Effective September 1, 2026, Nasdaq ISE (ISE), Nasdaq GEMX (GEMX), Nasdaq MRX (MRX), and Nasdaq Phlx (Phlx) will amend Options 2, Section 5 to modify the manner in which quoting obligations are aggregated and counted toward applicable quoting requirements for market makers associated with the same member.

Today, market makers in overlapping roles are required to meet each market making obligation separately. On Phlx, this means Lead Market Makers (“LMMs”), Directed Lead Market Makers (“Directed LMMs”), and Directed Streaming Quote Traders/Remote Streaming Quote Traders (“Directed SQTs/RSQTs”) are subject to distinct 90% continuous two-sided quoting obligations that are calculated separately by role. On ISE, GEMX, and MRX, Primary Market Makers (“PMMs”), Preferred Primary Market Makers (“Preferred PMMs”), and Preferred Competitive Market Makers (“Preferred CMMs”) are similarly subject to separate 90% continuous two-sided quoting obligations, each measured independently by role.

With this proposal, each exchange will aggregate quoting activity across all market maker roles that have a 90% continuous, two-sided quoting obligation (or such higher percentage as the applicable exchange may announce), when badges and options series are assigned within the same member organization or Member. For example, on ISE, compliance with the continuous, two-sided quoting obligations of PMMs, Preferred PMMs, and Preferred CMMs will be calculated together.

Therefore, the current requirement that a member satisfy LMM (or PMM), Directed LMM (or Preferred PMM), and Directed SQT/RSQT (or Preferred CMM) quoting obligations separately is eliminated. Separate compliance tracking for these overlapping roles within the same firm will no longer be required.

The substantive quoting standard remains unchanged. LMMs, Directed LMMs, and Directed SQTs/RSQTs on Phlx, and PMMs, Preferred PMMs, and Preferred CMMs on ISE, GEMX, and MRX, will continue to be required to provide continuous two-sided quotations in 90% of the cumulative number of seconds during the trading day (or such higher percentage as the applicable Exchange may announce). The amendment adjusts only the methodology by which activity is measured; it does not relieve any participant of the underlying obligation to quote continuously.

Further, the 60% continuous two-sided quoting obligation applicable to SQTs and RSQTs on Phlx, and to Competitive Market Makers on ISE, GEMX, and MRX, is unchanged. A member that is an SQT/RSQT (Phlx) or a Competitive Market Maker (ISE, GEMX, and MRX) in an options series where it is also assigned as the LMM or PMM, respectively, in that same options series will continue to be held to both sets of obligations separately in that options series. Also, an SQT or RSQT (Phlx), or a Competitive Market Maker (ISE, GEMX, and MRX), that executes a Directed Order or Preferenced Order will continue to be held to the standard of a Directed SQT/RSQT or Preferred CMM, as applicable.

ORA 2026-48 supersedes ORA 2021-36 only as it pertains to the 90% continuous quoting obligation.