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Jaime M. Walsh

+1 (312) 884-0927

Jaime.walsh@nadex.com

No. 20220916(1)

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September 16, 2022

Via CFTC Portal Submissions

Mr. Christopher Kirkpatrick

Secretary of the Commission

Office of the Secretariat

Commodity Futures Trading Commission

3 Lafayette Centre 

1155 21st Street, N.W. 

Washington D.C. 20581

RE: Rule Certification: Nadex Delists FTSE 100 Variable Payout and Binary Contracts

- Submission Pursuant to Commission Regulation §40.6(a)

Dear Mr. Kirkpatrick:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (the “Act”), and 

§40.6(a) of the regulations promulgated by the Commodity Futures Trading Commission (the 

“Commission”) under the Act, North American Derivatives Exchange, Inc. (“Nadex” or the 

“Exchange”) hereby submits to the Commission its intent to delist all of its FTSE 100 Variable 

Payout and Binary Contracts. Specifically, Nadex will be delisting the following contracts:

RULE 12.48 FTSE 100® FUTURE VARIABLE PAYOUT CONTRACTS

RULE 12.49 FTSE 100® FUTURE BINARY CONTRACTS

 As §40.6(a) exempts the delisting of a product from the 10-day review period, Nadex will 

delist the aforementioned contracts effective at the close of business on trade date Friday, 

September 16, 2022.

As of the close of business on September 16, 2022, all FTSE 100 Variable Payout and

Binary Contracts will have expired and no open positions or working orders will exist in the Nadex

market. 

Amendments to the Rulebook to remove the relevant contract specifications have been 

outlined in Exhibit A. Specific amendments are set forth in Exhibit B. Any deletions are stricken 

out while the amendments and/or additions are underlined.

Nadex hereby certifies that the additions contained herein comply with the Act, as 

amended, and the Commission Regulations adopted thereunder. No substantive opposing views 
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were expressed to Nadex with respect to any of these actions. Nadex hereby certifies that notice 

of these events was posted on its website at the time of this filing.

Should you have any questions regarding the above, please do not hesitate to contact me 

by telephone at (312) 884-0927 or by email at jaime.walsh@nadex.com.

 

 Sincerely, 

 Jaime M. Walsh

 Head of Legal
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EXHIBIT A

Rule Asset Duration/Close Time Action Effective 

Date

12.48 FTSE 100 Future 

Variable Payout 

Contracts

All Contracts Delist contracts COB 

September 16, 

2022

12.49 FTSE 100 Future 

Binary Contracts

All Contracts Delist contracts COB 

September 16, 

2022
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EXHIBIT B

Amendment of Rules 12.48 - 12.49

(The following Rule amendments are underlined and deletions are stricken out)

RULES 1.1 – 12.47 [UNCHANGED]

RULES 12.48 – 12.53 [RESERVED]

RULE 12.48 FTSE 100® FUTURE VARIABLE PAYOUT CONTRACTS

(a) SCOPE –These Rules shall apply to the Class of Contracts referred to as the FTSE 

100 Future Variable Payout Contracts issued by Nadex. 

(b) UNDERLYING – The Underlying for this Class of Contracts is the price (in British 

Pounds) of the FTSE 100 Futures contracts (“FFC”) traded on the ICE Futures Europe® exchange 

(IFE).1 The FFC trade prices that will be used for the Underlying will be taken from four (4) FFC 

delivery months: March, June, September, or December (each a “FFC 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 IFE FTSE 100 March 2012 futures have an Expiration Date of March 16, 2012. The 

last day on which the FTSE100 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 

FTSE 100 contracts will be the Monday of the week of the IFE FTSE 100 March 2012 futures 

contracts Expiration Date (i.e. March 16, 2012). Therefore, the End Date for using IFE FTSE 

100 March 2012 futures will be March 12, 2012 and the Start Date for the next delivery month, 

IFE FTSE 100 June 2012 futures, will be March 13, 20122. 

1

FTSE® and FTSE 100® are trademarks of the London Stock Exchange Group (“LSE”). The prices relating to any 

index are not in any way sponsored, endorsed or promoted by FTSE or by the LSE and neither FTSE nor LSE 

makes any warranty or representation whatsoever, expressly or impliedly, either as to the results to be obtained from 

the use of such prices and/or the figure at which any index stands at any particular time on any particular day or 

otherwise. Neither FTSE nor LSE shall be liable (whether in negligence or otherwise) to any person for any error in 

any index and neither FTSE nor LSE shall be under any obligation to advise any person of any error therein. The 

FTSE Future Binary Option Contracts are not sponsored, endorsed, sold or promoted by FTSE or LSE. Neither 

FTSE nor LSE accept any liability in connection with the trading of these products. ICE Futures Europe® is a 

registered mark of Intercontinental Exchange Holdings, Inc. (“ICE Holdings”). Nadex is not affiliated with ICE 

Futures Europe® or ICE Holdings, and the FTSE 100 Future Binary Option Contracts are not sponsored, endorsed, 

sold or promoted by ICE Futures Europe® or ICE Holdings in any way.

2 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 IFE FTSE 100® March 2012 Underlying futures is March 12, 

2012. March 12, 2012 is a Monday, however, and any Nadex weekly contracts listed on this date and expiring on 

Friday, March 16, 2012, will be listed using the IFE FTSE 100® June 2012 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
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(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 FTSE 100 Future Variable 

Payout Contract, the Payout Criteria for the Contracts will be set as follows:

(i) DAILY FTSE 100® FUTURE CALL SPREAD 

VARIABLE PAYOUT CONTRACTS, 4:00 PM ET CLOSE - At the commencement 

of trading in a Daily FTSE 100 Future 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 FTSE 100® FUTURE CALL SPREAD CONTRACT 

(aa) CEILING – The Ceiling shall be X + 200.

(bb) FLOOR – The Floor shall be X – 200.

(cc) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1. 

(2) In each case, “X” equals the last FTSE 100 Future price, as reported by the Source 

Agency, rounded to the nearest 100.

(ii) DAILY FTSE 100® FUTURE CALL SPREAD 

CONTRACTS, 4:00 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 – 200.

(2) CONTRACT 2: The Ceiling shall be X + 100; The Floor shall be X – 100.

(3) CONTRACT 3: The Ceiling shall be X + 200; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

(5) In each case, “X” equals the last FTSE 100 Future price, as reported by the Source 

Agency, rounded to the nearest 100.

(iii) INTRADAY FTSE 100® FUTURE CALL SPREAD 

CONTRACTS, 8AM ET to 4:00 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: 

expiration date. Therefore, the Start Date for the IFE FTSE 100 June 2012 futures will be Monday, March 12, 2012 

for any Nadex weekly contracts listed on this date.
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(1) CONTRACT 1: The Ceiling shall be X; The Floor shall be X – 150.

(2) CONTRACT 2: The Ceiling shall be X + 75; The Floor shall be X – 75.

(3) CONTRACT 3: The Ceiling shall be X + 150; The Floor shall be X.

(4) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 1.

(5) In each case, “X” equals the last FTSE 100 Future price, as reported by the Source 

Agency, rounded to the nearest 25.

(iv) INTRADAY 2-HOUR FTSE 100® FUTURE CALL 

SPREAD CONTRACTS, 5:00AM, 6:00AM, 7:00AM, 8:00AM, 9:00AM, 10:00AM, 

11:00AM, 12:00PM, 1:00PM, and 4:00PM 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 – 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 1.

(5) In each case, “X” equals the last FTSE 100 Future price, as reported by the Source 

Agency, rounded to the nearest 25.

(6) The Intraday 2-Hour FTSE® 100 Futures Variable Payout Spread Contracts, 

5:00AM, 6:00AM, 7:00AM, 8:00AM, 9:00AM, 10:00AM, 11:00AM, 12:00PM, 1:00PM and 

4:00PM ET Close, will not be listed on the three Business Days immediately following the End 

Date of the Underlying.

(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 FTSE 100 Future Call Spread 

Contracts shall be 1. 

(g) POSITION LIMIT – The Position Limits for FTSE 100 Future Call Spread Contracts 

shall be 250 Contracts per Class. 

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for

the FTSE 100 Future Call Spread Variable Payout Contracts for contracted Market Makers shall 

be 500 Contracts per strike level.
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(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 FTSE 100 Future 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 FTSE 100 

Future released by the Source Agency on the Expiration Date. The Expiration Value is calculated 

by the Source Agency by taking all FFC trade prices occurring in the ten (10) seconds leading up 

to the close of trading of the FTSE 100 Future 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 FFC trade prices and the lowest twenty (20) percent of FFC trade prices from the data 

set3, and using the remaining FFC trade prices to calculate the Expiration Value. The calculation 

used is a simple average of the remaining FFC 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) FFC trade prices exceeds the ten (10) seconds just prior to the close of trading 

of the FTSE 100 Future Call Spread Contract, the Expiration Value is calculated by the Source 

Agency by taking the last twenty-five (25) FFC trade prices just prior to the close of trading of 

the FTSE 100 Future Call Spread Contract removing the highest five (5) FFC trade prices and the 

lowest five (5) FFC trade prices, and using the remaining fifteen (15) FFC trade prices to calculate 

the Expiration Value. The calculation used is a simple average of all fifteen (15) FFC 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 12.49 FTSE 100® FUTURE BINARY CONTRACTS 

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the FTSE 100 

Future Binary Contract issued by Nadex. 

3

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.
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(b) UNDERLYING – The Underlying for this Class of Binary Contracts is the price (in 

British Pounds) of the FTSE 100 Futures contracts (“FFC”) traded on the ICE Futures Europe®

exchange (IFE).4 The FFC trade prices that will be used for the Underlying will be taken from 

four (4) FFC delivery months: March, June, September, or December (each a “FFC 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 IFE FTSE 100 March 2012 futures have an Expiration Date 

of March 16, 2012. The last day on which the FTSE100 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 FTSE 100 contracts will be the Monday of the week of the IFE FTSE 100 

March 2012 futures contracts Expiration Date (i.e. March 16, 2012). Therefore, the End Date for 

using IFE FTSE 100 March 2012 futures will be March 12, 2012 and the Start Date for the next 

delivery month, IFE FTSE 100 June 2012 futures, will be March 13, 20125. 

(c) SOURCE AGENCY – The Source Agency is the 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 FTSE 100 Future Binary Contract, 

the Payout Criteria for the Contracts will be set as follows:

(i) WEEKLY FTSE 100 FUTURE BINARY CONTRACTS 

(1) EXPIRATION TIME – 4:00 PM ET CLOSE

4 FTSE® and FTSE 100® are trademarks of the London Stock Exchange Group (“LSE”). The prices relating to any 

index are not in any way sponsored, endorsed or promoted by FTSE or by the LSE and neither FTSE nor LSE 

makes any warranty or representation whatsoever, expressly or impliedly, either as to the results to be obtained from 

the use of such prices and/or the figure at which any index stands at any particular time on any particular day or 

otherwise. Neither FTSE nor LSE shall be liable (whether in negligence or otherwise) to any person for any error in 

any index and neither FTSE nor LSE shall be under any obligation to advise any person of any error therein. The 

FTSE Future Binary Option Contracts are not sponsored, endorsed, sold or promoted by FTSE or LSE. Neither 

FTSE nor LSE accept any liability in connection with the trading of these products. ICE Futures Europe® is a 

registered mark of Intercontinental Exchange Holdings, Inc. (“ICE Holdings”). Nadex is not affiliated with ICE 

Futures Europe® or ICE Holdings, and the FTSE 100 Future Binary Option Contracts are not sponsored, endorsed, 

sold or promoted by ICE Futures Europe® or ICE Holdings in any way.

5 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 IFE FTSE 100® March 2012 Underlying futures is March 12, 

2012. March 12, 2012 is a Monday, however, and any Nadex weekly contracts listed on this date and expiring on 

Friday, March 16, 2012, will be listed using the IFE FTSE 100® June 2012 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 IFE FTSE 100 June 2012 futures will be Monday, March 12, 2012 

for any Nadex weekly contracts listed on this date.
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(2) STRIKE INTERVAL WIDTH – The interval width between each strike level

 shall be 50.

(3) NUMBER OF STRIKE LEVELS LISTED - Thirteen (13) strike levels will 

 be listed for each Weekly FTSE 100 Future 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 25 or 75 as reported by the Source Agency. Six (6) strike 

 levels will be generated above Binary Contract X at an interval of 50, and six 

 (6) strike levels will be generated below Binary Contract X at an interval of 

 50 (e.g. X – 50; X; X + 50). The Contract will have a Payout Criterion of 

 greater than the strike level value.

(ii) DAILY FTSE 100 FUTURE BINARY CONTRACTS 

(1) EXPIRATION TIME – 4:00 PM ET CLOSE

(2) STRIKE INTERVAL WIDTH – The interval width between each strike level

 shall be 20.

(3) NUMBER OF STRIKE LEVELS LISTED – Twenty-one (21) strike levels 

 will be listed for each Daily FTSE 100 Future 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 20 as reported by the Source Agency. Ten (10) strike levels 

 will be generated above Binary Contract Y at an interval of 20, and ten (10) 

 strike levels will be generated below Binary Contract Y at an interval of 20 

 (e.g. Y – 20; Y; Y + 20). The Contract will have a Payout Criterion of greater 

 than the strike level value.

(iii) INTRADAY FTSE 100 FUTURE BINARY CONTRACTS 

(1) EXPIRATION TIME – 5 AM, 6 AM, 7 AM, 8 AM, 9AM, 10 AM, 11 AM, 

 12 PM, 1 PM, 4 PM ET CLOSE

(2) EXCEPTIONS – No Intraday FTSE 100 Future Binary Contract will be listed 

on the three Business Days immediately following the End Date of the 

Underlying.

(3) STRIKE INTERVAL WIDTH – The interval width between each strike level
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 shall be 15.

(4) NUMBER OF STRIKE LEVELS LISTED – Nine (9) strike levels 

 will be listed for each Intraday FTSE 100 Future Binary Contract Series.

(5) 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 1 as reported by the Source Agency. Four (4) strike levels 

 will be generated above Binary Contract Z at an interval of 15, and four (4) 

 strike levels will be generated below Binary Contract Z at an interval of 15 

 (e.g. Z – 15; Z; Z + 15). The Contract will have a Payout Criterion of greater 

 than the strike level value.

(iv) Nadex may list additional FTSE 100 Future 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 FTSE 100 Future Binary Contract 

shall be $0.25.

(h) POSITION LIMIT – The Position Limits for the FTSE 100 Future Binary Contracts 

shall be 2,500 Contracts per Class. 

(i) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position Limit for the 

FTSE 100 Future Binary Contracts for contracted Market Makers shall be 5,000 Contracts per 

strike level.

(j) LAST TRADING DATE – The Last Trading Date in a Series is the same date as the 

Expiration Date.

(k) SETTLEMENT DATE – The Settlement Date in a Series is the same date as the 

Expiration Date.

(l) EXPIRATION DATE – The Expiration Date of the Contract will be the date for which 

the relevant FFC daily settlement price is released by the Source Agency. 

(m) 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 

FTSE 100 Future Binary Contract is $100.

(n) EXPIRATION VALUE – The Expiration Value is the price or value of FTSE 100 

Future released by the Source Agency on the Expiration Date. The Expiration Value is calculated 

by the Source Agency by taking all FFC trade prices occurring in the ten (10) seconds leading up 

to the close of trading of the FTSE 100 Future Binary Contract, provided at least twenty-five (25) 
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trade prices are captured during the ten (10) second period, removing the highest twenty (20) 

percent of FFC trade prices and the lowest twenty (20) percent of FFC trade prices from the data 

set6, and using the remaining FFC trade prices to calculate the Expiration Value. The calculation 

used is a simple average of the remaining FFC 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) FFC trade prices exceeds the ten (10) seconds just prior to the close of trading 

of the FTSE 100 Future Binary Contract, the Expiration Value is calculated by the Source Agency 

by taking the last twenty-five (25) FFC trade prices just prior to the close of trading of the FTSE 

100 Future Binary Contract removing the highest five (5) FFC trade prices and the lowest five (5) 

FFC trade prices, and using the remaining fifteen (15) FFC trade prices to calculate the Expiration 

Value. The calculation used is a simple average of all fifteen (15) FFC trade prices, rounded to 

one decimal point past the precision of the underlying market. 

(o) CONTINGENCIES – If no daily settlement price of the relevant FFC 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 12.54 – 12.65 [UNCHANGED]

End of Rulebook.

The remainder of this page has intentionally been left blank.

6

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.