# CFTC Letter No. 25-45: Modification of no-action position with respect to Part 43 and 45 reporting, as well as related sections of Parts 38 and 39, for binary options executed on or pursuant to the rules of MIAXdx and cleared through MIAXdx

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/CFTC_L25_45

## Section

- **Citation:** CFTC Letter No. 25-45
- **Heading:** Modification of no-action position with respect to Part 43 and 45 reporting, as well as related sections of Parts 38 and 39, for binary options executed on or pursuant to the rules of MIAXdx and cleared through MIAXdx
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** CFTC Staff Letters (2008-present) / Modification of no-action position with respect to Part 43 and 45 reporting, as well as related sections of Parts 38 and 39, for binary options executed on or pursuant to the rules of MIAXdx and cleared through MIAXdx.

## Text

Summary: Modification of no-action position with respect to Part 43 and 45 reporting, as well as related sections of Parts 38 and 39, for binary options executed on or pursuant to the rules of MIAXdx and cleared through MIAXdx.

CFTC LETTER NO. 25-45 NO-ACTION DECEMBER 11, 2025
1

Division of Market Oversight

Division of Clearing and Risk

Re:
Supplemental Staff Letter Regarding No-Action Position with Respect to
Commission Regulations 38.8(b), 38.10, 38.951 (in Part), 39.20(b)(2), and Parts 43
and 45, for MIAXdx Contracts

Introduction

The Division of Market Oversight (“DMO”) and the Division of Clearing and Risk (“DCR”
and, together with DMO, the “Divisions”) of the Commodity Futures Trading Commission
(“CFTC” or “Commission”) are issuing this letter in response to a request (the “Request”) from
LedgerX LLC d/b/a MIAX Derivatives Exchange LLC (“MIAXdx”).1 MIAXdx requested, on its
own behalf and on behalf of its participants, to amend Staff Letter 24-12.2 Staff Letter 24-12
granted MIAXdx’s request for a no-action position from the swap data reporting and
recordkeeping requirements of sections 38.8(b), 38.10, 38.951 (to the extent that regulation 38.951
requires compliance with Part 45 of the Commission’s regulations), 39.20(b)(2), and Parts 43 and
45 of the Commission’s regulations (collectively, the “Relevant Regulations”). MIAXdx has now
requested that the Divisions modify the no-action position granted in Staff Letter 24-12 to remove
condition 6,3 which provides that “[n]o MIAXdx participant clears a MIAXdx Contract through a
third-party clearing member.”4

Background

MIAXdx is a designated contract market (“DCM”) and a derivatives clearing organization
(“DCO”).5 MIAXdx lists for trade “binary options on the outcomes of various economic or
commercial events” (the “MIAXdx Contracts”).6 MIAXdx Contracts “settle at expiration by the
payment of an absolute amount to the holder of one side of the option and no payment to the

1 Letter from M. Bailey to R
MIAXdx is a designated contract market (“DCM”) and a derivatives clearing organization
(“DCO”).5 MIAXdx lists for trade “binary options on the outcomes of various economic or
commercial events” (the “MIAXdx Contracts”).6 MIAXdx Contracts “settle at expiration by the
payment of an absolute amount to the holder of one side of the option and no payment to the

1 Letter from M. Bailey to R. Varma and R. Haynes re: Request for Amended No-Action Relief from Certain Swap
Data Reporting and Recordkeeping Requirements (July 1, 2025).
2 CFTC Letter No. 24-12 (Sept. 3, 2024), available at https://www.cftc.gov/csl/24-12/download.
3 Request at 1.
4 CFTC Letter No. 24-12 at 5.
5 MIAXdx is also registered as a swap execution facility (“SEF”), but it has not requested a no-action position on
behalf of its SEF in the Request.
6 Request at 2. MIAXdx stated that it has “listed cash-settled binary options on cryptocurrencies,” but “expects to
offer other types of binary options in the future.” Request at 2 n.5.
CFTC Logo
U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5000
www.cftc.gov

2

counterparty, depending on the occurrence or non-occurrence of the event that is the subject of the
contract.”7

As options, binary options fall within the Commission’s plenary options authority under
Commodity Exchange Act (“CEA”) section 4c(b).8 CEA section 4c(b), in relevant part, prohibits
any person from offering, entering into, or confirming the execution of a transaction involving any
commodity regulated under the CEA that “is of the character of, or is commonly known to the
trade as, an ‘option’ . . .” contrary to any Commission rule prohibiting the transaction or allowing
it pursuant to specified terms and conditions. When promulgating Commission regulation 32.2,
the Commission stated that “the swap definition . . . includes options . .
on of a transaction involving any
commodity regulated under the CEA that “is of the character of, or is commonly known to the
trade as, an ‘option’ . . .” contrary to any Commission rule prohibiting the transaction or allowing
it pursuant to specified terms and conditions. When promulgating Commission regulation 32.2,
the Commission stated that “the swap definition . . . includes options . . . (whether or not traded on
a DCM).”9 Commission regulation 32.2 states, in relevant part, that commodity option
transactions must be conducted in compliance with the CEA and the Commission’s regulations
related to swaps.10

The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”)11
amended the CEA by adding a definition of “swap.”12 The Dodd-Frank Act required the
Commission and the Securities and Exchange Commission to further define jointly the term
“swap.” In jointly adopting such further definition, the Commissions stated that “the statutory
swap definition explicitly provides that commodity options are swaps[.]”13 MIAXdx represents
that its binary options “are swaps within the meaning of the [Commodity Exchange Act (‘CEA’)]”
because “Section 1a(47) of the CEA expressly defines ‘swaps’ to include options as well as any
contract that provides for any purchase, sale, payment, or delivery that is dependent on the
occurrence, non-occurrence, or the extent of the occurrence of an event or contingency associated
with a potential financial, economic, or commercial consequence.”14

Pursuant to the Dodd-Frank Act, the Commission promulgated various regulations
applicable to swaps, including the Relevant Regulations. The Relevant Regulations apply swap
reporting and recordkeeping obligations to DCMs, DCOs, and other market participants
r the extent of the occurrence of an event or contingency associated
with a potential financial, economic, or commercial consequence.”14

Pursuant to the Dodd-Frank Act, the Commission promulgated various regulations
applicable to swaps, including the Relevant Regulations. The Relevant Regulations apply swap
reporting and recordkeeping obligations to DCMs, DCOs, and other market participants. In
particular, Parts 43 and 45 require, respectively, real-time reporting of swap transaction and pricing
data to swap data repositories (“SDRs”) for purposes of public dissemination and reporting of
broader swap data to SDRs for the CFTC’s use in fulfilling its surveillance and market analysis
missions.

On September 3, 2024, the Divisions issued Staff Letter 24-12, which provided MIAXdx
a no-action position related to swap data reporting and recordkeeping requirements under the

7 Id. at 2.
8 7 U.S.C. § 6c(b).
9 Commodity Options, 77 Fed. Reg. 25320, 25321 n.6 (Apr. 27, 2012).
10 17 C.F.R. § 32.2.
11 Public Law 111–203, 124 Stat. 1376 (2010).
12 7 U.S.C. § 1a(47).
13 Further Definition of “Swap,” “Security-Based Swap,” and “Security-Based Swap Agreement;” Mixed Swaps;
Security-Based Swap Agreement Recordkeeping, 77 Fed. Reg. 48207, 48236 (Aug. 13, 2012). See also In re:
Blockratize, Inc. d/b/a Polymarket.com, CFTC Dkt. No. 22-09, at 2, 7 (Jan. 3, 2022) (“binary options . . . constitute
swaps under the CFTC’s jurisdiction, and therefore can only be offered on a registered exchange in accordance with
the Act and Regulations”).
14 Request at 2; see also 7 U.S.C. § 1(a)(47)(A)(i)-(ii).
ent Recordkeeping, 77 Fed. Reg. 48207, 48236 (Aug. 13, 2012). See also In re:
Blockratize, Inc. d/b/a Polymarket.com, CFTC Dkt. No. 22-09, at 2, 7 (Jan. 3, 2022) (“binary options . . . constitute
swaps under the CFTC’s jurisdiction, and therefore can only be offered on a registered exchange in accordance with
the Act and Regulations”).
14 Request at 2; see also 7 U.S.C. § 1(a)(47)(A)(i)-(ii).

3

Relevant Regulations for the MIAXdx Contracts.15 In granting that request, the Divisions noted
that the no-action position taken in Staff Letter 24-12 was similar to and consistent with previous
no-action positions taken with respect to reporting certain binary options transactions.16 The no-
action position taken in Staff Letter 24-12 contained several conditions, including condition 6,
which conditions the no-action position on MIAXdx prohibiting futures commission merchants
(“FCMs”) from intermediating clearing for MIAXdx Contracts.17

No-Action Position Requested

MIAXdx requested that the Divisions modify the no-action position granted in Staff Letter
24-12 to remove condition 6, which specifically provides that “[n]o Participants shall clear
MIAXdx Contracts through any third-party clearing member.”18

Condition 6 ties back to MIAXdx’s Order of Designation as a DCM, which states that
“[MIAXdx] shall not permit any FCM to clear trades executed on, or pursuant to the rules of, the
contract market on behalf of third-party customers, unless [MIAXdx] first notifies the Commission
of its intent to do so and submits any applicable rule changes pursuant to 17 C.F.R
ird-party clearing member.”18

Condition 6 ties back to MIAXdx’s Order of Designation as a DCM, which states that
“[MIAXdx] shall not permit any FCM to clear trades executed on, or pursuant to the rules of, the
contract market on behalf of third-party customers, unless [MIAXdx] first notifies the Commission
of its intent to do so and submits any applicable rule changes pursuant to 17 C.F.R. Part 40.”19 At
the time the Divisions issued Staff Letter 24-12, MIAXdx’s rulebook did not authorize FCMs to
intermediate clearing of MIAXdx Contracts.20 On May 30, 2025, MIAXdx submitted rulebook
amendments to the Commission that set out rules and procedures for FCMs to clear trades executed
on or pursuant to the rules of MIAXdx.21 In connection with those rulebook amendments,
MIAXdx has now requested that the Divisions modify the no-action position granted in Staff Letter
24-12 to remove condition 6.22 The requested modification would enable MIAXdx to rely on the
no-action position taken in Staff Letter 24-12 when reporting MIAXdx contracts that MIAXdx
participants and customers clear through third-party clearing members.

MIAXdx stated that the Divisions have previously granted similar no-action positions with
respect to the Relevant Regulations for similar contracts, without including a non-intermediation
condition prohibiting FCMs from clearing the contracts subject to the no-action position.23
MIAXdx also stated that, following its rulebook amendments to set its rules and procedures for

15 See CFTC Letter No. 24-12.
16 See id. at 4; see also CFTC Letter No. 17-31 (Jun. 30, 2017), available at https://www.cftc.gov/csl/17-31/download;
CFTC Letter No. 17-32 (Jun. 30, 2017), available at https://www.cftc.gov/csl/17-32/download; CFTC Letter No. 21-
11 (Apr. 22, 2021), available at https://www.cftc.gov/csl/21-11/download; CFTC Letter No. 24-09 (July 12, 2024),
available at https://www.cftc.gov/csl/24-09/download; CFTC Letter No. 24-12 (Sept
TC Letter No. 17-31 (Jun. 30, 2017), available at https://www.cftc.gov/csl/17-31/download;
CFTC Letter No. 17-32 (Jun. 30, 2017), available at https://www.cftc.gov/csl/17-32/download; CFTC Letter No. 21-
11 (Apr. 22, 2021), available at https://www.cftc.gov/csl/21-11/download; CFTC Letter No. 24-09 (July 12, 2024),
available at https://www.cftc.gov/csl/24-09/download; CFTC Letter No. 24-12 (Sept. 3, 2024), available at
https://www.cftc.gov/csl/24-12/download;
CFTC
Letter
No.
24-15
(Oct.
4,
2024),
available
at
https://www.cftc.gov/csl/24-15/download;
CFTC
Letter
No.
25-02
(Jan.
31,
2025),
available
at
https://www.cftc.gov/csl/25-02/download.
17 CFTC Letter No. 24-12 at 5.
18 Request at 1, 4.
19 In the Matter of the Application of LedgerX LLC for Designation as a Contract Market, Order of Designation (June
24,
2019),
available
at
https://www.cftc.gov/sites/default/files/filings/documents/2019/orgledgerxdcmorder190624.pdf.
20 See Request at 1.
21 See Letter from M. Bailey to C. Kirkpatrick re: Commission Regulation 40.6(a) – Rule Certification, LedgerX LLC
Submission No. 25-20 (May 30, 2025).
22 Request at 1.
23 See Request at 1; see also CFTC Letter No. 24-09 (July 12, 2024), available at https://www.cftc.gov/csl/24-
09/download and CFTC Letter No. 25-02 (Jan. 31, 2025), available at https://www.cftc.gov/csl/25-02/download.

4

FCMs to clear trades executed on or pursuant to the rules of MIAXdx, removing condition 6 from
the no-action position would be consistent with MIAXdx’s Order of Designation as a DCM and
Order of Registration as a DCO, which permit FCM intermediation of clearing if appropriate
rulebook amendments and other changes are made to facilitate such intermediation.24 In support
of their request, MIAXdx also reiterated representations made in its request for the no-action
position granted in Staff Letter 24-12, excluding its representation that no participants shall clear
MIAXdx Contracts through any third party clearing member:

• MIAXdx will require
ring if appropriate
rulebook amendments and other changes are made to facilitate such intermediation.24 In support
of their request, MIAXdx also reiterated representations made in its request for the no-action
position granted in Staff Letter 24-12, excluding its representation that no participants shall clear
MIAXdx Contracts through any third party clearing member:

• MIAXdx will require that all MIAXdx Contracts be fully collateralized;

• MIAXdx will clear the MIAXdx Contracts solely through MIAXdx;

• MIAXdx will publish on its website the following time and sales data for all MIAXdx
Contracts transactions promptly after execution thereof – trade timestamp, contract,
quantity, and price (in USD);

• MIAXdx shall provide DMO with transactional information as described in Commission
regulation 16.02;

• MIAXdx shall continue to comply with all SDR and recordkeeping requirements of the
CEA and Commission regulations, other than the Relevant Regulations, including (without
limitation) the applicable requirements of Parts 38 and 39 of the CFTC’s regulations (the
records described in this Undertaking 5 are referred to below as the “Required Records”);

• MIAXdx shall keep the Required Records open to inspection upon request by any
representative of the Commission, the United States Department of Justice, or the
Securities and Exchange Commission, or by any representative of a prudential regulator as
authorized by the Commission. Copies of all such records shall be provided at the expense
of MIAXdx to any representative of the Commission upon request. MIAXdx shall provide
copies of the Required Records either by electronic means, in hard copy, or both, as
requested by the Commission, with the sole exception that copies of records originally
created and exclusively maintained in paper form may be provided in hard copy only
es of all such records shall be provided at the expense
of MIAXdx to any representative of the Commission upon request. MIAXdx shall provide
copies of the Required Records either by electronic means, in hard copy, or both, as
requested by the Commission, with the sole exception that copies of records originally
created and exclusively maintained in paper form may be provided in hard copy only.

No-Action Position and Related Conditions

The Divisions have decided to take a no-action position consistent with MIAXdx’s
Request, subject to certain conditions described below, based largely on MIAXdx’s
representations and statements in support of the Request, because the Divisions believe, based on
MIAXdx’s representations, that the justifications underlying Staff Letter 24-12 continue to apply.
Given that MIAXdx has made rulebook amendments to allow FCM participation in clearing
intermediation, consistent with the requirements of its DCM Order of Designation and DCO Order
of Registration, the Divisions have determined it is appropriate to remove the corresponding
condition in Staff Letter 24-12, condition 6, prohibiting third-party clearing by participants. The
Divisions also believe that removing condition 6 is consistent with the approach taken in Staff
Letters 24-09 and 25-02, which do not contain a condition prohibiting third-party clearing by

24 Request at 1-2.

5

participants.25 The Divisions will not recommend that the Commission initiate an enforcement
action against MIAXdx or its participants for failure to comply with Commission regulations
38.8(b), 38.10, 38.951 (only to the extent that regulation 38.951 requires compliance with Part 45
of the Commission’s regulations), 39.20(b)(2), as well as the applicable provisions of Parts 43 and
45 of the Commission’s regulations, or the requirements of the relevant CEA provisions pursuant
to which the Relevant Regulations were promulgated, with respect to MIAXdx Contracts, subject
to the following conditions:26

1)
MIAXdx will
that regulation 38.951 requires compliance with Part 45
of the Commission’s regulations), 39.20(b)(2), as well as the applicable provisions of Parts 43 and
45 of the Commission’s regulations, or the requirements of the relevant CEA provisions pursuant
to which the Relevant Regulations were promulgated, with respect to MIAXdx Contracts, subject
to the following conditions:26

1)
MIAXdx will require all MIAXdx Contracts to be fully collateralized positions, as
defined by Commission regulation 39.2;27

2)
MIAXdx will clear all MIAXdx Contracts through MIAXdx and MIAXdx will
clear all MIAXdx Contracts;

3)
MIAXdx will publish on its website the following information for all MIAXdx
transactions promptly after execution thereof: trade timestamp, contract quantity,
and price;

4)
MIAXdx will provide the Commission with all transactional information as
described in Commission regulation 16.02;

5)
MIAXdx will comply with all reporting and recordkeeping requirements of the
CEA and CFTC regulations applicable to it in its respective capacities as a DCM
and a DCO, other than the Relevant Regulations, including, but not limited to, the
applicable requirements of Parts 38 and 39 of the Commission’s regulations (the
records required to be retained by this condition (5) are referred to below as the
“Required Records”);

6)
MIAXdx keeps the Required Records open to inspection upon request by any
representative of the Commission, the United States Department of Justice, or the
Securities and Exchange Commission, or by any representative of a prudential
regulator as authorized by the Commission. Copies of all such records shall be
provided, at the expense of MIAXdx, as applicable, to any representative of the
Commission upon request. MIAXdx, as applicable, shall provide copies of the
Required Records either by electronic means, in hard copy, or both, as requested

25 See CFTC Letter No. 24-09 (July 12, 2024), available at https://www.cftc.gov/csl/24-09/download and CFTC Letter
No
Copies of all such records shall be
provided, at the expense of MIAXdx, as applicable, to any representative of the
Commission upon request. MIAXdx, as applicable, shall provide copies of the
Required Records either by electronic means, in hard copy, or both, as requested

25 See CFTC Letter No. 24-09 (July 12, 2024), available at https://www.cftc.gov/csl/24-09/download and CFTC Letter
No. 25-02 (Jan. 31, 2025), available at https://www.cftc.gov/csl/25-02/download.
26 Some of these conditions regarding the no-action position may constitute a collection of information, as that term
is defined in the Paperwork Reduction Act, 44 U.S.C. §§ 3501 et. seq. The Office of Management and Budget
(“OMB”)—in accordance with 44 U.S.C. § 3507(d) and 5 C.F.R. §§ 1320.8 and 1320.10—has approved collection
3038-0049, entitled “Procedural requirements for requests for interpretative, no-action and exemptive letters,” for
such purposes. This collection would encompass collections made as part of exemptive or no-action position from the
Commission or its staff. The public is not required to respond to a collection of information that does not have a valid
OMB control number.
27 CFTC regulations define “fully collateralized position” as “a contract cleared by a derivatives clearing organization
that requires the derivatives clearing organization to hold, at all times, funds in the form of the required payment
sufficient to cover the maximum possible loss that a party or counterparty could incur upon liquidation or expiration
of the contract.” 17 C.F.R. § 39.2.
27 CFTC regulations define “fully collateralized position” as “a contract cleared by a derivatives clearing organization
that requires the derivatives clearing organization to hold, at all times, funds in the form of the required payment
sufficient to cover the maximum possible loss that a party or counterparty could incur upon liquidation or expiration
of the contract.” 17 C.F.R. § 39.2.

6

by the Commission, with the sole exception that copies of records originally created
and exclusively maintained in paper form may be provided in hard copy only.

This letter expresses a staff position only with respect to enforcement of the Relevant
Regulations. This letter does not state any legal conclusion regarding the characteristics or legality
of MIAXdx Contracts or the conduct of any person covered by the no-action position.28 This letter
and the no-action position taken herein represent the views of the Divisions only, and do not
necessarily represent the positions or views of the Commission or of any other Commission
division or office. This letter and the no-action position taken herein are not binding on the
Commission.29 Except as explicitly provided in this letter, the no-action position taken herein does
not excuse persons from compliance with any applicable requirements of the CEA or Commission
regulations. Further, this letter, and the no-action position contained herein, are based upon the
representations made to the Divisions. Any different, changed, or omitted material facts or
circumstances may render this letter void. As with all no-action letters, the Divisions retain the
authority to, in its discretion, further condition, modify, suspend, terminate or otherwise restrict
the terms of the no-action position provided herein
tion position contained herein, are based upon the
representations made to the Divisions. Any different, changed, or omitted material facts or
circumstances may render this letter void. As with all no-action letters, the Divisions retain the
authority to, in its discretion, further condition, modify, suspend, terminate or otherwise restrict
the terms of the no-action position provided herein.

If you have any questions concerning this letter, please contact Alicia Viguri, Division of
Market Oversight, at (202) 418-5219 or aviguri@cftc.gov; Paul Chaffin, Division of Market
Oversight, at (202) 418-5185 or pchaffin@cftc.gov; Owen Kopon, Division of Market Oversight,
at (202) 418-5360 or okopon@cftc.gov; or Eric Schmelzer, Division of Clearing and Risk, at (202)
836-0567 or eschmelzer@cftc.gov.

Sincerely,

____________________
________________________
Richard Haynes
Acting Director

Division of Clearing and Risk

Rahul Varma
Acting Director
Division of Market Oversight

28 For the avoidance of doubt, this letter is not intended to address whether any of the MIAXdx Contracts are consistent
with any statutory or regulatory requirement, including with respect to the requirements of CEA section 5c(c)(5)(C)
or Commission regulation 40.11. 17 C.F.R. § 40.11.
29 See 17 C.F.R. § 140.99(a)(2) (“A no-action letter binds only the issuing Division… and not the Commission or
other Commission staff.”).

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CFTC_L25_45. Check the current official text before relying on it. Not legal advice.