In accordance with PHLX Rule1042A, NOM Chapter VIII-Section 1, and BX Chapter VIII-Section 1, members and member firms must submit a Memorandum to Exercise notice to the Exchange no later than five (5) minutes after the close of each respective American-style index option (i.e. 4:00 p.m. ET or 4:15 p.m. ET). 

Members and member firms may submit a Memorandum to Exercise when exercising any American-style index option contract(s) in the following manner no later than five (5) minute after the close of trading:

• Complete, time-stamp and submit a PHLX Index Option Exercise Advice Form to the Nasdaq Surveillance Department
  
  
• Submit an index option exercise advice notice to the Options Clearing Corporation (“OCC”) through your respective clearing firm(s)
  
  
• Submit an e-mail index option exercise advice notice to the Nasdaq Surveillance Department

The provisions set forth of the aforementioned rules are not applicable on the last business day of expiration. In the case of an option contract expiring on a day that is not a business day, the aforementioned rules are not applicable the business day prior to the expiration of such series of options.

As a reminder, members and member firms may electronically submit Exercise Advice notices to the OCC or electronically e-mail index option exercise instructions to Nasdaq Surveillance Department in order to meet the five (5) minutes after the close of trading of each respective American-style index option 4:00 p.m. ET or 4:15 p.m. ET cut-off time. The time e-mail is received by the Exchange for an Exercise Advice or electronic submission is received by the OCC system for a Memorandum to Exercise will be the official time-stamp of the submission. It is the responsibility of the member to ensure the Exchange and OCC receive the instruction(s) by the cut-off time. 

Members and member firms are also reminded that the Exercise Advice submission to the Exchange for compliance purposes does not replace or constitute intent to exercise to the OCC.

As such, please allow sufficient time for the e-mail to be received by the Exchange’s e-mail system. Waiting too long to send your exercise instruction(s) may put you at risk of non-compliance with the submission cut-off time requirements. The Nasdaq Surveillance staff will confirm the receipt of your electronic exercise advice e-mail submission.