Title: 25-17
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After considering the request of MIAX Futures and related facts and circumstances, the Division believes that temporary no-action positions are warranted to provide participants in the HRSW Options market with a means to trade out of or offset their open positions in the September 2025 and December 2025 expirations when electronic trading is no longer available. Accordingly, the Division will not recommend that the Commission take an enforcement action against MIAX Futures in connection with the implementation of the Temporary HRSW Options Block Trading Protocol under DCM Core Principle 9 and Commission regulation 1.38.
Further, the Division will not recommend that the Commission take an enforcement action against MIAX Futures under CEA section 5c(c) of the Act and associated Commission regulations under Part 40 if MIAX Futures amends its rulebook to implement the Temporary HRSW Options Block Trading Protocol before June 30, 2025, when an electronic trading system will no longer be available for the HRSW Options.