crypto.com | Derivatives North America

200 West Jackson Blvd., Suite 1400

Chicago, IL 60606

January 4, 2024

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 Self-Certification: Amendments to Underlying Rollover Schedule in 

Nadex’s Gold, Silver, and Japan 225 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”) d/b/a crypto.com | Derivatives North America, hereby submits to the Commission 

its intent to amend the following rules in order to adjust the language in the description of 

its underlying futures month rollover schedule for the below contracts:

• Rule 12.4.1 – Gold “Call Spread” Variable Payout Contracts

• Rule 12.4.2 – Gold “Touch Bracket” Variable Payout Contracts

• Rule 12.5 – Gold Binary Contracts

• Rule 12.6.1 – Silver “Call Spread” Variable Payout Contracts

• Rule 12.6.2 – Silver “Touch Bracket” Variable Payout Contracts

• Rule 12.7 – Silver Binary Contracts

• Rule 12.54 – Japan 225 Variable Payout Contracts

• Rule 12.55 – Japan 225 Binary Contracts

Nadex is amending its rollover schedule for the underlying futures month used in the 

settlement calculation of the above contracts in order to align those contracts with the volume 

roll for other Nadex Commodity and Equity Index Contracts. Presently, the last day on 

which a delivery month is used as the underlying for the above Gold and Silver Contracts is 

the third to last business day of the month preceding the expiration month of the underlying 

futures contract. Additionally, for the above Japan 225 contracts, the last day on which a 

delivery month is sued as the underlying is the Monday of the week of the underlying futures 

contract expiration date. Nadex is amending its rollover schedule to reflect that the last day 

on which a delivery month will be used as the underlying for the Nadex Gold and Silver 
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contracts will be the last Friday Business Day of the month preceding the expiration month 

of the underlying futures contract, and for the Japan 225 Contract will be the Friday Business 

Day of the week preceding the expiration week of the underlying futures contract. This will 

enable a more efficient and consistent settlement process across each relevant class of 

products.

See Appendix A for a redlined Rulebook depicting the relevant changes for each of the above 

listed Nadex Rules.

Analysis of Nadex Rule Amendments Compliance With Core Principles

DCM Core Principles

Nadex has identified the following DCM Core Principles as potentially being 

impacted by the additional requirements for affiliated Trading: Core Principle 7 (Availability 

of General Information).

Core Principle 7 requires that the DCM ensure that its Rulebook is accurate, 

complete, current and readily accessible to the public, and all new or amended rules, both 

substantive and non-substantive, shall be reflected in the Rulebook on the date of 

implementation. Nadex makes its Rulebook publicly available on the Nadex website. On 

the effective date of this submission, the Rulebook will be updated and published with the 

aforementioned rule amendment. Accordingly, these amendments will not negatively affect 

Nadex’s ability to comply with this Core Principle.

DCO Core Principles

Nadex has identified the following DCO Core Principles as potentially being 

impacted by the additional means of funding a Nadex account: Core Principle L (Public 

Information).

Core Principle L requires a DCO make publicly available its rules in a clear and 

comprehensive manner. Nadex makes its Rulebook publicly available on its website, which 

will be updated with the additions discussed herein on the effective date. Accordingly, these 

amendments will not negatively affect Nadex’s ability to comply with this Core Principle.

* * * * *

The amendments to the Rulebook are set forth in Exhibit A. Any deletions are 

stricken out while the amendments and/or additions are underlined.
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Nadex hereby certifies that the additions contained herein comply with the Act, as 

amended, and the Commission Regulations adopted thereunder. No substantive opposing 

views were expressed to Nadex with respect to any of these actions.

Nadex hereby certifies that notice of these amendments was posted on its website at 

the time of this filing.

In accordance with the 10-day review period set forth in Commission Regulation 

40.6(a)(3), these Rule changes will be effective as of January 19, 2024. 

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

me by telephone at (312) 884-0161 or by email at kevin.dan@nadex.com.

 Sincerely, 

 Kevin J. Dan

 Chief Compliance Officer

 Chief Regulatory Officer