this is 2.2%; in the second example above, this is 1.5%.

(ii) Nadex may list additional CPI Event Contracts with different ranges of Payout Criteria on a 

discretionary basis in accordance with the Department of Labor and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the CPI Event Contracts shall be $0.25. 

(g) POSITION LIMIT – There are currently no Position Limits for the CPI Event Contract. 

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The CPI Event Contracts will stop trading on the Last Trading Date at 8:25 AM ET. 

(i) SETTLEMENT DATE – The Settlement Date will be the date the CPI number is released by 

the Source Agency. 
285

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the CPI, 

as reported in the CPI Report, is scheduled to be released. 

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money CPI Event Contract is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the CPI release number on the 

Expiration Date. The Expiration Value is released by the Source Agency at 8:30 AM ET on the Expiration 

Date.

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.84 FEDERAL BALANCE SHEET TOTAL ASSETS (MILLIONS) EVENT CONTRACTS 

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Federal Balance 

Sheet Total Assets (Millions) “Total Assets” Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the Total Assets (Millions) 

figure in the Consolidated Statement of Condition of All Federal Reserve Banks last reported by the Source 

Agency. 

(c) The Start Date for the Total Assets Event Contracts will be at least two business days prior to 

the next Expiration Date. The End Date will be the Last Trading Date. 

(d) SOURCE AGENCY – The Source Agency is the United States Federal Reserve Bank.

(e) TYPE – The Type of Contract is a Event Contract.

(f) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the Total Assets Event Contract, the Payout Criteria for 

the Contracts will be set as follows: 

(i) WEEKLY TOTAL ASSETS EVENT CONTRACTS

(1) At the commencement of trading in a Fed Balance Sheet Total Assets (Millions) 

Event Contract, Nadex shall list one (1) eligible Payout Criteria between 1,000,000 and 

25,000,000, as determined by Nadex, with contract Payout Criteria of greater than (>) the 

Expiration Value. For example, Nadex may list the following Payout Criteria: 9,000,000.

(2) In the case above, “X” equals the first Payout Criteria listed. In the example above, 

this is 9,000,000.

(ii) Nadex may list additional Total Assets Event Contracts with different ranges of Payout 

Criteria on a discretionary basis in accordance with the Federal Reserve Bank and Commission 

Regulations.
286

(g) MINIMUM TICK – The Minimum Tick size for the Total Assets Event Contracts shall be $0.25. 

(h) POSITION LIMIT – There are currently no Position Limits for the Total Assets Event Contract. 

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The Total Assets Event Contracts will stop trading on the Last Trading Date at 4:25 PM ET. 

(j) SETTLEMENT DATE – The Settlement Date will be the date the Total Assets number is 

released by the Source Agency. 

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the Total 

Assets (Millions), as reported in the Factors Affecting Reserve Balances Report, is scheduled to be released. 

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money Total Assets Event Contract 

is $100. 

(m) EXPIRATION VALUE – The Expiration Value is the level of the Total Assets (Millions) 

release number on the Expiration Date. The Expiration Value is released by the Source Agency at 4:30 PM 

ET on the Expiration Date.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.85 NEW HOME SALES EVENT CONTRACTS 

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the New Home Sales 

Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the New Residential Home 

Sales figure last reported by the Source Agency. The Start Date for the New Home Sales Event Contracts 

will be at least two business days prior to the next Expiration Date. The End Date will be the Last Trading 

Date. 

(c) SOURCE AGENCY – The Source Agency is the United States Census Bureau.

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the New Home Sales Event Contract, the Payout Criteria 

for the Contracts will be set as follows: 

(i) WEEKLY NEW HOME SALES EVENT CONTRACTS

(1) At the commencement of trading in a New Home Sales Event Contract, Nadex shall 

list all eligible Payout Criteria in a range of five (5) consecutive increments between 100,000 
287

and 5,000,000, as determined by Nadex, with contract Payout Criteria of greater than (>) the 

Expiration Value. For example, Nadex may list the following range of Payout Criteria (using 

the 50,000 increment): 650,000, 700,000, 750,000, 800,000, 850,000. For the next issuance, 

Nadex may list the following range of Payout Criteria (using a 100,000 increment): 500,000, 

600,000, 700,000, 800,000, 900,000. 

(2) In each case above, “X” equals the first Payout Criteria listed. In the first example 

above, this is 650,000; in the second example above, this is 500,000. 

(ii) Nadex may list additional New Home Sales Event Contracts with different ranges of Payout 

Criteria on a discretionary basis in accordance with the Census Bureau and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the New Home Sales Event Contracts shall be 

$0.25. 

 

(g) POSITION LIMIT – There are currently no Position Limits for the New Home Sales Event

Contract. 

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The New Home Sales Event Contracts will stop trading on the Last Trading Date at 9:55 AM ET. 

(i) SETTLEMENT DATE – The Settlement Date will be the date the New Residential Home Sales 

number is released by the Source Agency. 

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the New 

Residential Home Sales number, as reported in the Monthly New Residential Sales Report, is scheduled to 

be released. 

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money New Home Sales Event

Contract is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the New Home Sales release 

number on the Expiration Date. The Expiration Value is released by the Source Agency at 10:00 AM ET 

on the Expiration Date.

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.86 RETAIL SALES CHANGE EVENT CONTRACTS 

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the Retail Sales Change 

Event Contract issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the monthly percentage increase 

or decrease in Advance Monthly Sales for Retail and Food Services figure last reported by the Source 
288

Agency. The Start Date for the Retail Sales Change Event Contracts will be at least two business days prior 

to the next Expiration Date. The End Date will be the Last Trading Date.

(c) SOURCE AGENCY – The Source Agency is the United States Census Bureau.

(d) TYPE – The Type of Contract is a Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by Nadex at the 

time the Event Contracts are initially issued. For the Retail Sales Change Event Contract, the Payout 

Criteria for the Contracts will be set as follows: 

(i) WEEKLY RETAIL SALES CHANGE EVENT CONTRACTS

(1) At the commencement of trading in a Retail Sales Change Event Contract, Nadex 

shall list all eligible Payout Criteria in a range of five (5) consecutive increments between -5.0% 

and 5.0%, as determined by Nadex, with contract Payout Criteria of greater than (>) the 

Expiration Value. For example, Nadex may list the following range of Payout Criteria (using 

the 0.2% increment): -0.5%, -0.3%, -0.1%, 0.1%, 0.3% For the next issuance, Nadex may list 

the following range of Payout Criteria (using a 1% increment): 0.0%, 1.0%, 2.0%, 3.0%, 4.0%.

(2) In each case above, “X” equals the first Payout Criteria listed. In the first example 

above, this is -0.5%; in the second example above, this is 0.0%. 

(ii) Nadex may list additional Retail Sales Change Event Contracts with different ranges of 

Payout Criteria on a discretionary basis in accordance with the Census Bureau and Commission 

Regulations.

(f) MINIMUM TICK – The Minimum Tick size for the Retail Sales Change Event Contracts shall 

be $0.25. 

(g) POSITION LIMIT – There are currently no Position Limits for the Retail Sales Change Event

Contract. 

(h) LAST TRADING DATE – The Last Trading Date in a Series is the same day as the Expiration 

Date. The Retail Sales Change Event Contracts will stop trading on the Last Trading Date at 8:25 AM ET. 

(i) SETTLEMENT DATE – The Settlement Date will be the date the Advance Monthly Sales for 

Retail and Food Services figure is released by the Source Agency. 

(j) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the 

Advance Monthly Sales for Retail and Food Services figure, as reported in the Advance Monthly Sales for 

Retail and Food Services Report, is scheduled to be released. 

(k) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the 

money Contract on Settlement Date. The Settlement Value of an in the money Retail Sales Change Event

Contract is $100. 

(l) EXPIRATION VALUE – The Expiration Value is the level of the percentage increase or 
289

decrease from the Previous Month in Retail Sales Change release number on the Expiration Date. The 

Expiration Value is released by the Source Agency at 8:30 AM ET on the Expiration Date.

(m) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.87 BITCOIN CRYPTOCURRENCY EVENT CONTRACT

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Bitcoin Cryptocurrency 

(“Bitcoin” or “BTC”) Event Contracts, referred to as an ‘Event Contract”, issued by the Exchange. 

(b) UNDERLYING – The Underlying for this Class of Contracts is the spot bitcoin cryptocurrency as 

reported in the ICE® Cryptocurrency Data1aggregated by Blockstream® Corporation2and distributed by 

ICE Data® Connectivity and Feeds, Inc., herein referred to as “IDCF BIT”, quoted in US dollars.

(c) SOURCE AGENCY – The Source Agency is the Exchange.

(d) TYPE – The Type of Contract is an Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by the Exchange at 

the time the Event Contracts are initially issued. For the Bitcoin Event Contracts, the Payout Criteria for 

the Contracts will be set as follows: 

(i) DAILY BITCOIN EVENT CONTRACTS

(1) EXPIRATION TIME – 5 PM Monday thru Thursday; 4 PM Friday.

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 200.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels will be listed 

for each Daily Bitcoin Event Contract Series.

1

ICE® is a registered mark of IntercontinentalExchange, Inc. (“ICE”) and ICE Data® is a registered mark of Intercontinental Exchange Holdings, 

Inc (“ICE Holdings”). The Exchange is not affiliated with ICE or ICE Data Connectivity and Feeds, Inc., and the Bitcoin Cryptocurrency Event 

Contracts are not sponsored, endorsed, sold or promoted by ICE or ICE Data Connectivity and Feeds, Inc. in any way.

2 Blockstream® is a registered mark of Blockstream Corporation (“Blockstream”). The Exchange is not affiliated with Blockstream and the Bitcoin 

Cryptocurrency Event Contracts are not sponsored, endorsed, sold or promoted by Blockstream.
290

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Event Contract “X” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in 0.25 as reported by the Source 

Agency. Four (4) strike levels will be generated above Event Contract X at an interval of 200, 

and Four (4) strike levels will be generated below Event Contract X at an interval of 200 (e.g. 

X – 200; X; X + 200). The Contract will have a Payout Criterion of greater than the strike level 

value.

(ii) INTRADAY 2-HOUR BITCOIN EVENT CONTRACTS

(1) EXPIRATION TIME – 8 PM, 9 PM, 10 PM, 11 PM, 12 AM, 1 AM, 2 AM, 3 

AM, 4 AM, 5 AM, 6 AM, 7 AM, 8 AM, 9 AM, 10 AM, 11 AM, 12 PM, 1 PM, 2 PM, 3 PM, 5 

PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 100.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels will be listed 

for each Intraday 2-Hour Bitcoin Event Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Event Contract “Y” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in either 0.00, 0.0025, 0.0050, 0.0075 

as reported by the Source Agency. Four (4) strike levels will be generated above Event Contract 

Y at an interval of 100, and four (4) strike levels will be generated below Event Contract Y at 

an interval of 100 (e.g. Y – 100; Y; Y + 100). The Contract will have a Payout Criterion of 

greater than the strike level value.

(iii) Nadex may list additional Bitcoin Event Contracts with different ranges of Payout Criteria 

on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Bitcoin Event Contracts shall be $0.25.

(g) POSITION LIMIT – The Position Limits for Bitcoin Event Contracts shall be 2,500 Contracts per 

Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Bitcoin Event 

Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same as the Expiration Date. No 

trading in the Bitcoin Event Contracts shall occur after its Last Trading Date.
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(j) SETTLEMENT DATE – The Settlement Date will be the date on which the Bitcoin price as reported 

by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the Bitcoin 

price is released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the money 

Contract on the Settlement Date. The Settlement Value of an in the money Bitcoin Event Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the Bitcoin Index Value calculated and produced 

by the Source Agency on the Expiration Date. The Source Agency shall calculate and produce a Bitcoin 

Index Value once each second throughout the life of the Bitcoin Event Contracts. That is, each second the 

Source Agency will calculate a Bitcoin Index Value by taking by taking all IDCF BIT trade prices occurring 

in the ten (10) seconds leading up to the Calculation Time, provided at least twenty-five (25) trade prices 

are captured during the ten (10) second period, removing the highest twenty (20) percent of IDCF BIT trade 

prices and the lowest twenty (20) percent of IDCF BIT trade prices from the data set, and using the 

remaining IDCF BIT trade prices to calculate the Bitcoin Index Value for that second. The calculation used 

is a simple average of the remaining IDCF BIT trade prices in the data set, rounded to one decimal point 

past the precision of the Underlying market. In the event the time it takes to collect at least twenty-five (25) 

IDCF BIT trade prices exceeds the ten (10) second period, the Bitcoin Index Value will be calculated by 

the Source Agency by taking the last twenty-five (25) IDCF BIT trade prices just prior to the Calculation 

Time, removing the highest five (5) IDCF BIT trade prices and the lowest five (5) IDCF BIT trade prices, 

and using the remaining fifteen (15) IDCF BIT trade prices to calculate the Bitcoin Index Value. The 

calculation used is a simple average of all fifteen (15) IDCF BIT trade prices, rounded to one decimal point 

past the precision of the Underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

RULE 12.88 ETHER CRYPTOCURRENCY EVENT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the Ether Cryptocurrency 

(“Ether” or “ETH”) Event Contracts, referred to as an ‘Event Contract”, issued by the Exchange. 

(b) UNDERLYING – The Underlying for this Class of Contracts is the spot Ether cryptocurrency as 

reported in the ICE® Cryptocurrency Data aggregated by Blockstream® Corporation and distributed by ICE 

Data® Connectivity and Feeds, Inc., herein referred to as “IDCF ETH”, quoted in US dollars.

(c) SOURCE AGENCY – The Source Agency is the Exchange.

(d) TYPE – The Type of Contract is an Event Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set by the Exchange at 

the time the Event Contracts are initially issued. For the Ether Event Contracts, the Payout Criteria for the 

Contracts will be set as follows: 
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(i) DAILY ETHER EVENT CONTRACTS

(1) EXPIRATION TIME – 5 PM Monday thru Thursday; 4 PM Friday.

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 30.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels will be listed 

for each Daily Ether Event Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Event Contract “X” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in 0.25 as reported by the Source 

Agency. Four (4) strike levels will be generated above Event Contract X at an interval of 30, 

and four (4) strike levels will be generated below Event Contract X at an interval of 30 (e.g. X 

– 30; X; X + 30). The Contract will have a Payout Criterion of greater than the strike level value.

(ii) INTRADAY 2-HOUR ETHER EVENT CONTRACTS

(1) EXPIRATION TIME – 8 PM, 9 PM, 10 PM, 11 PM, 12 AM, 1 AM, 2 AM, 3 

AM, 4 AM, 5 AM, 6 AM, 7 AM, 8 AM, 9 AM, 10 AM, 11 AM, 12 PM, 1 PM, 2 PM, 3 PM, 5 

PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level 

shall be 15.

(3) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels will be listed 

for each Intraday 2-Hour Ether Event Contract Series.

(4) STRIKE LEVELS GENERATED - Strike levels will be generated such that 

Event Contract “Y” is valued ‘at-the-money’ in relation to the Underlying market as determined 

by the Source Agency, immediately before the issuance of these Contracts, and shall be 

measured in U.S. cents rounded to the nearest value ending in either 0.00, 0.0025, 0.0050, 0.0075 

as reported by the Source Agency. Four (4) strike levels will be generated above Event Contract 

Y at an interval of 15, and four (4) strike levels will be generated below Event Contract Y at an 

interval of 15 (e.g. Y – 15; Y; Y + 15). The Contract will have a Payout Criterion of greater than 

the strike level value.

(iii) Nadex may list additional Ether Event Contracts with different ranges of Payout Criteria 

on a discretionary basis in accordance with the CEA and Commission Regulations.

(f) MINIMUM TICK – The Minimum Tick size for Ether Event Contracts shall be $0.25.
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(g) POSITION LIMIT – The Position Limits for Ether Event Contracts shall be 2,500 Contracts per 

Class.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the Ether Event 

Contracts for contracted Market Makers shall be 5,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same as the Expiration Date. No 

trading in the Ether Event Contracts shall occur after its Last Trading Date.

(j) SETTLEMENT DATE – The Settlement Date will be the date on which the Ether price as reported 

by the Source Agency.

(k) EXPIRATION DATE – The Expiration Date of the Contract will be the date on which the Ether 

price is released.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the holder of the in the money 

Contract on the Settlement Date. The Settlement Value of an in the money Ether Event Contract is $100.

(m) EXPIRATION VALUE – The Expiration Value is the Ether Index Value calculated and produced 

by the Source Agency on the Expiration Date. The Source Agency shall calculate and produce a Ether Index 

Value once each second throughout the life of the Ether Event Contracts. That is, each second the Source 

Agency will calculate a Ether Index Value by taking by taking all IDCF ETH trade prices occurring in the 

ten (10) seconds leading up to the Calculation Time, provided at least twenty-five (25) trade prices are 

captured during the ten (10) second period, removing the highest twenty (20) percent of IDCF BIT trade 

prices and the lowest twenty (20) percent of IDCF BIT trade prices from the data set, and using the 

remaining IDCF BIT trade prices to calculate the Ether Index Value for that second. The calculation used 

is a simple average of the remaining IDCF BIT trade prices in the data set, rounded to one decimal point 

past the precision of the Underlying market. In the event the time it takes to collect at least twenty-five (25) 

IDCF BIT trade prices exceeds the ten (10) second period, the Ether Index Value will be calculated by the 

Source Agency by taking the last twenty-five (25) IDCF BIT trade prices just prior to the Calculation Time, 

removing the highest five (5) IDCF BIT trade prices and the lowest five (5) IDCF BIT trade prices, and 

using the remaining fifteen (15) IDCF BIT trade prices to calculate the Ether Index Value. The calculation 

used is a simple average of all fifteen (15) IDCF BIT trade prices, rounded to one decimal point past the 

precision of the Underlying market.

(n) CONTINGENCIES – If no level is actually announced on the Expiration Date due to a delay, 

postponement or otherwise in such release announcement by the Source Agency, the Settlement Date will 

be delayed until the Underlying number is released for that Series.

108 If 20% of the data set would result in a non-integer number of trade prices, the number of trade prices to be removed from 

the set will be rounded down. For example, if the number of trade prices collected during the last 10 seconds prior to the 

close of trading was 31, 20% of the data set would be 6.2 trade prices. As 6.2 is a non-integer number, the value will be 

rounded down, and the 6 highest and 6 lowest trade prices will be removed from the data set.
294

End of Rulebook.