23-029

September 29, 2023

VIA PORTAL

Commodity Futures Trading Commission

Attention: Christopher Kirkpatrick, Secretary

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Re: CFTC Regulation 40.6(a) Certification: Submission of Amendments to the 

Nodal Exchange Rulebook

Dear Mr. Kirkpatrick:

Nodal Exchange, LLC (“Nodal Exchange” or “Exchange”) is notifying the Commodity Futures 

Trading Commission (“CFTC” or “Commission”) that it is self-certifying amendments to the 

Nodal Exchange Rulebook (“Rules”) pursuant to Commission Regulation 40.6(a). The 

Exchange is amending Appendix A – Contract Specifications for all Power Futures. The 

Exchange intends to implement the amended Rules on or after October 20, 2023.

For all Power Futures Day Ahead contracts, the Exchange is amending the Last Trading 

Date from “The third (or fourth/sixth, depending on the ISO) business day following the 

last calendar day of the month” to “Last business day of the contract period”. In addition, 

the Exchange is amending the Final Settlement Date from “The first business day following 

the Last Trading Day” to “The third (or fourth/sixth, depending on the ISO) business day 

following the last calendar day of the month”. 

For all Power Futures Real Time contracts, the Exchange is amending the Last Trading Date 

from “The third (or fourth/sixth, depending on the ISO) business day following the last 

calendar day of the month” to “The first business day of the month following the contract 

period”. In addition, the Exchange is amending the Final Settlement Date from “the first 

business day following the Last Trading Day” to “The third (or fourth/sixth, depending on 

the ISO) business day following the last calendar day of the month”.

Exchange management has assessed the amendments to the Rules, and their compliance 

with applicable provisions of the Act, including the Commissions Regulations and the Core 

Principles. Nodal Exchange has identified that the amendments may affect the following 

Core Principles as follows:
23-029

Core Principle 2 – Compliance with the Rules: The amendments to the Rules provide 

clarity and consistency with the Act for compliance with the Rules. Appendix A is applicable 

to all Nodal Exchange Participants.

Core Principle 3 – Contracts Not Readily Subject to Manipulation: The applicable Power

Futures contracts are not readily subject to manipulation and are based on established and 

liquid underlying cash markets. Trading of the contracts is monitored by the Exchange.

Core Principle 7 – Availability of General Information: The amendments to the Rules 

provide clarity to Exchange Participants. The amended Rules are available to market 

authorities, Participants, Authorized Brokers and the public on the Exchange website.

Core Principle 11 – Financial Integrity of Transactions: The applicable Power Futures 

contracts will continue to be cleared by Nodal Clear, a registered derivatives clearing 

organization subject to Commission regulation, and carried by qualified futures merchants. 

Pursuant to Section 5c(c) of the Act and the Commission’s Regulation 40.6, the Exchange 

certifies that amended Rules comply with the Act and the Commission’s Regulations 

thereunder. There have not been any opposing views expressed regarding the amendments 

to the Rules.

Nodal Exchange certifies that this submission has been concurrently posted on the Nodal 

Exchange website at www.nodalexchange.com.

If you have any question or need additional information regarding this submission, please 

contact me at 703-962-9853 or Markotic@nodalexchange.com.

Sincerely,

/s/ Max Markotic

Managing Director

Attachment:

• Exhibit A: Nodal Exchange Appendix A - Contract Specifications REDLINE

• Exhibit B: List of contracts