Market Maker Agreement

crypto.com | Derivatives North America

200 West Jackson Blvd., Suite 1400

Chicago, IL 60606

 

Market Maker Agreement, September 2022

This Market Maker Agreement (“Agreement”) is entered into 

between North American Derivatives Exchange, Inc. d/b/a 

crypto.com | Derivatives North America, a designated contract 

market and derivatives clearing organization incorporated in 

Delaware, with its principal place of business at 200 West 

Jackson Blvd., Suite 1400, Chicago, Illinois 60606, and 

__________________________________,

 

a [corporation/limited liability company] organized under the 

laws of the State of ___________, with its principal place of 

business at ________________________________________,

(“Market Maker”), (together, the “Parties”) as of 

______________________, 20____(the “Effective Date”). 

Capitalized terms not expressly defined in this Agreement shall 

have the meaning ascribed to them in the crypto.com | 

Derivatives North America Rules.

1 CONTROLLING PROVISIONS; CONDITION PRECEDENT

(a) All of the terms and conditions contained in the Membership 

application process, as well as in the crypto.com | Derivatives 

North America Rules, shall regulate all exchange trading 

activities of a Market Maker unless otherwise provided for in this 

Agreement, in which case this Agreement shall be controlling. 

(b) For avoidance of doubt, Market Maker may not function as a 

Market Maker under this Agreement unless Market Maker is a 

Member of crypto.com | Derivatives North America, and 

notwithstanding any other provision of this Agreement, Market 

Maker being a Member shall be a condition precedent to the 

effectiveness of this Agreement.

(c) Market Maker and crypto.com | Derivatives North America

shall agree to the specific Classes, as identified in Appendix A 

to this Agreement, for which Market Maker will be obligated to 

provide liquidity (“Designated Classes”).

2 MARKET MAKER OBLIGATIONS

(a) Beginning on the Effective Date, and except as otherwise 

provided for in the Agreement (including any Appendix thereto) 

or on the crypto.com | Derivatives North America website, the 

Market Maker shall quote binding bid and offer prices

throughout the duration of the listed Contracts in Market Maker’s 

Designated Classes, which shall be submitted as Post-Only 

Quotes as that term is defined in the crypto.com | Derivatives 

North America Rules, at or inside of the defined maximum 

spread (“Defined Spread”) and not less than the defined 

minimum size (“Defined Size”). Market Maker shall not submit 

Non Post-Only Orders as that term is defined by the crypto.com 

| Derivatives North America Rules.

(b) The Market Maker acknowledges and agrees not to engage 

in any activity that would violate the Commodity Exchange Act, 

as amended (the “Act”), or the Commission’s regulations 

adopted thereunder, or crypto.com | Derivatives North America

Rules or terms of its Membership Agreement. The Market Maker 

also understands and agrees that this Agreement may be 

unilaterally modified or cancelled by crypto.com | Derivatives 

North America for any reason if directed to do so by the 

Commodity Futures Trading Commission (the “Commission”) in 

order to comply with the Act or the Commission’s regulations 

adopted thereunder. 

(c) Market Maker shall not knowingly employ any Authorized 

Traders who are subject to statutory disqualification under 

Section 8a(3) of the Act.

(d) Market Maker shall notify crypto.com | Derivatives North 

America within 24 hours of the addition or deletion of any 

Authorized Traders for their account at crypto.com | Derivatives 

North America. All Authorized Traders may engage in Market 

Making activity on the exchange only via their assigned 

username.

(e) Market Maker is obligated to respond to any crypto.com | 

Derivatives North America request for information regarding 

their Market Making activity on the exchange.

3 SUSPENSION OF MARKET MAKER OBLIGATIONS

(a) Market Maker shall not be required to act in accordance with 

Section 2(a) quoting requirements and may suspend all quoting 

during the occurrence of any of the following events 

(“Suspension Event”):

(i) the calculation of the Derived Underlying Market 

Data corresponding to a Designated Class has 

been suspended;

(ii) there is no direct Underlying market for a Designated 

Class or no related market or event upon which to 

base the prices for a Designated Class;

(iii) there exists in the reasonable opinion of crypto.com 

| Derivatives North America and Market Maker such 

a change, whether or not foreseeable, in national or 

international financial, political, or economic 

conditions as would in crypto.com | Derivatives 

North America and Market Maker’s view make it 

impossible to accurately price Contracts in the 

Designated Class;

(iv) an act of God, war, terrorism, fire, flood, civil 

disturbance, or act of any governmental authority 

beyond the control of the Market Maker or 

crypto.com | Derivatives North America occurs 

which prevents the Market Maker from entering 

Post-Only Quotes or prevents the Market Maker’s

ability to fulfil its obligations as described herein;

(v) where any interruption, defect, withdrawal or failure 

of power supply, trading systems, network, internet 

connections, computer systems, communications 

(whether owned or operated by Market Maker, 

crypto.com | Derivatives North America or any third 

party) or other similar force majeure event prevents 

the Market Maker from entering Post-Only Quotes or 
crypto.com | Derivatives North America

200 West Jackson Blvd., Suite 1400

Chicago, IL 60606

 

Market Maker Agreement, September 2022

prevents the Market Maker’s ability to fulfil its 

obligations as described herein; or

(vi) Market Maker has a position in any Designated 

Class or Contract that equals or exceeds 90% of the 

applicable position limit for such Designated Class 

or Contract; or

(vii) as otherwise specifically provided for in this 

Agreement, including any Appendix thereto.

(b) The Parties will each inform the other by telephone and 

subsequently by email as soon as practicable after either of 

them becomes aware that they believe any of the foregoing 

Suspension Events is occurring or has occurred, or ceases to 

exist. With respect to any Suspension Event pursuant to Section 

3(a)(v) that extends for more than 20 minutes in any Contract or 

Designated Class, Market Maker must also file a Market Maker 

Issue/Disruption Notification within 48 hours of the suspension 

with details of the event, or, if the full details of the event remain 

unknown after 48 hours, the Market Maker must update 

crypto.com | Derivatives North America as to the findings of its 

investigation within 48 hours and provide a final Issue/Disruption 

Notification as soon as practicable, but no later than 7 calendar 

days following the Suspension Event. Any investigation 

requiring more than 7 calendar days must be discussed with 

crypto.com | Derivatives North America prior to the reporting 

deadline. 

4 MODIFICATION OF MARKET MAKER OBLIGATIONS

(a) Market Maker shall not be required to act in accordance with 

Section 2(a) quoting requirements and may modify quoting as 

specified below during the occurrence of any of the following 

events (“Modification Event”):

(i) Expiry Period – Market Maker may refrain from 

submitting Post-Only Quotes during these periods,

as described below, for any particular Contract, 

just prior to expiry of that Contract (“Expiry 

Period”). A Market Maker that chooses to submit 

Post-Only Quotes during an Expiry Period will be 

required to comply with the Defined Spread and 

Defined Size requirements as set forth in 

Appendix A.

a. The five (5) minute period just prior to expiry 

of any Event Contract;

b. the two (2) minute period just prior to expiry of 

any Intraday, Daily, or Weekly Contract, with 

the exception of the Intraday 5-Minute and 20-

Minute, and Touch Bracket Contracts; 

c. the one (1) minute period just prior to the 

expiry of any Intraday 5-Minute or Intraday 

20-Minute Contract; and

d. the thirty (30) second period just prior to the 

expiry of any Weekly Touch Bracket 

Contract.

(ii) Economic Announcement or Unusual Market

Period – Market Maker may refrain from 

submitting Post-Only Quotes during any Economic 

Announcement or Unusual Market Period, as 

defined below. A Market Maker that chooses to 

submit Post-Only Quotes during an Economic 

Announcement or Unusual Market Period will be 

required to comply with the Defined Spread and 

Defined Size requirements as set forth in 

Appendix A.

a. The five (5) minutes prior to the scheduled 

announcement and the five (5) minutes after 

the announcement of any major economic 

indicator; or

b. any unusual market condition or price 

volatility which is determined by crypto.com | 

Derivatives North America, acting reasonably 

and in consultation with Market Maker, to 

prevent the maintenance of an orderly 

market.

(iii) Two-Sided Markets – Market Maker will not be 

required to price a two-sided market, and will be 

permitted to reduce its size below the Defined Size 

requirements (including to 0). 

a. In any Binary Contract within a Designated 

Class that is so deep in-the-money as to be 

valued at $100 offer or so deep out-of-themoney as to be valued at zero ($0) bid. 

Specifically, when the Market Maker’s bid is 

within the maximum spread of the ceiling or 

the Market Maker’s offer is within the 

maximum spread of the floor;

b. in any Call Spread Contract within a 

Designated Class when the underlying for 

that Call Spread Contract is outside the range 

of the Call Spread Contract;

c. in any Touch Bracket Contract when the 

Index Value is within 10 ticks of the Touch 

Bracket Contract’s Cap or Floor; or

d. during the first 30 seconds and last 30 

seconds of any Intraday 5-Minute Binary 

Contract; or

e. as otherwise specifically provided for in this 

Agreement, including any Appendix thereto.

(iv) Illiquid Markets – Market Maker may refrain from 

submitting Post-Only Quotes during a period of 

illiquid underlying markets defined as, thinly traded 

markets in particular time periods as determined 

by crypto.com | Derivatives North America from 

time to time and made public via posting on its 

website. A Market Maker that chooses to submit 

Post-Only Quotes during an Illiquid Market period 

will be required to comply with the Defined Spread 

and Defined Size requirements as set forth in 

Appendix A.

(b) crypto.com | Derivatives North America may amend the 

definitions of Modification Events and its applicable Rules 

unilaterally by providing 10 days’ written notice to the Market 

Maker. To the extent reasonably possible and practicable, 

crypto.com | Derivatives North America will consult with the 

Market Maker and other relevant Market Makers prior to 

amending its Modification Events Rules.

5 CONFIDENTIALITY

(a) Confidential Information means all information, whether 

written or oral, and in any form (including, without limitation, 

engineering documents, research and development, manuals, 
crypto.com | Derivatives North America

200 West Jackson Blvd., Suite 1400

Chicago, IL 60606

 

Market Maker Agreement, September 2022

reports, designs, drawings, plans, flowcharts, software (in 

source or object code), program listings, data file printouts, 

processes, component part listings and prices, product 

information, new product plans, sales and marketing plans 

and/or programs, pricing information, customer lists and other 

customer information, financial information and employee files 

or other employee information) relating to the disclosing party’s 

business or technology to receiving party.

(i) The term “Confidential Information” also shall be 

deemed to include: 

a. all notes, analyses, compilations, studies, 

interpretations, or other documents prepared 

by recipient or its representatives that contain, 

reflect or are based upon in whole or in part, 

the information furnished by or on behalf of 

disclosing party to recipient pursuant hereto; 

and

b. Confidential Information disclosed prior to, as 

of, or after the date of this Agreement.

(ii) Confidential Information does not include 

information; 

a. lawfully received from third parties without 

confidentiality obligation to the disclosing 

party; 

b. in the public domain other than through 

breach of the obligation of confidentiality 

imposed by this Agreement; 

c. independently developed without use of the 

other party’s Confidential Information; or 

d. is lawfully known to the recipient without an 

obligation of confidentiality the time recipient 

receives the same from the disclosing party, 

as evidenced by written records. 

(b) Return of Confidential Information. Promptly upon the 

written request of the discloser, the recipient shall, and shall 

cause its representatives to, return to the discloser, or destroy 

all Confidential Information. If the recipient destroys the 

Confidential Information, it shall certify that it has done so in 

writing and promptly deliver that certificate to discloser. Despite 

the provisions of this Section 5(b), the recipient may retain one 

permanent file copy of the Confidential Information of the 

discloser and any derivative materials if required to do so under 

any state or federal law or regulation.

(c) Obligations of Confidentiality.

(i) Each party will

a. use the other’s Confidential Information solely 

to perform its obligations under this 

Agreement, and disclose the other’s 

Confidential Information only to its agents, 

contractors, and employees legally bound, in 

writing, to keep Confidential Information 

confidential and only to the extent necessary 

for them to perform this Agreement;

b. in no event use less than ordinary care to 

protect the other’s Confidential Information 

against unauthorized disclosure to any third 

party; and

c. notify the other of unauthorized use, 

disclosure, theft or other loss of Confidential 

Information of which it learns.

(ii) Confidential Information may be disclosed as 

required by law, provided that prior to any such 

disclosure, the recipient will

a. assert the confidential nature of the 

Confidential Information to the court or 

agency; 

b. provide sufficient notice to the disclosing party 

to permit it to contest the disclosure 

requirement; and 

c. cooperate with the disclosing party, at the 

disclosing party’s expense, in protecting 

against any such disclosure and/or obtaining 

a protective order narrowing the scope of the 

compelled disclosure and protecting its 

confidentiality. 

(d) Survival. Despite any other provision of this Agreement, this 

entire Section 5 Confidentiality survives any termination of this 

Agreement. 

6 FEES

(a) The Market Maker will pay a fee of $_________in order to 

establish a dedicated line.

(b) The Market Maker shall pay to crypto.com | Derivatives North 

America transaction-based Exchange Fees as determined and 

published by crypto.com | Derivatives North America from time 

to time during the Term of the Agreement. “Exchange Fees” 

comprise all fees relating to the execution and settlement of 

transactions on the exchange, including, but not limited to, 

trading and settlement fees. Further, Market Makers are subject 

to additional fees as noted in the crypto.com | Derivatives North 

America Fee Schedule.

7 MINIMUM DEPOSIT AND MAINTENANCE AMOUNT

(a) Market Maker is required to have an initial Minimum Deposit 

of $500,000 and a Maintenance Amount of $250,000: 

(b) In this Section, “Minimum Deposit” means the amount the 

Market Maker must initially deposit in order to establish an 

account at crypto.com | Derivatives North America and 

“Maintenance Amount” means the minimum amount that must 

be in the Market Maker’s account at all times. In the event the 

Market Maker’s available cash balance falls to the Maintenance 

Amount, the Market Maker must immediately deposit sufficient 

funds to bring the available cash balance to $500,000.

(c) Market Maker cannot withdraw funds from its crypto.com | 

Derivatives North America account if, after such withdrawal, its 

crypto.com | Derivatives North America available cash balance 

would be less than $500,000, except on termination of 

Agreement.

8 ASSIGNMENT

Neither this Agreement, nor any of the rights or obligations under 
crypto.com | Derivatives North America

200 West Jackson Blvd., Suite 1400

Chicago, IL 60606

 

Market Maker Agreement, September 2022

this Agreement, may be assigned or transferred by either party 

without the express prior written consent of the other party.

9 TERM OF AGREEMENT

The term of this Agreement shall be for a term of one year 

(“Initial Term”), as of the Effective Date. This Agreement shall 

be automatically renewed annually after the Initial Term 

(collectively “Term”) unless terminated pursuant to Section 10 of 

this Agreement.

10 TERMINATION

(a) This Agreement may be terminated immediately by 

crypto.com | Derivatives North America in the event that (i) all 

products in the Market Maker’s Designated Classes have been 

delisted, (ii) the Market Maker makes a material statement which 

is untrue or made in bad faith, (iii) crypto.com | Derivatives North 

America is so ordered by the Commission, (iv) the Market Maker 

does not satisfy the terms of the Agreement, or (v) the Market 

Maker breaches a material provision of this Agreement or 

commits a major offense. 

(b) This Agreement may be terminated by either party for any 

reason provided the terminating party provides 30 days written 

notice to the non-terminating party.

(c) This Agreement will terminate if and when the Market 

Maker’s crypto.com | Derivatives North America Membership 

terminates.

11 AMENDMENTS

This Agreement, and any Appendix thereto, may be amended 

from time to time by crypto.com | Derivatives North America with 

at least 10 business days’ notice to the Market Maker. Market 

Maker’s Designated Classes may be amended from time to time 

by agreement of the Parties.

MARKET MAKER

Signed for and on behalf of Market Maker:

By: __________________________________________

Print Name: ___________________________________

Title: _________________________________________

Date: _____________________________________________

12 WAIVER OF COMPLIANCE

Any failure of a party to comply with any obligation herein may

be expressly waived in writing by the other party to this 

Agreement, but such waiver or failure to insist upon strict 

compliance with such obligation shall not operate as a waiver of, 

or estoppel with respect to, any subsequent or other failure.

13 MANDATORY ARBITRATION

Any controversy or claim arising out of or in connection with this 

Agreement or the performance or breach hereof, or relating to 

designation as a Market Maker, including any claim against 

crypto.com | Derivatives North America, the crypto.com | 

Derivatives North America settlement bank, or any other 

crypto.com | Derivatives North America Member or Market 

Maker, shall be settled by arbitration as set forth in the 

crypto.com | Derivatives North America Rules. 

14 CHOICE OF LAW

THIS AGREEMENT SHALL BE CONSTRUED IN 

ACCORDANCE WITH, AND ALL DISPUTES HEREUNDER 

SHALL BE GOVERNED BY, THE LAWS OF THE STATE OF 

ILLINOIS AS APPLIED TO CONTRACTS MADE AND 

TO BE PERFORMED IN ILLINOIS, WITHOUT APPLYING 

CONFLICT OF LAW RULES.

By signing this Agreement, Market Maker accepts full 

responsibility for having knowledge of and adhering 

to all rules and regulations governing crypto.com | 

Derivatives North America.

NORTH AMERICAN DERIVATIVES EXCHANGE, INC.

D/B/A CRYPTO.COM | DERIVATIVES NORTH 

AMERICA

Signed for and on behalf of North American Derivatives 

Exchange, Inc.:

By: __________________________________________

Print Name: ___________________________________

Title: _________________________________________

Date: _____________________________________________
 APPENDIX A

5 Nadex Market Maker Agreement, Appendix A, January 2024

DESIGNATED CLASSES – THIS APPENDIX A ACCOMPANIES THE NADEX MARKET MAKER AGREEMENT.

Market Maker/Member Name: 

Market Maker/Member Username: 

The following is a list of the Designated Classes for which the above-named Member has requested to be assigned as a Market Maker and the 

Defined Spread and Defined Size applicable to the Designated Classes in accordance with Chapter 4 of the Nadex Rulebook and this Market 

Maker Agreement.1, 2

Designated Classes

Binary Contracts

Section 4(a)(i) –

Expiry Period 

Section 4(a)(iv) –

Illiquid Markets3

Maximum 

Defined 

Spread4

Minimum 

Defined Size5

Execution and 

Settlement Fees

Position 

Limits (per 

Strike)

Currencies6: Intraday 2-Hour, 

Daily, and Weekly

▪ EUR/USD Binary

▪ GBP/USD Binary

▪ USD/JPY Binary

▪ USD/CHF Binary

▪ USD/CAD Binary

▪ EUR/JPY Binary

▪ GBP/JPY Binary

▪ AUD/USD Binary

▪ EUR/GBP Binary

▪ AUD/JPY Binary

▪ USD/MXN Binary 

Currencies7: Intraday 5-

Minute

▪ EUR/USD Binary

▪ GBP/USD Binary

1 Market Maker shall make a good faith best effort to price equivalent markets in the Nadex Demo/Practice environment but will not be held to the maximum Defined 

Spread and minimum Defined Size requirements set forth in this Appendix. 

2 Market Maker will not be deemed to have violated the maximum defined spread obligation in any Foreign Currency or Crypto Currency product if the maximum 

bid/ask spread was exceeded for a duration of less than 15 seconds, or if in the reasonable opinion of Nadex the maximum bid/ask spread was exceeded as the 

result of underlying market illiquidity, underlying market volatility, if the maximum bid/ask spread was exceeded during a period in which the relevant underlying 

Foreign Currency or Crypto currency market quote spreads were experiencing wider than normal bid / offer quote spreads in the relevant underlying market or if 

the underlying market in the binary products, in the reasonable opinion of Nadex, is considered at-the-money, within one minute prior to contract expiration.

3 Nadex has identified the following products and time periods as Illiquid Markets: All Intraday 5-Minute, Intraday 2-Hour, Daily, and Weekly, Foreign Currency 

Binary contracts available for trading, at times the Exchange is open, between the hours of 2:00PM ET and 3:00AM ET.

4 Market Maker will not be deemed to have violated the maximum defined spread obligation in the event the maximum bid/ask spread is exceeded as the result of 

the adjustment of a Post-Only (Price Adjustment) quote by the Exchange. If a Market Maker submits a cancel rather than a post adjusted price, the Market Maker 

is relieved of their quoting requirements in that particular contract until the Market Maker’s quotes are no longer needed to be post adjusted.

5 A quote that has been executed partially or in full shall be replenished to the Defined Size as soon as reasonably practical, as determined by Nadex.

6 For any Foreign Currency Binary Contract, Market Maker may widen the maximum spread to 25% during the last 15 minutes prior to the expiration of that Contract, 

or as otherwise defined in the Market Maker Agreement. Market Maker is not required to submit quotes during Suspension or certain Modification Events, however, 

if the Market Maker chooses to submit quotes during this time period, the Market Maker must comply with the obligations as defined in the Market Maker Agreement 

and this Appendix. 

7

If a Market Maker holds a position of 100 contracts (50 contracts during Illiquid Market hours), net long or short, in any 5-minute Foreign Binary Currency contract, 

Market Maker will not be required to adhere to the maximum Defined Spread, two-sided market quotes or minimum Defined Size obligations. 
 

 6 Nadex Market Maker Agreement, Appendix A, January 2024

▪ USD/JPY Binary

▪ AUD/USD Binary

▪ USD/CAD Binary

▪ GBP/JPY Binary

▪ EUR/JPY Binary

Commodities: Intraday 2-

Hour, Daily, and Weekly

▪ Gold Binary

▪ Silver Binary

▪ Crude Oil Binary

▪ Natural Gas Binary

Indices: Intraday 2-Hour, 

Daily, and Weekly

▪ US 500 Binary

▪ US SmallCap 2000 

Binary

▪ US Tech 100 

Binary

▪ Wall Street 30 

Binary

▪ Japan 225 Binary 

(No Intraday)

Indices: Intraday 20-Minute

▪ US 500 Binary

▪ US SmallCap 2000 

Binary

▪ US Tech 100 

Binary

▪ Wall Street 30 

Binary

Crypto Currencies8: Intraday 

20-Minute – ($10)

▪ Bitcoin Binary

▪ Ether Binary

▪ Litecoin Binary

▪ Bitcoin Cash Binary

▪ Dogecoin Binary

▪ Shiba Inu Binary

▪ Avalanche Binary

▪ Chainlink Binary

▪ Polkadot Binary

8

In the Crypto Currency binary markets, in any 20-Minute and 2-hour contract listing, a Market Maker is not required to quote a minimum defined size nor quote 

a two-sided market, for first 30 seconds and last 30 seconds of each 20-Minute and 2-hour contract listing; during the last 60 seconds if two-sided quotes are 

submitted, the maximum defined spread is increased to 40%
 

 7 Nadex Market Maker Agreement, Appendix A, January 2024

Crypto Currencies9,

10:

Intraday 2-Hour – ($10)

▪ Bitcoin Binary

▪ Ether Binary

▪ Litecoin Binary

▪ Bitcoin Cash Binary

▪ Dogecoin Binary

▪ Shiba Inu Binary

▪ Avalanche Binary

▪ Chainlink Binary

▪ Polkadot Binary

Designated Classes

Call Spread Contracts

Section 4(a)(i) –

Expiry Period

Section 4(a)(iv) –

Illiquid Markets

Maximum 

Defined 

Spread11

Minimum 

Defined Size

Execution and 

Settlement Fees

Position 

Limits (per 

Strike)

Daily Wide and Daily Narrow, 

8 or 8.25-Hour, and Intraday 

2-Hour 

▪ Silver Call Spread 

(Daily Wide and 

Daily Narrow, 5.5-

Hour, and Intraday 

2-Hour)

Daily Wide and Daily Narrow, 

8 or 8.25-Hour, and Intraday 

2-Hour 

▪ Wall Street 30 Call 

Spread

▪ US 500 Call Spread

▪ US SmallCap 2000 

Call Spread

▪ US Tech 100 Call 

Spread

9

In the Crypto Currency binary markets, during the last two minutes of trading in any 20-Minute and 2-hour contract listing, Market Makers are allowed to 

decrease their minimum quote quantity to 100 lots per side. Any quoting by Market Maker must comply with the maximum Defined Spread.

10 If a Market Maker holds a position of 3000 contracts, net long or short, in any 20-Minute and 2-hour contract listing Crypto Currency binary contract, Market 

Maker will not be required to adhere to the maximum Defined Spread, two-sided market quotes or minimum Defined Size obligations. 

11 Market Maker will not be deemed to have violated the maximum Defined Spread obligation in the event the maximum bid/ask spread is exceeded as the result 

of the adjustment of a Post-Only (Price Adjustment) quote by the Exchange. If a Market Maker submits a cancel rather than a post adjusted price, the Market 

Maker is relieved of their quoting requirements in that particular contract until the Market Maker’s quotes are no longer needed to be post adjusted.
 

 8 Nadex Market Maker Agreement, Appendix A, January 2024

▪ Gold Call Spread 

(Daily Wide and 

Daily Narrow, 5.5-

Hour, and Intraday 

2-Hour)

▪ Crude Oil Call 

Spread 

(Daily Wide and 

Daily Narrow 6.5-

Hour, and Intraday 

2-Hour)

▪ Natural Gas Call 

Spread 

(Daily Wide and 

Daily Narrow, 6.5-

Hour, and Intraday 

2-Hour)

▪ Japan 225 

(Daily Wide and 

Daily Narrow)

Weekly, Daily, 8-Hour, 5-

Hour, and Intraday 2-Hour 

▪ AUD/USD Call 

Spread

▪ EUR/JPY Call 

Spread

▪ EUR/USD Call 

Spread

▪ GBP/JPY Call 

Spread

▪ GBP/USD Call 

Spread

▪ USD/JPY Call 

Spread

▪ USD/CHF Call 

Spread

▪ USD/CAD Call 

Spread

▪ EUR/GBP Call 

Spread

(Weekly and Daily 

Only)

▪ AUD/JPY Call 

Spread

(Weekly and Daily 

Only)

Designated Classes Section 4(a)(i) –

Expiry Period 

Section 4(a)(iv) –

Illiquid Markets

Maximum 

Defined 

Spread

Minimum 

Defined Size Execution and 

Settlement Fees

Position 

Limits (per 

Strike)
 

 9 Nadex Market Maker Agreement, Appendix A, January 2024

Touch Bracket 

Contracts12,

13

▪ EUR/USD Touch 

Bracket

▪ GBP/USD Touch 

Bracket

▪ USD/CHF Touch 

Bracket

▪ USD/JPY Touch 

Bracket

▪ AUD/USD Touch 

Bracket

▪ EUR/JPY Touch 

Bracket

▪ GBP/JPY Touch 

Bracket

▪ USD/CAD Touch 

Bracket

▪ EUR/GBP Touch 

Bracket

▪ AUD/JPY Touch 

Bracket

▪ US 500 Touch 

Bracket

▪ US SmallCap 2000 

Touch Bracket

▪ US Tech 100 Touch 

Bracket

▪ Wall Street 30 

Touch Bracket

▪ Gold Touch Bracket

▪ Silver Touch 

Bracket

▪ Crude Oil Touch 

Bracket

▪ Natural Gas Touch 

Bracket

▪ Bitcoin Touch 

Bracket

▪ Ether Touch 

Bracket

▪ Litecoin Touch 

Bracket 

▪ Bitcoin Cash Touch 

Bracket

12 If Market Maker holds a position of 1,000 contracts, net long or short, in any Touch Bracket Contract, Market Maker will not be required to adhere to the maximum 

Defined Spread, two-sided market quotes, or minimum Defined Size obligations. 

13 A Market Maker will not be deemed to have violated the maximum defined spread obligation in the event the maximum bid/ask spread is exceeded as the 

result of the adjustment of a Post-Only (Price Adjustment) quote by the Exchange. If a Market Maker submits a cancel rather than a post adjusted price, the 

Market Maker is relieved of their quoting requirements in that particular contract until the Market Maker’s quotes are no longer needed to be post adjusted. Market 

Maker is relieved of quoting obligations if the Index Value for any Crypto Currency Touch Bracket is within 20 ticks, or if the Index Value for any other Touch 

Bracket Contracts excluding Crypto Currency contracts is within 10 ticks of the Touch Bracket Contract Cap or Floor. A Market Maker is allowed to submit a onesided quote during the period when the Index Value for any Crypto Currency Touch Bracket is within 20 ticks, or if the Index Value for any other Touch Bracket 

Contract excluding Crypto Currency contracts is within 10 ticks, of the Touch Bracket Contract Cap or Floor; however, the bid or offer quote must be within the 

Maximum quote spread from the floor or ceiling for that given contract.
 

 10 Nadex Market Maker Agreement, Appendix A, January 2024

▪ Dogecoin Touch 

Bracket

▪ Shiba Inu Touch 

Bracket

▪ Avalanche Touch 

Bracket

▪ Chainlink Touch 

Bracket

▪ Polkadot Touch 

Bracket

Exemptions Product Exemption Duration

Market Maker is exemption from quoting in 

the following products:

NORTH AMERICAN DERIVATIVES EXCHANGE, INC.

Signed for and on behalf of Nadex:

_____

Print Name: _____

Title: _____

Date: _____

MARKET MAKER

Signed for and on behalf of Market Maker:

_____

Print Name: _____

Title: _____

Date: _____