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CFTC’s Division of Market Oversight Seeks Public Comment on Proposed

No-Action Position to MIAX Futures Exchange, LLC (2025/6/23)

The Division of Market Oversight (DMO) of the Commodity Futures Trading

Commission is seeking public comment on a proposed no-action position to MIAX

Futures Exchange, LLC (MIAX Futures), a designated contract market (DCM),

pursuant to Commission Regulation 140.99. Comments must be submitted by 12 p.m.

EDT on June 25, 2025.

By letter dated June 23, 2025, MIAX Futures requested that DMO issue a letter

stating that it will not recommend enforcement action to the Commission in

connection with MIAX Futures’ temporary provision for the trading of Minneapolis

Hard Red Spring Wheat (HRSW) options on futures (HRSW Options) exclusively

through block trades. The requested relief is necessary due to the unavailability of an

electronic trading system for the HRSW Options and is intended to allow market

participants, including those who are not eligible contract participants (ECPs) as

defined in section 1a(18) of the Commodity Exchange Act (CEA), to trade or offset

open positions.

MIAX Futures has proposed amendments to its rulebook, effective from June 30

through August 29, 2025, to: (i) permit block trading of HRSW Options outside of a

centralized market; (ii) lower the block trade threshold for HRSW Options from 15

contracts to one contract; and (iii) permit non-ECPs to participate in block trades of

HRSW Options.

In order to implement these rulebook amendments, MIAX Futures seeks

no-action relief from DCM Core Principle 9, Commission Regulation 1.38, and CEA

section 5c(c) and related regulations under Part 40. Staff proposes granting

time-limited relief, as described in the proposed letter, to reduce the risk of market

disruption and to provide market participants additional time to manage or exit open

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