This letter further extends no-action positions provided by DMO for those package transactions where at least one individual swap component is made available to trade and therefore subject to the trade execution requirement under CEA section 2(h)(8), and all other components are contracts for the purchase or sale of a commodity for future delivery, i.e. futures contracts (“MAT/Futures Package Transactions”).

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.