Notice2024-18475
Self-Regulatory Organizations; Nasdaq MRX, LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Amend the Exchange's Pricing Schedule at Options 7, Section 3
Primary source
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Published
August 19, 2024
Issuing agencies
Securities and Exchange Commission
Full Text
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<title>Federal Register, Volume 89 Issue 160 (Monday, August 19, 2024)</title>
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[Federal Register Volume 89, Number 160 (Monday, August 19, 2024)]
[Notices]
[Pages 67130-67133]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2024-18475]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-100721; File No. SR-MRX-2024-30]
Self-Regulatory Organizations; Nasdaq MRX, LLC; Notice of Filing
and Immediate Effectiveness of Proposed Rule Change To Amend the
Exchange's Pricing Schedule at Options 7, Section 3
August 13, 2024.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act''),\1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that
on July 31, 2024, Nasdaq MRX, LLC (``MRX'' or ``Exchange'') filed with
the Securities and Exchange Commission (``SEC'' or ``Commission'') the
proposed rule change as described in Items I, II, and III, below, which
Items have been prepared by the Exchange. The Commission is publishing
this notice to solicit comments on the proposed rule change from
interested persons.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
The Exchange proposes to amend the Exchange's Pricing Schedule at
Options 7, Section 3. While these amendments are effective upon filing,
the Exchange has designated the proposed amendments to be operative on
August 1, 2024.
The text of the proposed rule change is available on the Exchange's
website at <a href="https://listingcenter.nasdaq.com/rulebook/mrx/rules">https://listingcenter.nasdaq.com/rulebook/mrx/rules</a>, at the
principal office of the Exchange, and at the Commission's Public
Reference Room.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, the Exchange included statements
concerning the purpose of and basis for the proposed rule change and
discussed any comments it received on the proposed rule change. The
text of these statements may be examined at the places specified in
Item IV below. The Exchange has prepared summaries, set forth in
sections A, B, and C below, of the most significant aspects of such
statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
1. Purpose
The purpose of the proposed rule change is to amend the Exchange's
Pricing Schedule at Options 7, Section 3.
Maker/Taker Pricing
Today, as set forth in Table 1 of Options 7, Section 3, the
Exchange assesses Market Makers \3\ and Priority Customers \4\ the
below tiered maker/taker fees and rebates in Penny and Non-Penny
Symbols that are based on increasing volume requirements set forth in
Table 3 of Options 7, Section 3.\5\
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\3\ A ``Market Maker'' is a market maker as defined in Nasdaq
MRX Rule Options 1, Section 1(a)(21).
\4\ A ``Priority Customer'' is a person or entity that is not a
broker/dealer in securities, and does not place more than 390 orders
in listed options per day on average during a calendar month for its
own beneficial account(s), as defined in Nasdaq MRX Options 1,
Section 1(a)(36).
\5\ The tiered volume requirements are based on Total Customer
ADV. Total Customer ADV is Priority Customer Total Consolidated
Volume divided by Customer Total Consolidated Volume, including
volume executed by Affiliated Members or Affiliated Entities.
Priority Customer Total Consolidated Volume is a Member's total
Priority Customer volume executed on MRX in that month, including
volume executed by Affiliated Members or Affiliated Entities. All
eligible volume from Affiliated Members or an Affiliated Entity will
be aggregated in determining applicable tiers.
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Taker fee/ Taker fee/ Taker fee/ Taker fee/
Market participant Maker fee Maker fee Maker fee Maker fee rebate rebate rebate rebate
Tier 1 Tier 2 Tier 3 Tier 4 Tier 1 Tier 2 Tier 3 Tier 4
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Penny Symbols:
Market Maker................................ $0.50 $0.50 $0.50 $0.50 $0.35 $0.35 $0.35 $0.35
Priority Customer........................... 0.00 0.00 0.00 0.00 (0.31) (0.36) (0.41) (0.44)
Non-Penny Symbols:
Market Maker................................ 1.25 1.25 1.25 1.25 1.10 1.10 1.10 1.10
Priority Customer........................... 0.00 0.00 0.00 0.00 (0.80) (0.90) (1.00) (1.10)
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Additionally, for SPY, QQQ, and IWM, the Exchange currently
assesses $0.00 per contract for Market Maker Tier 1 through Tier 4
Maker Fees and Priority Customer Tier 1 through Tier 4 Taker Fees/
Rebates in Penny Symbols.\6\ In other words, Market Makers can provide
liquidity in these symbols at no cost (instead of paying the $0.50
Tiers 1-4 Maker Fee in Penny Symbols), and Priority Customers can
remove liquidity in these symbols at no cost (instead of receiving the
Tiers 1-4 Taker Rebates in Penny Symbols ranging from $0.31-$0.44 per
contract).
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\6\ See note 6, Options 7, Section 3, Table 1.
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The Exchange now proposes to amend the pricing for SPY, QQQ, and
IWM as described above to begin charging $0.02 per contract for Market
Maker Tier 1 through Tier 4 Maker Fees in these symbols. Further, the
Exchange proposes to begin providing $0.02 per contract for Priority
Customer Tier 1
[[Page 67131]]
through Tier 4 Taker Rebates in these symbols. As proposed, note 6 will
provide: ``Market Maker Tier 1 through Tier 4 Maker Fees in Penny
Symbols will be $0.02 per contract for the following option symbols:
SPY, QQQ and IWM. Priority Customer Tier 1 through Tier 4 Taker Rebates
in Penny Symbols will be ($0.02) per contract for the following option
symbols: SPY, QQQ and IWM.''
The Exchange also proposes to modify the Priority Customer Tiers 1-
4 Taker Rebates in Penny and Non-Penny Symbols as described above.
Specifically, the Exchange proposes in new note 7 of Options 7, Section
3, Table 1 that Priority Customer orders will not receive any Taker
Rebates in Penny and Non-Penny Symbols for trades executed against
another Priority Customer order. Instead, the Priority Customer order
will be assessed $0.00 per contract.
PIM Break-Up Rebates
Today, as set forth in Options 7, Section 3.A, the Exchange pays a
PIM break-up rebate to an originating Priority Customer PIM order that
executes with a response (order or quote), other than the PIM contra-
side order, of $0.25 per contract in Penny Symbols and $0.60 per
contract in Non-Penny Symbols.\7\ The Exchange also offers additional
break-up rebates in note 3 of Options 7, Section 3.A for Members that
meet certain volume requirements or alternatively, that enter into
Affiliated Member \8\ or Affiliated Entity \9\ relationships. In
particular, note 3 currently provides: ``Break-up Rebates are provided
for an originating Priority Customer PIM Order that executes with any
response (order or quote) other than the PIM contra-side order. Members
that are not in an Affiliated Member or Affiliated Entity relationship
and that execute 0.05% or greater of Customer Total Consolidated Volume
\10\ which adds liquidity in non-PIM Priority Customer contracts within
a month will receive an additional rebate of: (i) $0.20 per contract in
Penny Symbols for Complex PIM Orders only, (ii) $0.15 per contract in
Penny Symbols for Regular PIM Orders only, and (iii) $0.45 per contract
in Non-Penny Symbols for both Regular and Complex PIM Orders.
Alternatively, Affiliated Members or Affiliated Entities will be
eligible to receive the rebates in this note 3 without any additional
volume requirements. The Exchange will provide the rebate to the OFP
arm of an Affiliated Member relationship, or the Appointed OFP arm of
an Affiliated Entity relationship.''
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\7\ Break-up rebates apply only to regular PIM orders of 500 or
fewer contracts and to complex PIM orders where the largest leg is
500 or fewer contracts.
\8\ An ``Affiliated Member'' is a Member that shares at least
75% common ownership with a particular Member as reflected on the
Member's Form BD, Schedule A.
\9\ An ``Affiliated Entity'' is a relationship between an
Appointed Market Maker and an Appointed OFP for purposes of
qualifying for certain pricing specified in the Pricing Schedule.
Market Makers and OFPs are required to send an email to the Exchange
to appoint their counterpart, at least 3 business days prior to the
last day of the month to qualify for the next month. The Exchange
will acknowledge receipt of the emails and specify the date the
Affiliated Entity is eligible for applicable pricing, as specified
in the Pricing Schedule. Each Affiliated Entity relationship will
commence on the 1st of a month and may not be terminated prior to
the end of any month. An Affiliated Entity relationship will
automatically renew each month until or unless either party
terminates earlier in writing by sending an email to the Exchange at
least 3 business days prior to the last day of the month to
terminate for the next month. Affiliated Members may not qualify as
a counterparty comprising an Affiliated Entity. Each Member may
qualify for only one (1) Affiliated Entity relationship at any given
time.
\10\ ``Customer Total Consolidated Volume'' means the total
volume cleared at The Options Clearing Corporation in the Customer
range in equity and ETF options in that month.
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The Exchange now proposes to modify the note 3 rebate
qualifications only for those Members that are not in Affiliated Member
or Affiliated Entity relationships. Under this proposal, Affiliated
Members or Affiliated Entities will continue to be eligible to receive
the note 3 rebates without any additional volume requirements.
Specifically, the Exchange proposes to require Members not in
Affiliated Member or Affiliated Entity relationships to execute 0.04%
or greater of Customer Total Consolidated Volume which adds liquidity
in non-PIM Priority Customer contracts in regular orders within a month
to receive the additional rebates in note 3.
2. Statutory Basis
The Exchange believes that its proposal is consistent with Section
6(b) of the Act,\11\ in general, and furthers the objectives of
Sections 6(b)(4) and 6(b)(5) of the Act,\12\ in particular, in that it
provides for the equitable allocation of reasonable dues, fees, and
other charges among members and issuers and other persons using any
facility, and is not designed to permit unfair discrimination between
customers, issuers, brokers, or dealers.
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\11\ 15 U.S.C. 78f(b).
\12\ 15 U.S.C. 78f(b)(4) and (5).
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The Exchange's proposed changes to its schedule of credits are
reasonable in several respects. As a threshold matter, the Exchange is
subject to significant competitive forces in the market for options
securities transaction services that constrain its pricing
determinations in that market. The fact that this market is competitive
has long been recognized by the courts. In NetCoalition v. Securities
and Exchange Commission, the D.C. Circuit stated as follows: ``[n]o one
disputes that competition for order flow is `fierce.' . . . As the SEC
explained, `[i]n the U.S. national market system, buyers and sellers of
securities, and the broker-dealers that act as their order-routing
agents, have a wide range of choices of where to route orders for
execution'; [and] `no exchange can afford to take its market share
percentages for granted' because `no exchange possesses a monopoly,
regulatory or otherwise, in the execution of order flow from broker
dealers'. . . .'' \13\
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\13\ NetCoalition v. SEC, 615 F.3d 525, 539 (D.C. Cir. 2010)
(quoting Securities Exchange Act Release No. 59039 (December 2,
2008), 73 FR 74770, 74782-83 (December 9, 2008) (SR-NYSEArca-2006-
21)).
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The Commission and the courts have repeatedly expressed their
preference for competition over regulatory intervention in determining
prices, products, and services in the securities markets. In Regulation
NMS, while adopting a series of steps to improve the current market
model, the Commission highlighted the importance of market forces in
determining prices and SRO revenues and, also, recognized that current
regulation of the market system ``has been remarkably successful in
promoting market competition in its broader forms that are most
important to investors and listed companies.'' \14\
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\14\ Securities Exchange Act Release No. 51808 (June 9, 2005),
70 FR 37496, 37499 (June 29, 2005) (``Regulation NMS Adopting
Release'').
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Numerous indicia demonstrate the competitive nature of this market.
For example, clear substitutes to the Exchange exist in the market for
options security transaction services. The Exchange is only one of
seventeen options exchanges to which market participants may direct
their order flow. Within this environment, market participants can
freely and often do shift their order flow among the Exchange and
competing venues in response to changes in their respective pricing
schedules. As such, the proposal represents a reasonable attempt by the
Exchange to increase its liquidity and market share relative to its
competitors.
Maker/Taker Pricing
The Exchange believes that the proposed changes to the maker/taker
pricing for Market Makers and Priority Customers in the manner
described above are reasonable, equitable and not unfairly
discriminatory for the reasons that follow.
[[Page 67132]]
SPY, QQQ, IWM Pricing
The Exchange believes that it is reasonable to begin charging $0.02
per contract for Market Maker Tier 1 through Tier 4 Maker Fees in SPY,
QQQ, and IWM, and to begin providing $0.02 per contract for Priority
Customer Tier 1 through Tier 4 Taker Rebates in these symbols. As it
relates to Market Makers, the Exchange notes that it is only increasing
the Tier 1 through Tier 4 Maker Fees by a small amount (i.e., from
$0.00 to $0.02). Further, Market Makers will continue to be charged
significantly less for adding liquidity in SPY, QQQ, and IWM ($0.02)
than for adding liquidity in other Penny Symbols ($0.50). As it relates
to Priority Customers, the Exchange will begin providing Tier 1 through
Tier 4 Taker Rebates of $0.02 whereas today, Priority Customers do not
receive any Taker Rebates for removing liquidity in SPY, QQQ, and IWM.
The Exchange therefore believes that with the proposed changes, Market
Makers and Priority Customers will continue to be incentivized to bring
SPY, QQQ, and IWM order flow to MRX, which benefits all market
participants by providing more trading opportunities. The Exchange also
believes that assessing different pricing for SPY, QQQ, and IWM, as
compared to other symbols, is reasonable because trading in SPY, QQQ,
and IWM is different from trading in other symbols in that they are
more liquid, have higher volume and competition for executions is more
intense.
The Exchange believes that the proposed changes to the SPY, QQQ,
and IWM pricing for Market Makers and Priority Customers are equitable
and not unfairly discriminatory because they will apply uniformly to
similarly situated market participants (i.e., the proposed Tier 1
through Tier 4 Maker Fees in SPY, QQQ, and IWM will apply uniformly to
Market Makers and the proposed Tier 1 through Tier 4 Taker Rebates in
SPY, QQQ, and IWM will apply uniformly to Priority Customers). The
Exchange believes that it is equitable and not unfairly discriminatory
to apply the proposed changes to only Market Makers and Priority
Customers. As it relates to Market Makers, the Exchange notes that they
have different requirements and additional obligations that other
market participants do not (such as quoting requirements).\15\ As such,
the proposed Maker Fees of $0.02 per contract (which continue to be
significantly lower than the $0.50 per contract Market Maker Maker Fees
assessed for other Penny Symbols) are designed to continue to
incentivize Market Maker add liquidity activity in SPY, QQQ, and IWM.
As it relates to Priority Customers, the Exchange notes that these
market participants have historically received more favorable pricing
on the Exchange.\16\ Further, an increase in the activity of Priority
Customers benefits all market participants by providing more trading
opportunities, which attracts Market Makers. An increase in the
activity of these market participants, in turn, facilitates tighter
spreads, which may cause an additional corresponding increase in order
flow from other market participants, to the benefit of all market
participants.
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\15\ See Options 2, Section 5.
\16\ See, e.g., maker/taker pricing for Priority Customers in
Options 7, Section 3, Table 1; and complex order fees for Priority
Customers in Options 7, Section 4.
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Priority Customer Taker Pricing
As discussed above, the Exchange proposes in new note 7 of Options
7, Section 3, Table 1 that Priority Customer orders will not receive
the Tier 1 through Tier 4 Taker Rebates in Penny and Non-Penny Symbols
for trades executed against another Priority Customer order. Instead,
the Priority Customer order will be assessed $0.00 per contract. The
Exchange believes that its proposal is reasonable because Priority
Customers will continue to receive more favorable pricing for removing
liquidity in Penny and Non-Penny Symbols compared to Non-Priority
Customers.\17\ Specifically, as set forth in Table 1 of Options 7,
Section 3, all Non-Priority Customers currently pay a $0.35 Taker Fee
in Tiers 1-4 for removing liquidity in Penny Symbols, and a $1.10 Taker
Fee in Tiers 1-4 for removing liquidity in Non-Penny Symbols.
Additionally, Priority Customers will continue to receive the generous
Taker Rebates in Penny and Non-Penny Symbols for trades executed
against Non-Priority Customers. The Exchange notes that other options
exchanges, including for example its affiliate Nasdaq GEMX (``GEMX''),
assess different taker pricing depending on the counterparty.\18\
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\17\ ``Non-Priority Customers'' include Market Makers, Non-
Nasdaq MRX Market Makers (FarMMs), Firm Proprietary/Broker-Dealers,
and Professional Customers.
\18\ See GEMX Pricing Schedule at Options 7, Section 3, note 16.
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The Exchange believes that its proposal is equitable and not
unfairly discriminatory because it will apply uniformly to all Priority
Customers. The Exchange does not believe it is unfairly discriminatory
to apply the proposed changes to only Priority Customers because
Priority Customers will continue to receive more favorable pricing for
removing liquidity in Penny and Non-Penny Symbols compared to Non-
Priority Customers, as discussed above. The Exchange has historically
provided more favorable pricing to Priority Customers.\19\ Furthermore,
Priority Customer order flow enhances liquidity on the Exchange for the
benefit of all market participants by providing more trading
opportunities, which in turn attracts Market Makers and other market
participants that may trade with this order flow.
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\19\ See supra note 16.
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PIM Break-Up Rebates
The Exchange believes that the proposed changes to the
qualifications for receiving the additional PIM break-up rebates in
note 3 of Options 7, Section 3.A are reasonable, equitable, and not
unfairly discriminatory for the reasons that follow. As discussed
above, the Exchange is proposing to require Members not in Affiliated
Member or Affiliated Entity relationships to execute 0.04% or greater
of Customer Total Consolidated Volume which adds liquidity in non-PIM
Priority Customer contracts in regular orders within a month to receive
the additional rebates in note 3. With the proposed changes, the
Exchange is effectively lowering the volume requirement and narrowing
the scope of the rebate qualifications to regular orders. The Exchange
believes that the lower volume requirement of 0.04% (versus the current
0.05%) is reasonable because it will further incentivize Members to
bring liquidity adding non-PIM regular order flow for execution on the
Exchange for the same rebate amounts, which the Exchange believes may
result in tighter spreads, thereby making the Exchange a more
attractive trading venue to the benefit of all market participants. The
Exchange also believes it is reasonable to narrow the scope of the
rebate qualifications in note 3 to only non-PIM regular orders because
the Exchange believes that market participants are already sufficiently
incentivized to bring Priority Customer non-PIM complex order flow to
MRX through the Exchange's existing pricing schedule.\20\
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\20\ Specifically, the Exchange does not assess any complex
order fees for Priority Customers today. See Options 7, Section 4.
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The Exchange also believes that the proposed changes to the
additional PIM break-up rebate qualifications are equitable and not
unfairly discriminatory because the changes will apply uniformly to all
similarly situated market participants. While the rebates
[[Page 67133]]
will continue to apply only to Priority Customers, the Exchange
believes that the application of this rebate program is equitable and
not unfairly discriminatory because the Exchange has historically
provided more favorable pricing for Priority Customers.\21\
Furthermore, Priority Customer order flow benefits all market
participants by providing more trading opportunities, which attracts
Market Makers. An increase in the activity of these market participants
in turn facilitates tighter spreads, which may cause an additional
corresponding increase in order flow from other market participants, to
the benefit of all market participants.
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\21\ See supra note 16.
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B. Self-Regulatory Organization's Statement on Burden on Competition
The Exchange does not believe that the proposed rule change will
impose any burden on competition not necessary or appropriate in
furtherance of the purposes of the Act.
In terms of intra-market competition, the Exchange does not believe
that its proposal will place any category of market participants at a
competitive disadvantage. The Exchange believes that all of the changes
proposed above will incentivize market participants to direct more
order flow to the Exchange, to the benefit of all market participants
who may interact with this order flow. While some aspects of the
proposal apply directly to Market Makers (through the Market Maker Tier
1 through Tier 4 Maker Fees for SPY, QQQ, and IWM) or Priority
Customers (through the Priority Customer Tier 1 through Tier 4 Taker
Rebates for SPY, QQQ, and IWM; the $0.00 Taker Fee in Penny and Non-
Penny Symbols when trading against another Priority Customer order; and
the PIM break-up rebate qualification changes), the Exchange believes
that the proposed changes taken together will fortify and encourage
activity, especially Market Maker and Priority Customer activity, on
the Exchange. As discussed above, all market participants will benefit
from any increase in market activity that the proposal effectuates.
In terms of inter-market competition, the Exchange notes that it
operates in a highly competitive market in which market participants
can readily favor competing venues if they deem fee levels at a
particular venue to be excessive, or rebate opportunities available at
other venues to be more favorable. In such an environment, the Exchange
must continually adjust its fees to remain competitive with other
options exchanges. Because competitors are free to modify their own
fees in response, and because market participants may readily adjust
their order routing practices, the Exchange believes that the degree to
which fee changes in this market may impose any burden on competition
is extremely limited. In sum, if the changes proposed herein are
unattractive to market participants, it is likely that the Exchange
will lose market share as a result. Accordingly, the Exchange does not
believe that the proposed changes will impair the ability of members or
competing order execution venues to maintain their competitive standing
in the financial markets.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
No written comments were either solicited or received.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become effective pursuant to Section
19(b)(3)(A)(ii) of the Act.\22\ At any time within 60 days of the
filing of the proposed rule change, the Commission summarily may
temporarily suspend such rule change if it appears to the Commission
that such action is: (i) necessary or appropriate in the public
interest; (ii) for the protection of investors; or (iii) otherwise in
furtherance of the purposes of the Act. If the Commission takes such
action, the Commission shall institute proceedings to determine whether
the proposed rule should be approved or disapproved.
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\22\ 15 U.S.C. 78s(b)(3)(A)(ii).
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IV. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
<bullet> Use the Commission's internet comment form (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>); or
<bullet> Send an email to <a href="/cdn-cgi/l/email-protection#afdddac3ca82ccc0c2c2cac1dbdcefdccacc81c8c0d9"><span class="__cf_email__" data-cfemail="d5a7a0b9b0f8b6bab8b8b0bba1a695a6b0b6fbb2baa3">[email protected]</span></a>. Please include
file number SR-MRX-2024-30 on the subject line.
Paper Comments
<bullet> Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.
All submissions should refer to file number SR-MRX-2024-30. This file
number should be included on the subject line if email is used. To help
the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's internet website (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for website viewing and
printing in the Commission's Public Reference Room, 100 F Street NE,
Washington, DC 20549, on official business days between the hours of 10
a.m. and 3 p.m. Copies of the filing also will be available for
inspection and copying at the principal office of the Exchange. Do not
include personal identifiable information in submissions; you should
submit only information that you wish to make available publicly. We
may redact in part or withhold entirely from publication submitted
material that is obscene or subject to copyright protection. All
submissions should refer to file number SR-MRX-2024-30 and should be
submitted on or before September 9, 2024.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\23\
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\23\ 17 CFR 200.30-3(a)(12).
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Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2024-18475 Filed 8-16-24; 8:45 am]
BILLING CODE 8011-01-P
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